● Information Company Collects and Receives;
● How Company Uses Your Information (purpose);
● Sharing Information with Third Parties;
● Third-Party Content;
● Cookies and Other Web Technologies;
● Your Rights;
● How We Protect Your Information;
● Transfer of Data Outside Your Territory;
● Information Security;
● Do Not Track;
● How to Contact Company.
Information Company Collects and Receives.
When you Use the Website, Software & Services, we automatically collect and store the following types of information:
1. Online Identifiers. The Software & Services on the Website include collecting or generating an online identifier that associate a User with a device. The identifier parameter might vary as dependency of the type of Use and includes installation ID that our system randomly generates when you Use the Software & Services on the Website, or cookie ID or IP address.
2. Device and Technical Information. Certain technical information regarding your device, and your Use of the Software & Services on the Website, including, for example, the device type and version number, name and version of operating system Internet protocol (IP) address, anonymous user identifiers such as cookies and similar web technologies (for more information see under Cookies and Other Technologies below) and your configuration and settings of the device including language and time zone;
3. Usage Information. Certain usage related information regarding your use and interaction with the Software & Services on the Website, your language settings, your engagement with elements and features of the Software & Services as used by you on the Website, including button clicks, relevant jobs offerings you interacted with, your search queries as defined by you with respect to your job search criteria, time and date of your search queries, details about your visits to the Website, communication data and the resources that you access and use on a Website;
4.Contact Related Information. If you communicate with us via email or the “Contact Us” section in the website, we may also collect your email address, name and any information voluntarily submitted by you in connection with such engagement initiated by you (for example, your name, company name, and particular query or request).
How Company Uses Your Information.
Use of PII
As stated above, we collect the following information from you:
● User agent (technical information related to your use of the relevant browser, for example: browser version, etc.)
● IP Address
● Install-ID (for installations of specific software such as Browser Extensions)
● Cookie ID
● URL Referrer (indicates the last page the user was on)
● Job search terms
● PII provided by you as part of the registration process for the email notification service;
● Support related information (when you use the “Contact Us” section)
The following describes how we use such information (also, the “Purpose”):
1.To provide you with the Software & Services on the Website, and related features, content and job search services and functionality, including providing you with the search results displayed on the Websites detailing relevant job offerings of ClientConnect, Inc’s partners included on the Website and sending you (via email) notifications of jobs offerings which we believe would be of interest to you. We also use this data for fraud detection and prevention as mentioned in detail below, and to assess the length of time of a user in our systems for service valuation purposes. We delete this data once our fraud and lifetime value assessment has been completed (as discussed in the next paragraphs). For this purpose, Company processes this information on the basis of your consent, which is freely and actively accepted by you when you first use our Software and Services on the Website.
In order to provide the job search services as part of the Software & Services on the Website, we use 3rd party providers in order to facilitate the provision of such job search services, we will share your IP address and your user agent with partners who provide you with certain job offering, including the results that match your job search criteria. To detect and prevent fraud on the Website.
Company uses each of the following, and in some cases, the combination of IP Address, Cookie Id, Install-ID, URL Referrer and Search Term to conduct fraud detection on potentially fraudulent and illegal uses of the Software & Services on the Website, in both the Use of the Software & Service, and on the business to business serving and measurement level. We need this information for 3 months to conduct this fraud analysis. Following this 3-month period, we will delete all data except for the Cookie-ID and Install-ID which we use for business performance analysis as described in the next paragraph. For this purpose, Company processes this information on the basis of a legitimate interest for preventing fraud.
In performing fraud detection and prevention, we use the services of third parties who will receive and access your Personal Information as described in this Section 2.
2. Disputes and Enforcement; Applicable law, regulations or Enforceable Governmental Request.
We use your PII to take action in case of a dispute involving you in connection with the Software & Services on the Website and to enforce the terms and conditions applicable to the Software & Services on the Website. We also use your PII to comply with legal and regulatory requirements (e.g., the disclosure of information to law enforcement or tax authorities), and to protect against suspicious or other illegal activities.
For this purpose, we may share your information with law enforcement or other competent authorities and any third party, as may be required (e.g to respond to claims or satisfy any legal process, subpoena, or governmental request; or to protect the rights, property, or personal safety of Company’s users, its partners, or the general public). We will also share this information with our professional advisors in the scope of this purpose.
We will retain this Personal Information for the amount of time as required by law to fulfil the above purposes. This may include ensuring that we have an accurate record of your dealings in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your PII or dealings.
Use of Non-PII
Company uses non-PII information it collects (including information that was fully anonymized with inability to be associated or attributed to an individual person), for the following purposes:
1. To operate and update the Software & Services on the Website, and to provide you with existing and new functionality and features of the Software & Services on the Website and additional job offerings.
2. to improve, fix and customize the Software & Services on the Website over time.
3. to monitor, analyze and optimize our users Use of the Software & Services, including analyzing seasonal and annual usage trends, in a form of aggregated data, and providing certain technical and usage information to our business partners as part of the job search services we provide on the Website.
4. to maintain and improve the quality and operation of the Software & Services on the Website, including, monitoring viewability of and interaction with the job offerings provided to you on the Website and other products and services provided by Company.
We retain this information for as long as necessary to fulfil our business and/or operational purposes or comply with a legal or regulatory requirement. We may also choose to anonymize parts of your PII so that it can no longer be identifiable or attributable to any unique device or person if we want to keep it for longer periods of time than the retention periods set forth above.
Additional Sharing of PII with Third Parties.
Except as described above, we may share your information with the following categories of third parties, for the respective purposes:
● Third party tools and services that enable easy and secure analysis of data, of usage of the Software and Services and extracting business insights and metrics. For example, Google Analytics.
● With our subsidiaries, affiliated and parent companies pursuant to the legitimate interest for the provision of the Software & Services on the Website.
● In the event Company goes through a business transition such as a merger or acquisition by another company, consolidation, change of control, reorganization, or sale of all or a portion of its assets, your information will be among the assets transferred;
Transferring Personal Information From and Outside of the European Union.
We will take appropriate steps to ensure that transfers of your PII are in accordance with applicable laws and carefully managed to protect your privacy rights and interests. To this end, if we as the data controller share your information with our corporate affiliates or third party service providers outside the EEA, we have – prior to sharing your information with such corporate affiliate or third party service provider – established the necessary means to ensure an adequate level of data protection. We will provide further information on the means to ensure an adequate level of data protection on request.
As part of the provision of the Software & Services on the Website, ClientConnect will present to you job offerings from third party partners, to be displayed on the Website, in accordance with the search criteria provided by you (collectively, “Third Party Content and Services”).
The Third Party Content will include references to relevant jobs published by third parties, that match the job search terms entered by you. By clicking on any job offer included in the Third Party Content displayed on the Website you will be transferred to a partner’s website that will provide you with further details on the relevant job offering you clicked. ClientConnect may share the user IP and user agent with such Third Parties for the sole purpose of providing you with the job offerings suitable to your request and search criteria and will enable you to further interact with such job offering provided by our third-party partners. The use of such Third-Party Content and Services is subject to their privacy policies. In order to clarify, we do not review, approve, monitor, endorse, warrant, or make any representations with respect to such Third-Party Content and Services to which you will be referred to from the Website and your review of the Third Party Content from our Website and further access to any Third-Party Content Services by following such job offering into the partner’s website is at your own risk. We are not responsible for the information contained and/or made available through, the practices of, or your use or inability to use such Third-Party Content and Services. You expressly relieve us from any and all liability arising from your use of such Third-Party Content and Services. We recommended that you read the terms, conditions and privacy policies of such Third-Party Content and Services before using or accessing any of them.
Cookies and Other Technologies.
As indicated above, the Software & Services on the Website collects or allows third parties to collect, through blocks of code called “pixels” or “web beacons”, certain information about you and send it to our servers and to our partners (either directly or indirectly). We or our partners, may package all or part of this information into small text files called Cookies and send the Cookie to your computer. As an example, Cookies may store job search terms made through the Software & Services or relevant jobs you clicked, the web pages you accessed, your interaction with job offerings presented to you via the Software & Services on the Website, features you used, your session duration and your configurations and preferences of the Software & Services on the Website. You can learn more about cookies on the Internet Advertising Bureau’s website: http://www.allaboutcookies.org.
Most browsers are initially set up to accept Cookies but you can reset your browser to refuse all Cookies or to indicate when a Cookie is sent. However, some functions of the Software & Services on the Website may not function properly if your cookies are disabled.
The Software & Services on the Website are not intended for minors in any jurisdiction and you hereby represent that you are not a minor according to you relevant jurisdiction. For example, users under the age of 13 in the United States and users under the age of 16 in the European Union are not permitted to use the Software & Services. We do not knowingly collect, use, share or disclose any personal information from minors. We reserve the right to request proof of age at any stage, so that we can verify that minors are not using the Software & Services.
We advise parents and guardians to regularly monitor their children’s use of email and other online communications and activities. Control tools that create a safer online environment for children are available from third party online services and software providers.
In the event that it comes to our knowledge that a minor is using the Software & Services on the Website, we will prohibit and block such a user from accessing the Software & Services on the Website and will make all efforts to promptly delete any PII with regard to such user, as applicable.
The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR or the CCPA):
○ You have a right to access personal data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
○ You have the right to request that we rectify any personal data we hold that is inaccurate or misleading;
○ You have the right to request the erasure/deletion of your personal data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your personal data, for example for the establishment, exercise or defense of legal claims;
○ You have the right to object, to or to request restriction, of the processing;
○ You have the right to data portability. This means that you may have the right to receive your personal data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
○ You have the right to withdraw your consent to processing your personal data at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
○ You also have a right to request certain details of the basis on which your personal data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
○ You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.
If you are a California resident, the following rights may apply to you:
○ You have the right to know what personal information is being collected about you in the twelve months preceding your request;
○ You have the right to request the erasure/deletion of your personal data (e.g. from our records and the records of our service providers). Please note that there may be circumstances in which we are required to retain your personal data, for example for the establishment, exercise or defense of legal claims;
○ You have the right to know whether your personal information is sold or disclosed and to whom in the twelve months preceding your request; Please be noted that we do not sell your information.
○ You have the right to equal service and price, even if you exercise your privacy rights;
○ You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence (e.g. the Attorney General in your State). We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.
Exercising your Rights. You can exercise your rights by contacting us as provided under https://www.jobsfuel.com/contact/. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfill your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
How we Protect your Information.
Do Not Track.
Do Not Track is a privacy preference that can be configured in certain web browsers (the “DNT Feature”); the DNT Feature, when enabled on a web browser, signals the websites you visit that you do not want certain information about your visit collected. Company does not currently respond or recognize DNT Feature signals.
If you have any complaints on our processing of your PII or if you believe that we have breached our own privacy policies or applicable law, we encourage you to contact us. However, please note that applicable EU data protection laws provide you with a right to lodge a complaint with the competent supervisory authority as well.
How to Contact Company.
Attention: General Counsel
1 World Trade, 77th Floor
New York, NY 10007
Last updated: January 20, 2022