DATA CONFIDENTIALITY POLICY

The Company processes a series of personal data of Users and Candidate Users when using reedact.com or Reedact Services.

This Privacy Policy (the “Policy”) describes what types of personal data are processed, how they are used, what your options are in connection with these processing operations, and how We shall respect your rights in accordance with (EU) legislation 2016/679 (“GDPR”), as person subject to the data protection legislation.

BEFORE USING REEDACT.COM, REEDACT PLATFORM OR OUR SERVICES, WE RECOMMEND THAT YOU READ THIS POLICY TO UNDERSTAND HOW PERSONAL DATA IS PROCESSED.

1. Who is responsible for processing your data?

Sharevents Global SRL, based in Grintiesului Street, No. 3, Sector 6, Bucharest, Romania, is the operator of personal data under personal data protection law, including the GDPR, as regards to the personal data of the Users collected and processed through reedact.com and the Reedact Platform (app.reedact.com).

For the processing of personal data, the Company has appointed a Data Protection Officer or DPO that can be contacted using the following contact details:

Reedact Data Protection Officer  Address: Grintiesului Street, No. 3, Sector 6, Bucharest, Romania  Email: hello@reedact.com Phone: +40726372578.

As for data collected through cookies for marketing purposes (for details, see the Cookies Policy section), the Company has undertaken to comply with the legislation on the protection of personal data in connection with this processing.

2. What data do we process?

We process the following categories of personal data:

Data you provide directly

Creating the User Account

When you create a Candidate User account, you must provide us with a series of data such as your first name, surname, e-mail address / mobile phone no., age, main skills, position held within a certain company, main skills, achievements and areas of responsibility.

Data from the registered user profile

You can include a number of information in your user profile as well as in the CVs that are part of your Candidate User account such as your studies, professional experience, skills, photos, information etc.

Other data you provide directly when using the Reedact Platform or interacting with Reedact:

We can store the information you received from us as a result of requests sent by email or chat, or when you participate in our polls and questionnaires; Also, if you use our remote interview services, we can process your image and voice through online conferencing services implemented in the Reedact Platform, and we can have access to your Reedact service conversations through our Support service.

Data collected or generated by us as a result of your interaction with the Reedact Platform

We receive information about when and/or how you visit or otherwise use Reedact Services, including how you use the Reedact Platform (e.g., whether you’ve updated your CV or not, whether or not you applied to a job with it).

We also use cookies and similar technologies to recognize you and your devices. We also allow others to use cookies. The way we use these technologies is described in the Cookies Policy.

Also, when using the Reedact Platform (including cookies or similar technologies on other sites), we receive information about your IP address, IP-based location, proxy server, operating system, web browser and add-on modules, device identifier. If you use our services from a mobile device, that device sends us data about your location based on your mobile device settings. We shall ask you to accept prior to using GPS or other tools to identify your location.

Data obtained from third parties

We receive information about your visits and interaction with services provided by other entities when you visit the services of other providers including advertisements, cookies, or similar technologies.

3. Why do we process your personal data?

In what follows we shall inform you of the purposes for which we collect and process your personal data and on the legal basis for data processing.

3.1.  Use of Services by Candidate Users

If you want to enjoy all the facilities offered by the Reedact Platform, you must create a User account. The User Account allows you to access a range of dedicated Candidate Services such as creating a CV or contacting recruiters. Legal basis: Art. 6 (1) (b) GDPR – conclusion and performance of the contract.

The Reedact Platform can also be accessed by Recruiters Users abroad, including outside the European Economic Area, to jurisdictions that have not been adequately protected. If you apply for a position published by such Recruitment Users, your data may be transferred to such jurisdiction, and the legal basis for the transfer is Art. 6 (1) (b) GDPR – conclusion and performance of the contract.

We can also use a range of data you provide to optimize your job suggestions or suggestions to complete your CV. Legal basis: Art. 6 (1) (f) GDPR – legitimate interest. We have a legitimate interest in improving our Services and providing suggestions / tips to Candidate Users to maximize the success of our Services.

3.2.  Managing relationships with Users and support

We process a series of personal data for the purposes of managing relationships with Reedact Platform Users, for example when contacting us with various questions or requests about Reedact Platform functionality, Reedact Platform malfunctions or errors. Legal basis: Art. 6 (1) (f) GDPR – legitimate interest in our interest in providing appropriate services to all Users.

