We at Comeet Technologies, Inc. (“Comeet“, “we”, “us”, “our”) develop and operate a recruiting and applicant tracking platform (the “Platform”) for companies with positions they are recruiting for (the “Recruiting Company”).
This Privacy Notice (the “Notice“) describes the ways that the Recruiting Organization, using Comeet’s Platform, handles your personal data. It also describes the rights and options available to you with respect to your information.
Please note that this Notice covers the Platform’s privacy practices in general matters. The Recruiting Company may have an additional privacy notice explaining its own specific privacy practices related to your personal data (the “Recruiting Company’s Notice”). You should also read the Recruiting Company’s Notice. You can access it through the link that may be provided to you in the email you received from the Recruiting Company or by contacting the Recruiting Company and requesting a copy. If the Recruiting Company’s Notice conflicts with this Notice, then the Recruiting Company’s Notice will apply.
DATA CONTROLLER AND DATA PROCESSOR
The Recruiting Company is the data controller of the personal data on the Platform.
Comeet is the data processor on behalf of the Recruiting Company.
The Recruiting Company is the data controller of your personal data on the Platform. It determines the purposes and means of processing your data. You can review the Recruiting Company’s contact information in the Recruiting Company’s Notice. Comeet is the data processor of your personal data on the Platform, processing the data on behalf of the Recruiting Company. Comeet’s address is 109 South 5th Street, Brooklyn, New York, United States. We can be reached by email at firstname.lastname@example.org.
PERSONAL DATA PROCESSED
We process information about you relating to your candidacy for positions at the Recruiting Company.
You are not legally required to provide us your information.
We process the following information about you as a candidate for positions at the Recruiting Company: contact information, address, Curriculum Vitae (resumé) information (including information such as skills, work experience, education), notes submitted with the application, URL of your LinkedIn and other online profiles, the position for which you have been or are being considered, the source who submitted your candidacy (e.g., recruiting agency, referral), email correspondences between you and the Recruiting Company and between the Company and other sources (such as recruiting agency and referrals) about your candidacy, information from references, events in the lifecycle of your candidacy, your responses to questionnaires sent to you by the Recruiting Company, information about your candidacy and employment options (such as availability to be hired and salary expectations), evaluations of your candidacy, internal discussions within the Recruiting Company about your candidacy, materials you or other parties (such as evaluators or background check providers) submitted in relation to your candidacy.If you submit your candidacy by email, or online, then you are the main source of the personal data. In that case, you do not have a legal duty to provide the information, and providing it, is subject to your desire. However, the information is necessary for the Recruiting Company to consider your candidacy for the position.Your personal data on Comeet can also originate from other sources, such as LinkedIn profile, recruitment agencies and headhunters and referrals. For more information about the source from which your personal data originates, contact the Recruiting Company, in accordance with the Recruiting Company’s Notice.
We also collect analytical information about your use of the Platform and your recruitment process.
When you use the Platform we will collect statistical and analytics information about your use of the Platform, and de-identified information about your candidacy, including: IP address from which you accessed the Platform, time and date of access, type of browser used, language use, links clicked, actions taken while using the Platform, de-identified information about your skills, education and experience, your salary expectations, and your recruitment process (“Analytical Information“).
HOW YOUR PERSONAL DATA IS USED
The Recruiting Company will use your personal data to evaluate and consider you as a candidate for positions
The Recruiting Company will use your personal data to evaluate and consider you as a candidate for positions, in accordance with its processes and policies for evaluating employment candidates. The Recruiting Company will also use this information to contact you about job openings and your candidacy. The legal basis under EU law for processing your personal data for this purpose is for the Recruiting Company’s legitimate purpose in evaluating candidates for positions.
Comeet will use the Analytical Information for quality assurance and business development purposes of the Platform
We will use the Analytical Information statistics for quality assurance and business development purposes of the Platform, for improving hiring processes, for improvement of the Platform and its user experience, helping Recruiting Companies understand candidates’ fit for job openings and find relevant candidates for job openings. We also use the Analytical Information for aggregated content and benchmarks that help recruiters, managers and candidates like yourself (such as salary ranges for job positions). The legal basis under EU law for processing this is the legitimate purposes in developing, enhancing and maintaining the Platform.
WHO WILL PROCESS YOUR DATA
We will not share your information with third-party recipients, except as listed below, or if you give your explicit consent.
Your personal data will be handled by our service providers helping us operate the Platform
We will share your personal information with our service providers who assist us with the internal operations of the Platform. These companies are authorized to use your personal information only as necessary to provide these services to us and not for their own promotional purposes. We do not sell your personal information to third parties. A detailed list of those service providers is available at http://help.comeet.co/en/articles/3132004-comeet-sub-processors.
We will share your general recruitment status with third parties who submitted your candidacy to the Recruiting Company.
Submissions by third-parties. If your details are submitted to the Recruiting Company by a third-party (such as an employee of the recruiting company or a recruiting agency), the Recruiting Company can give the third-party access to your name, photo and general recruitment status.
Indirect referrals. If you apply to a job opening using a unique referral link that was provided to you by an employee of the Recruiting Company to which you are applying, the Recruiting Company may share your general recruitment status, without identifying you by name, with the person that provided you the referral link.
The purpose of sharing the above information is to operate incentive programs (i.e. employee referral bonus programs) of the Recruiting Company and to provide feedback to third-parties who submit candidates to the Recruiting Company regarding their submission.
The legal basis under EU law for processing your personal data in this manner is the Recruiting Company’s legitimate purpose in running its recruitment program.
