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Last Updated: December 17, 2019
This section of the Privacy Policy is required by the California Consumer Protection Act (“CCPA”) and applies to California residents.
SmartRecruiters collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. In particular, SmartRecruiters has collected the following categories of personal information from consumers within the last 12 months:
Category | Examples | Collected |
Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers that You decide to provide to our customer or us. | YES |
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | YES |
Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | YES |
Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | NO |
Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO |
Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a SmartRecruiters website, application, or advertisement. | Yes |
Geolocation data. | Physical location or movements. | NO |
Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
Professional or employment-related information. | Current or past job history or performance evaluations. | YES |
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO |
Personal information does not include:
SmartRecruiters obtains the categories of personal information listed above from the following categories of sources:
SmartRecruiters may use or disclose the personal information SmartRecruiters collects for one or more of the following business purposes:
SmartRecruiters will not collect additional categories of personal information or use the personal information SmartRecruiters collected for materially different, unrelated, or incompatible purposes without providing You notice.
SmartRecruiters may disclose Your personal information to a third party for a business purpose. When SmartRecruiters discloses personal information for a business purpose, SmartRecruiters enters a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding 12 months, SmartRecruiters has disclosed the following categories of personal information for a business purpose:
SmartRecruiters discloses Your personal information for a business purpose to the following categories of third parties:
In the preceding 12 months, SmartRecruiters has not sold any personal information.
The CCPA provides California residents with specific rights regarding their personal information. This section describes Your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that SmartRecruiters disclose certain information to You about our collection and use of Your personal information over the past 12 months. Once SmartRecruiters receives and confirms Your verifiable consumer request, SmartRecruiters will disclose to You:
Deletion Request Rights
You have the right to request that SmartRecruiters delete any of Your personal information that SmartRecruiters collected from You and retained, subject to certain exceptions. Once SmartRecruiters receives and confirms Your verifiable consumer request, SmartRecruiters will delete (and direct our service providers to delete) Your personal information from our records, unless an exception applies.
SmartRecruiters may deny Your deletion request if retaining the information is necessary for SmartRecruiters or our service providers to:
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to SmartRecruiters by either:
Also:
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, SmartRecruiters 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.
Only You or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable consumer request related to Your personal information. You may also make a verifiable consumer request on behalf of Your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
SmartRecruiters cannot respond to Your request or provide You with personal information if SmartRecruiters cannot verify Your identity or authority to make the request and confirm the personal information relates to You. Making a verifiable consumer request does not require You to create an account with us. SmartRecruiters will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
SmartRecruiters endeavor to respond to a verifiable consumer request within 45 days of its receipt. If SmartRecruiters requires more time (up to 90 days), SmartRecruiters will inform You of the reason and extension period in writing. If You have an account with us, SmartRecruiters will deliver our written response to that account. If You do not have an account with us, SmartRecruiters will deliver our written response by mail or electronically, at Your option. Any disclosures SmartRecruiters provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response SmartRecruiters provides will also explain the reasons SmartRecruiters cannot comply with a request, if applicable. For data portability requests, SmartRecruiters will select a format to provide Your personal information that is readily useable and should allow You to transmit the information from one entity to another entity without hindrance.
SmartRecruiters does not charge a fee to process or respond to Your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If SmartRecruiters determines that the request warrants a fee, SmartRecruiters will tell You why SmartRecruiters made that decision and provide You with a cost estimate before completing Your request.
SmartRecruiters will not discriminate against You for exercising any of Your CCPA rights. Unless permitted by the CCPA, SmartRecruiters will not:
Changes to this Privacy Policy:
SmartRecruiters reserve the right to change this Privacy Policy at any time. SmartRecruiters will notify You of significant changes 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 two weeks following such notification. Non-material changes or clarifications will take effect immediately. SmartRecruiters encourage You to check our site and this Privacy Policy for updates.