3.3.  Providing communications on the Services

Users may receive various communications from us that relate to the provision of the Services (e.g. if the CV was viewed). We process these data based on our legitimate interest in art. 6 (1) (f) GDPR. We consider that our legitimate interest is to not prejudice the rights and interests of the data subjects as communications are closely linked to the provision of the Services requested. At the same time, we offer users the ability to disable these communications at any time from their e-mail subscription options placed inside the received e-mail.

Providing commercial communications

We want to send you promotional materials, let you know about the new services offered by the Company, launch invitations to participate in polls or to answer questionnaires and to communicate other similar information that we consider to be of interest to you, including, if you agree, by sending you promotional materials / marketing communications on the products / services of our Company’ partners.

We shall forward these communications if we have your agreement. Legal basis: Art. 6 (1) (a) GDPR – Consent.

Users can always unsubscribe from these communications. For example, if you withdraw your consent for commercial communications, we shall not be able to send you our offers or you shall not be able to participate in our polls and surveys.

Also, if we have the consent for commercial communications, in certain circumstances, we may use the information collected from you in combination with the data resulting from your interaction with the Reedact Platform Services, to be used in the context of our marketing communications. The legal basis for such processing is: art. 6 (1) (f) GDPR – legitimate interest. We want to streamline our marketing activity by offering our customers relevant and personalized service offerings.

3.4.  Using geolocation services

When using the mobile device geolocation feature, we shall ask for your consent. Legal basis of processing: Art. 6 (1) (f) GDPR – Consent.

3.5.  Analyses and statistics on the Reedact Platform, cookies, and similar technologies

We may use the personal data that the Users provide or that we collect in the context of using the Services for the purpose of performing analyses and statistics on our Services, including how the Reedact Platform works. The legal basis for such processing is: art. 6 (1) (f) GDPR – legitimate interest. The analyses and statistics we make help us to better understand how we can improve our Services or the Reedact Platform functionality.

We also use cookies and other similar technologies under the Cookies Policy to conduct analyses and statistics. Depending on the type of cookies used and similar technologies, the legal basis is: art. 6 (1) (f) GDPR – legitimate interest in necessary and functional cookies or art. 6 (1) (a) GDPR – Consent for analysis, tracking, and behavioral advertising cookies.

3.6.  Connecting via Facebook plugin

Candidates can sign in or create an account using the Facebook plug-in that allows you to sign in with your Facebook account. When Candidate Users use this feature, public data (e.g. name, surname, email address, telephone number). Use of this data is necessary for the creation of the User account, therefore the legal basis of the processing is Art. 6 (1) (b) of GDPR, respectively the conclusion and performance of the contract.

3.7.  Fulfilment of legal obligations

Sometimes data processing is required to meet our legal obligations (Legal basis: Article 6 (1) (c) GDPR – Enforcement of a legal obligation), such as:

  • payment of taxes and relevant contributions, reporting to relevant tax authorities and keeping accounting records;
  • archiving data according to applicable law.

3.8.  Defense of rights and interests in justice

We may also process personal data for the purposes of establishing, exercising or defending a legal remedy in proceedings before a court, administrative procedure or other formal proceedings in which the Company is involved (Legal basis: Article 6 (1) (f) GDPR – protection of the rights and interests of the operator)

4. Who do we reveal the data to?

We may disclose your personal data to (i) Entities and/or persons empowered by us (from EEA or third-party states) involved in the provision of Services, including the provision of commercial communications (such as data center providers, payment for various payment facilities in the Reedact Platform, e-mail platform providers such as Google Mail or Mailchimp); (ii) if we are required to disclose personal data for compliance with any legal obligation or decision of a judicial authority, public authority or governmental authority; or (iii) if we are required or otherwise permitted to do so under applicable law. Your personal data may also be disclosed to third-party cookies providers and similar technologies as described in the Cookies Policy.

5. How do we keep the data?

We keep your personal data as necessary to meet the purposes for which it was collected, with due regard for internal data retention procedures, including applicable archiving rules.

In general, Candidate User Data is retained as long as it has a User Account in the Reedact Platform. Personal data shall be deleted if the Candidate User requests to deactivate and delete the account, or after a minimum of 5 years from the date when the Candidate User becomes inactive (i.e. from the date of the last interaction in the Reedact Platform).

Data for cookies and similar technologies are kept according to the specific terms set for those technologies, the storage period being between the duration of the session (for session cookies) and a duration of up to 2 years (for analysis cookies).