We will share your Information with competent authorities, if you abused your rights to use the Platform, or violated any applicable law.
If you have seriously abused your rights to use the Platform, or violated any applicable law, we will share your information with competent authorities and with third parties (such as legal counsels and advisors), for the purpose of handling of the violation or breach. The legal basis under EU law for processing your data for this purpose is our legitimate interests in defending and enforcing against violation and breaches that are harmful to our business.
We will share your Information if we are legally required.
If we are required to disclose your information by a judicial, governmental or regulatory authority. The legal basis under EU law for processing your data for this purpose is our legitimate interests in complying with mandatory legal requirements imposed on us.
We will share your Information with third-party in any event of change in Comeet’s structure.
If the operation of the Platform is organized within a different framework, or through another legal structure or entity (such as due to a merger or acquisition, we will share your information only as required to enable the structural change in the operation of the Platform. The legal basis under EU law for processing your data for this purpose is our legitimate interests in our business continuity.
SECURITY AND DATA RETENTION
Details of the data retention periods are explained in the Recruiting Company’s Notice.
In general, the Recruiting Company will keep your data for an initial retention period and it can then pseudonymize it.
Once pseudonymized, your data will be restored if you subsequently apply or are applied to another position.
You can consent to the Recruiting Company keeping your data for a longer retention period in order to contact you about positions in the future.
The storage periods for your personal data and the criteria used to determine them, are specified by the Recruiting Company. In general, the Recruiting Company will retain your personal data on Comeet for an initial retention period. That initial retention period is determined by the Recruiting Company as specified period of time (e.g., 6 months) after the latest of: (1) the Recruiting Company adding your data to Comeet, and (2) the last activity the Recruiting Company performed regarding your candidacy on Comeet. Once that initial retention period has passed, The Recruiting Company can pseudonymize your data. If it does so, your data will be restored if you subsequently apply to a position at the Recruiting Company or if you are subsequently submitted for a position at the Recruiting Company by others.The Recruiting Company may ask for your consent to keep your data for a longer period of time after the initial retention period, so that it can more easily contact you about opportunities in the future. In that case, the legal basis for retaining your data beyond the initial retention period is your consent. If you’ve given your consent, you can withdraw it at any time by contacting the Recruiting Company, in accordance with the Recruiting Company’s Notice. Note that in any event, a backup copy of your data will be kept for a period of up to one year following data removal or pseudonymization, for purposes such as disaster recovery. Please review the Recruiting Company’s Notice for more information about the specified retention periods.
We implement measures to secure your Information
We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of information. However, these measures do not provide absolute information security. Therefore, although efforts are made to secure your personal information, it is not guaranteed, and you cannot expect that the Service will be immune from information security risks.
INTERNATIONAL DATA TRANSFERS
We will perform international transfer of your Information only in accordance with data protection laws.
We transfer your personal data from within the European Union to locations outside the European Union. Comeet is located in the United States and is involved in processing your data there. International data transfers to Comeet are safeguarded with EU Commission certified standard data protection contract clauses.The safeguards for international data transfers to Comeet’s sub-processors are set out in Comeet’s list of sub-processors in http://help.comeet.co/en/articles/3132004-comeet-sub-processors.
YOUR EU RIGHTS
You have the right to access, update or delete your information and obtain a copy of your information.
If you are in the EU, you may ask the Recruiting Company to receive a copy of your personal information that is stored on the Platform, or have the Recruiting Company update, correct or delete your information. You are also entitled to obtain from the Recruiting Company your information in a structured, commonly used and machine-readable format, and have the right to transmit those data to another data controller. If you wish to exercise any of these rights, contact the Recruiting Company through the channels listed on the Recruiting Company’s Notice.
You have the right to opt-out of us processing data based on our legitimate interests,
You have the right to opt-out of Comeet processing your data for Comeet’s legitimate interests, unless we demonstrate that we have compelling legitimate interests which override your rights and freedoms. To exercise this right, contact us at email@example.com.
You have a right to submit a complaint to the relevant supervisory data protection authority.
Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. If you are in the EU, then according to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority, in particular in the Member State of your residence, place of work or place of alleged infringement of the GDPR.
For a list of supervisory authorities in the EU, click here (PDF document).
The Platform is not directed to candidates under 16. Inquiries concerning children’s information on the Platform should be addressed to the Recruiting Company.
The Platform is not directed to candidates under the age of 16. The Recruiting Company will have its own policies regarding under-aged candidates. Therefore, inquiries from parents concerning the use of children’s information on the Platform should be addressed to the Recruiting Company, in accordance with the Recruiting Company’s Notice.
CHANGES TO THIS PRIVACY NOTICE
If we change this Notice, we and the Recruiting Company will make efforts to proactively notify you of such changes.
From time to time, we may change this Notice. If we do so, we and the Recruiting Company will make efforts to proactively notify you of such changes. In any event, the latest version of the Notice will always be accessible at http://help.comeet.co/en/articles/3134994-privacy-notice.
General Data Protection Regulation (GDPR) - European Representative
Pursuant to Article 27 of Europe’s General Data Protection Regulation (GDPR), Comeet Technologies Inc. has appointed European Data Protection Office (EDPO) as its GDPR representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR by: using EDPO’s online request form or writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium
UK General Data Protection Regulation (GDPR) – UK Representative
Pursuant to Article 27 of the UK GDPR, Comeet Technologies Inc. has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR by: using EDPO UK’s online request form or writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom.