YOUR PRIVACY MATTERS

Table of Contents:

• Introduction
• Information We Collect
• How We Use Your Data
• How We Share Information
• Your Choices & Obligations
• Other Important Information

 

1. INTRODUCTION

Your personal information, will be held by Headstart AI and its subsidiaries (collectively referred to as ("Headstart", “we”, “us”, “our”). We care about your privacy and value the trust you place in us when giving us access to your personal data. This Privacy Policy (‘the Policy’) is to let you know how companies within Headstart AI promise to look after your personal information when you use our services (described below).

Headstart is Software used as a Service (SaSS). It is used by recruiters in their hiring functions (“Corporate User”) and candidates in their job search and/or applications (“Candidate User”) (collectively referred to as “User”, “you”).

This Policy supplements our Terms and Conditions and Cookie Policy. It ensures that you are fully informed as to what personal information we collect from you, how it is used, shared, and protected, and your rights in connection with our Services (described below).

Services: This Policy applies to Headstart.io, Headstartapp.com, their sub-domains and other Headstart-related sites, apps, communications and services (“Services”).

Change: Headstart can modify this Policy, and if we make material changes to it, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective. If you object to any changes that we make, you have the right to discontinue access or use of our Services and to close your Account.

You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Policy means that the collection, use and sharing of your personal information is subject to the updated Privacy Policy.

 

2. WHAT INFORMATION DO WE COLLECT?

We collect personal information about you to the extent it is necessary to provide our Services to you. This information may vary depending on whether you are a Corporate User or Candidate User.

2.1 DATA YOU PROVIDE TO US

When you register, create an account or profile (collectively referred to as “an Account”) the information you provide to us will include personal and special category data that directly or indirectly identifies you, such as your name, email, work history, educational background, spoken languages, date of birth or living address. You have choices about the information you provide to us, and the personal information we will require from you will vary depending on whether you are a Candidate User or Corporate User, and on how you are using our Services.

2.2 DATA FROM OTHERS

Others buying our Services for your use, such as your employer, provide us with personal data about you, such as your name, email address and position, in order for us to create you an Account for them as a Corporate User of our services.  In such instances you should review your employer’s own Privacy Notice as well as ours.

In relation to a Candidate User, we will also collect information about you from recruiters who form part of the Service relationship, such as feedback on your interview, interview dates and other such information that pertains to using our Services.

2.3 CUSTOMER SUPPORT

We will collect personal information from you if you contact us with a question, need help or have feedback. This will usually include your name, email and telephone number as well as the contents of your message.

2.4 SERVICE USE

We log usage data whenever visitors view our website or otherwise use our Services, including our sites, app and platform technology (e.g., our off-site plugins).  These will include the provision of information about the frequency and duration of your activities, such as when you progress in the Account setup. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.

2.5 COOKIES, WEB BEACONS AND OTHER SIMILAR TECHNOLOGIES

As further described in our Cookie Policy, we use cookies and similar technologies (e.g., pixels, ad tags and device identifiers) to recognise you and/or your device(s) on, off and across different Services and devices. Some third parties may also use cookies as described in our Cookie Policy.

You can control cookies through your browser settings and other tools. Please note that if cookies are disabled or removed, not all features of our Services will operate as intended.

2.6 YOUR DEVICE AND LOCATION

When you visit or leave our Services (including our plugins or cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to next. We also receive information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or your ISP or mobile carrier. If you use our Services from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location.

2.7 MESSAGES, CHAT AND EMAILS

We collect information about you when you send, receive, or engage with messages, chat and emails in connection with our Services.

2.8 OTHER

Our Services are dynamic, and we often introduce new features, which may require the collection of new information. If we collect materially different personal data or materially change how we use your data, we will notify you and will also modify this Policy.  Wherever we deem it necessary we will first conduct a data protection impact assessment before introducing new ways of collecting or using your personal data.

3. HOW WE USE YOUR DATA

How we use your personal information will depend on:

• whether you are a Candidate User or Corporate User;
• which Services you use;
• how you use those Services;
• the choices you make in your settings.

We use the personal information that we have about you to provide and personalise, including with the help of automated systems (described below), our Services, and in some instances so that they can be more relevant and useful to Users.

3.1 CREATING AN ACCOUNT

We use your information to authorise your access to the Services, verify your identity, authenticate your visits, deliver our Services, including to personalise features and content, and make suggestions for you in connection with using our Services. This will vary depending on whether you are a Candidate User or Corporate User.

Corporate User: We will use the information to provide you with recommendations as to suitable candidates to your roles, analytics on how you are using the Services, how you interact with our Services and send reminders (depending on your settings).

Candidate User: We will use the information you provide us, in combination with other publicly available information, to provide you with job application information and updates, suitability to jobs, send reminders, facilitate communications between you and others through our Services (for example interview scheduling with recruiters), keep you informed of our products and services. We use automated systems to profile and provide recommendations to help make our Services fair and efficient.

3.2 COMMUNICATIONS

We will contact you through email, mobile phone, notices posted on our websites or apps and other ways through our Services, including text messages and push notifications. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use the Services, network updates and reminders. You may change your communication preferences at any time in your settings page. Please be aware that you cannot opt-out of receiving service messages from us, including security and legal notices.

3.3 DEVELOPING SERVICES

We use data, including public feedback, to conduct research and development for the further development of our Services in order to provide you and others with a better, more intuitive and personalized experience.

3.4 CUSTOMER SUPPORT

We use the data (which includes your communications) to investigate, respond to and resolve complaints and Service issues (e.g. bugs).

3.5 AGGREGATE INSIGHTS AND RESEARCH

We use the personal information available to us to research social, economic and workplace trends such as skills needed for jobs, generate statistics concerning your industry, etc. We only share insights and research as aggregated data i.e. this is data from a mass audience and therefore you are not identifiable.

3.6 SECURITY AND INVESTIGATIONS

We use your personal information (including your communications) if we think it’s necessary for security purposes or to investigate possible fraud or other violations of our Terms of Service or this Privacy Policy and/or attempts to harm our Users or visitors.

3.7 HOW WE USE YOUR INFORMATION TO MAKE AUTOMATED DECISIONS AND PROFILING

Some of the functionalities we offer include systems that make automated decisions about you, using data you or your employer provide or in combination with other publicly available information, some of which may be fully automated. This helps us to make sure our decisions are quick, fair, efficient and correct. This happens, for instance, when we predict Candidate Users suitability for roles or when we try to understand what type of candidates a Corporate User believes to be a better fit for a position. If you want to know more about this please contact us.

You can object to a fully automated decision, and ask that a person reviews it. If you want to know more about these rights, please contact us.

3.8 ADDITIONAL LIMITS ON USE OF YOUR GOOGLE USER DATA

Notwithstanding anything else in this Privacy Policy, if you provide the App access to the following types of your Google data, the App's use of that data will be subject to these additional restrictions:

The App will only use access to read, write, modify or control Gmail message bodies (including attachments), metadata, headers, and settings to provide a web email client that allows users to compose, send, read, and process emails and will not transfer this Gmail data to others unless doing so is necessary to provide and improve these features, comply with applicable law, or as part of a merger, acquisition, or sale of assets.

• The App will not use this Gmail data for serving advertisements.
• The App will not allow humans to read this data unless we have your affirmative agreement for specific messages, doing so is necessary for security purposes such as investigating abuse, to comply with applicable law, or for the App's internal operations and even then only when the data have been aggregated and anonymised.

 

4. HOW WE SHARE INFORMATION

4.1 OUR SERVICES

Your information is shared with others in the following ways:

CANDIDATE USER

We share your information with the employer whom you sought to apply to and were redirected to Headstart to apply (e.g., you applied for a job with company XYZ but completed your application through Headstart). Subject to your consent, we may also share your information with other employers that are using our Services.

CORPORATE USER

If your employer has registered for our Services as a Corporate User and provided us with your initial information, we will share with your employer information on how you use our Services e.g. when you log on, how long you were using our Services, the actions you undertake etc.

Your activities and communications might also be visible to other Corporate Users in your company depending on your role, the level of access permissions available to you, and the type of functionality you are using.

4.2 HEADSTART AI

We disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.

4.3 SERVICE PROVIDERS

We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.

4.4 LEGAL DISCLOSURES

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations, (4) protect the security or integrity of our Service (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of Headstart, our Users, personnel, or others. We attempt to notify Users about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

4.5 CHANGE IN CONTROL OR SALE

We may share your personal information as part of a sale (of Headstart AI or its subsidiary), merger or change in control, or like activities or in preparation for any of these events, subject to other security measures (e.g., anonymisation, pseudonymisation etc.) in order to comply with any required due diligence activities. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Policy unless you agree otherwise.

 

5. YOUR CHOICES & OBLIGATIONS

5.1 DATA RETENTION

We only retain your personal information while your Account is in existence or as needed to provide you with the Services. This includes information you or others provided to us and data generated or inferred from your use of our Services. You have the right to delete your account (described below). This is a case-by-case determination that depends on things like the nature of the data, why it is collected and processed, and relevant legal or operational retention needs. In some cases we choose to retain certain information in a depersonalised or aggregated form, such as when we need to comply with your request to suppress non-service communications.

5.2 RIGHTS TO ACCESS AND CONTROL YOUR PERSONAL DATA

You have some choices about the collection, use and sharing of your data. We offer you settings to control and manage the personal data we have about you and how this is used. You have the option to adjust your settings or delete your account. Please note, the extent of these choices will depend on whether you are a Candidate User or a Corporate User.

For personal data that we have about you:

• Change or Correct Data: You have access to edit permissions on all of your personal data at any time through our Services;
• Object to, Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal information (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate);
• Right to Access and/or Take Your Data: You can ask us for a copy of your personal information and can ask for a copy of personal information you provided in machine readable form using the process specified in the Settings page.
• Delete Data: Upon request we will erase or delete all or some of your personal information provided it is no longer necessary to provide Services to you, required for a legitimate business purposes, legal or contractual record keeping requirements.

Please contact us should you have any questions about your rights in relation to the processing we carry out on your data. Our contact details are at the end of this Policy.

5.3 ACCOUNT CLOSURE

If you choose to close your Account, your personal data will generally stop being visible to others on our Services within 48 hours. We delete closed account information within 30 days of account closure.

We retain your personal information after you have closed your Account if reasonably necessary to comply with legal obligations (including law enforcement requests), meet regulatory requirements, audit requests, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms of Service, or fulfil your request to “unsubscribe” from further messages from us. We will retain anonymized information after your account has been closed.

5.4 HOW TO WITHDRAW YOUR CONSENT

You can withdraw your consent at any time. Please contact us if you want to do so. Our contact details are below.

This will only affect the way we use information when our reason for doing so is that we have your consent.

 

6. OTHER IMPORTANT INFORMATION

6.1 SECURITY

We implement security safeguards designed to protect your personal information. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

6.2 CROSS-BORDER DATA TRANSFERS

We process data both inside and outside of the European Union. Countries where we process data may have laws which are different, and potentially not as protective, as the laws of your own country. We will not transfer personal data to a third party country outside of the UK or EEA that is not compliant with the applicable data protection laws via adequacy agreement, Binding Corporate Rules or other legally appropriate means as defined by the Information Commissioners Office (including EU Standard Contractual Clauses) without your explicit consent.

6.3 LAWFUL BASES FOR PROCESSING

We will only collect and process personal data about you where we have lawful basis to do so. The lawful bases we operate under include contract (where processing is necessary for the performance of a contract with you - e.g. You create an Account to use our Services), legitimate interests, scientific, research or statistical purposes (e.g. to develop our algorithms) and, where applicable, the unambiguous consent of the individual data subject.

Where we rely on consent to process personal data, you have the right to withdraw or decline your consent at any time.

Where we rely on legitimate interests, or scientific, research or statistical purposes, you have the right to object, or to request details from us of any legitimate interest balancing exercises we may have carried out.

If you have any questions about the lawful basis upon which we collect and use your personal data, please contact us. Our contact details are below.

7. CONTACT DETAILS

You can contact our Data Protection Officer at [email protected]