6. What rights do you have as a person of interest?

By law, the following rights of the person of interest are recognized:

  • Right of access

you can obtain from us the confirmation that we process your personal data as well as information on the specifics of the processing

  • The right to correct the data

you can ask us to modify your incorrect personal data or, if necessary, fill in the data that is incomplete.

  • The right to delete

you may request the deletion of your personal data when: (i) it is no longer necessary for the purposes for which we have collected and processed it; (ii) You have withdrawn your consent to the processing of the data and we can no longer process it on other legal grounds; (iii) data is processed contrary to law; respectively (iv) the data must be deleted in accordance with the relevant legislation.

  • Withdrawal of consent and right of opposition

you can at any time withdraw consent to data processing on a consent basis. You may also oppose marketing processing at any time, including profiling for that purpose, and processing based on the Company’s legitimate interest, for reasons related to your specific circumstances.

  • Restriction

under certain circumstances, you may request the restriction of the processing of your personal data

  • The right to data portability

In so far as we process data by automated means, you may request, under the law, to provide your data in a structured, frequently used and readable form. If you request this, we may pass your data to another entity, if technically possible.

  • Right to file a complaint with the supervisory authority

you have the right to file a complaint with the data processing supervisor if you believe that your rights have been violated:

National Authority for the Supervision of Personal Data in Romania

G-ral. Gheorghe Magheru Blvd., 28-30 Sector 1, postal code 010336 Bucharest, Romania

anspdcp@dataprotection.ro

FOR EXERCISING THE RIGHTS LISTED ABOVE, YOU MAY CONTACT US USING THE CONTACT DETAILS REFERRED TO IN SECTION 1 (DPO CONTACT DATA).

The Company can also be contacted using the data and contact mechanisms available in the Reedact Platform.

POLICY ON COOKIES AND OTHER SIMILAR TECHNOLOGIES

Reedact can set or read cookies and device identifiers when you are using the Reedact Platform or are visiting a website, app, or service that uses our Services.

1. Some useful information on cookies and device identifiers

1.1.  What is a cookie?

An “Internet Cookie” (also known as “cookie browser” or “HTTP cookie” or simply “cookie”) is a small file consisting of letters and numbers stored on your computer, mobile or other equipment utilized by a user for accessing the Internet.

The cookie is installed based on a request issued by a web-server to a browser (such as Internet Explorer, Firefox, Chrome) and is completely “passive” (it does not contain any software, viruses or spyware and cannot access the information on the hard- drive of the user). The cookie stores certain information (for example, your preferred language or web page settings) that your browser can retransmit when you go back to the web page (depending on the cookie’s lifespan).

Cookies themselves do not require personal information to be used and, in most cases, do not personally identify Internet users.

1.2.  What are the types of cookies?

There are several types of cookies. Their classification is based on their lifespan, role and source, as follows:

  • Types of cookies by lifespan

Session cookies

they are temporarily stored in the web browser’s cookie folder where they are stored until the user exits the web site or closes the browser window (for example, when logging on / off from a webmail account or social network).

Persistent cookies

They are stored on the hard drive of a computer or device (and generally depend on the default cookie lifetime). Persistent cookies also include those placed on a website other than the one the user is currently visiting – known as ‘third party cookies’ – which can be used anonymously to store a user’s interests so that advertising is delivered as relevant as possible to users.

  • Types of cookies depending on their role

Strictly required cookies

These types of cookies are required for websites to function properly. The strictly required cookies allow you to navigate the site and enjoy its features. Without these cookies, we shall not be able to offer certain features, such as automatic redirection to the least busy server or retaining your wish list.

Functional cookies

Functional cookies record information about choices that users make, and they also allow site operators to customize the site according to the user’s requirements. For example, cookies can be used to save category / segment preferences.

Performance and analysis cookies

These types of cookies allow Internet site operators to monitor visits and traffic sources, how users interact with the internet page or certain sections of the website.

Information provided by analysis cookies helps operators understand how visitors use sites and then use this information to improve the way content is presented to users.

Targeting and advertising cookies

These cookies can provide the ability to monitor users’ online activities and set up user profiles that can then be used for marketing purposes. For example, based on cookies, the products and services agreed by a user can be identified, this information subsequently serving to transmit appropriate advertising messages to that user.

  • First party cookies vs. third party cookies

Each cookie has a “responsible” (i.e. website / Internet domain) that places that cookie.

First party cookies (first part) are placed by the Internet domain / website accessed by the user (whose address appears in the browser address bar). For example, if the user visits www.reedact.com and the cookie field placed on his / her computer is www.reedact.com then it is a first party cookie.

A third-party cookie (third party) is placed by another Internet domain / website other than the one accessed by the user; this means that the website you access also contains information from a third-party site – for example, an ad banner that appears on the site you’re accessing. Thus, if the user visits www.reedact.com but the cookie placed on his computer has mybusole.net as domain then it is a third-party cookie.

  • Built-in content (buttons, apps, and social widgets)

Webpages allow the implementation of third-party social buttons or widgets that allow users to interact with sites whose social buttons or widgets are being deployed. User interaction with third-party social buttons or widgets allows the third party to collect some information about that user, including the IP address, page header information, and browser information.

  • How do targeting and advertising cookies work?

In general, data about Internet browsing activity is collected and analyzed anonymously. If this analysis reveals a specific interest, a cookie (a small text file used by most sites to store some useful information to make browsing experience better) – is placed on the user’s computer, and this cookie determines what ad is received by the user, which is called interest-based advertising.

Interest-based advertising is a way to deliver ads on the websites you visit and make them more relevant to your interests. The common interests are grouped according to the previously deployed browsing activity and the users are only served with the advertising that matches their interests. In this way, advertising is relevant and as useful as possible.

To better understand …

Imagine you want to change your CV or are looking for a job. You visit the section of a specialized site (e.g. www.reedact.com) and read some relevant articles about career advice or jobs.

At the next online browsing, when you go online to read, for example, a news article or an online store page, you are being delivered as ad the resume-builder notice posted on a specialized site (such as www.reedact.com).

You shall receive these specially personalized ad messages, because you and others like you have shown an increased interest in these services. This way you can improve your web experience by reducing the number of non-interest-based ads.

2. What types of cookies and device identifiers are we using?

Below is the detailed list of cookies and device identifiers used.

You can withdraw your consent to use cookies (except the required cookies) at any time by changing the options in the appropriate cookies settings available.

Of course, you can set your browser to block and necessary cookies, but the site may not work properly. Also, disabling other types of cookies (other than necessary) could affect your experience or experience in using the Site.

2.1.  Cookies required

The strictly required cookies allow you to browse reedact.com and enjoy its features. Without these cookies, we shall not be able to offer certain features, such as automatic redirection to the least busy server or retaining your wish list.

Below are some examples of cookies we use on reedact.com.

Cookie name Supplier / Domain Purpose and content Lifespan
CookieConsent Cookiebot Stores the user’s cookie consent state for the current domain 1 year

2.2.  Functional cookies

Functional cookies record information about the choices you have made and also allow us to adapt the Website to suit your needs and requests.

We do not use such cookies.

2.3.  Performance and analysis cookies

These types of cookies help us understand how users utilize reedact.com. We only use these data to help improve the Services and Performance of the Reedact Platform.

Here are some examples of how we use these data:

  1. Information on the section / sections of the site more frequently visited to help us improve our User browsing experience;
  2. Managing and resolving potential Site errors;
  3. Design tests to improve how the site looks and works.

Sometimes these analyses are performed by third entities on behalf of Reedact.

 

Cookie name Supplier / Domain Purpose and content Lifespan
_ga Google Registers a unique ID that is used to generate statistical data on how the visitor uses the website. 2 years
_gat Google Used by Google Analytics to throttle request rate 1 day
_gid Google Registers a unique ID that is used to generate statistical data on how the visitor uses the website. 1 day

 Google Analytics analysis services

Reedact uses Google Analytics, a web analysis service of Google Inc., based in 1600 Amphitheater Parkway, Mountain View, CA 94043, United States (“Google”).

Based on your consent, Google will analyze on our behalf how you use our website. For this purpose, we use, among others, the cookies detailed in the table above. The information collected by Google in connection with the use of reedact.com by you (for example, the referral URL, the webpages you visit, your browser type, language settings, your operating system, screen resolution) shall be sent to a Google server in the United States where they shall be stored and analyzed; the corresponding results shall then be made available in an anonymous form. In this process, traffic data shall not be attributed to the full IP address you use. We have activated our Google’s IP anonymization function on our website, so the last 8 digits (IPv4 type) or the last 80 bits (IPv6 type) of the IP address you are using are deleted.

Furthermore, Google is certified in accordance with the EU-US Privacy Shield standards, which provide an adequate level of data protection for data processing by Google in the US.

For more information about Google Analytics, please refer to Google Analytics Terms of Service, Google Analytics security and privacy principles, and Google Privacy Policy.

You can withdraw your consent to web analytics at any time either by downloading and installing a Browser Plugin provided by Google, or by managing your consent through the above settings.

2.4.  Targeting and advertising cookies used by reedact.com

2.4.1.  Third-party advertising

Most of the ads you see on the Site are run by Reedact. However, we also allow other companies to provide advertising material and collect information through cookies or other similar technologies (third parties) included in the Site. Practically, these targeting technologies that accompany the displayed ad messages the Users seem allow them to monitor how effective are the displayed ad messages. Third-party advertising partners can also use other cookies that they have set on your device when browsing other websites. They use this data to know whether or not you have viewed a particular ad or to identify you in their database and then use this data to serve other types of advertising that would fit your interests.

We make reasonable efforts for partners with whom we collaborate for the purpose of online advertising and which we allow to add an identifier or code to the Site to handle responsibly the personal data retrieved from our Site. However, we do not control how they process personal data, and they have their own rules and policies for processing personal data.

2.4.2.  Types of online targeting and advertising cookies used on reedact.com

Cookie name Supplier / Domain Purpose and content Lifespan
fr Facebook Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers. 3 months
__fb_chat_plugin Facebook Used to track the user’s interaction with the website’s Facebook chat-widget. Persistent
_fbp Facebook Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers. 3 months
messaging_plugin_ht Facebook Pending Persistent

 2.4.3.  Social Plugins

Reedact.com can use or deploy plug-ins to social networks of third parties. In general, your interaction with a plug-in allows third parties to collect some information about you, including your IP address, page header information, and browser information.

Reedact.com implemented the following social buttons:

  • Facebook (https://www.facebook.com/privacy)
  • LinkedIn (https://www.linkedin.com/legal/privacy-policy)

•  Instagram (https://help.instagram.com/519522125107875)

3. How do I stop cookies?

Disabling and refusing to receive cookies can make some sites unavailable or difficult to visit and use. Also, refusing to accept cookies does not mean you shall no longer receive / see online advertising.

It is possible to set up the browser so that these cookies are no longer supported or you can set the browser to accept cookies from a specific site. But for example, if you are not registered using cookies, you shall not be able to comment.

You can stop placing cookies by managing your consent through the above settings. The required cookies shall not be disabled from this module as they are required for the Site to function.

 You can accept or refuse all cookies on the sites you visit by changing the settings in your browser.

Some examples depending on the browsers you use:
Internet Explorer version 8.0
1. Enter Tools and then Internet Options
2. Enter the Privacy tab
3. Use the slider to select the setting you want.
(http://windows.microsoft.com/ro-ro/internet-explorer/delete-manage-cookies#ie=ie-11)

Chrome:
1. Click the Chrome menu on the browser toolbar and select Settings
2. Click Show Advanced Settings
3. In the “Confidentiality” section, click the Content Settings button.
4. In the “Cookies” section, you can change the following settings for cookies:
– Delete cookies
– Blocking cookies by default
– Allowing cookies by default
– Storage of cookies and site data by default until the browser is closed
– Setting exceptions for cookies on certain sites or domains
(https://support.google.com/accounts/answer/61416?hl=en)

Firefox:
Note: Cookies are by default enabled in Firefox

To check or change the settings:
1. At the top of the Firefox window, click the Edit menu and select Preferences
2. Select the Privacy panel.
3. Set Firefox: with the option Use custom settings for history.
4. Check the box Accept cookies from sites to enable cookies and uncheck them to disable them.
(https://support.mozilla.org/en/kb/activating-and-deactivating-cookies)

For other Internet browsers please see their instructions to learn more about how you can change your browser settings or how to delete cookies.

We want to inform you that the option to disable cookies can minimize certain features and the functionality of the web site.

 Turning off DoubleClick remarketing pixels

In the case of pixels and DoubleClick remarketing cookies, they can be disabled by visiting the DoubleClick Disabling page (https://www.google.com/ settings/ads/onweb#display_optout?hl=en) or the Network Advertising Initiative Disabling page (http://www.networkadvertising.org/managing/opt_out.asp).

Turn off Criteo remarketing pixels

Pixel and Criteo remarketing cookies can be disabled by visiting our privacy policy (http://www.criteo.com/privacy/).

Information on how visitors can disable the use of cookies by Google can be accessed by visiting Google Ad Settings (http://www.google.com/settings/ads?hl=en_US).

You can also advise users to disable the use of cookies by a third party provider by visiting the Network Advertising Initiative (http://www.networkadvertising.org/managing/opt_out.asp) deactivation page.



     

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