Detailed information on the processing of Personal Data for all type of Users
Personal Data is collected for the following purposes and using the following services:
Access to third-party accounts
This type of service allows this Application to access Data from your account on a third-party service and perform actions with it.
These services are not activated automatically, but require explicit authorization by the User.
GitHub account access (GitHub Inc.)
This service allows this Application to connect with the User’s account on GitHub, provided by GitHub Inc.
Personal Data processed: device information; email address; Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes: a sale according to the CCPA, CPA and CTDPA
Mailchimp account access (Intuit Inc.)
This service allows this Application to connect with the User’s account on Mailchimp, provided by Intuit Inc.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes: a sale according to the CCPA, CPA and CTDPA
Google Drive account access (Google LLC)
This service allows this Application to connect with the User’s account on Google Drive, provided by Google LLC.
Personal Data processed: Data communicated while using the service; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes: a sale according to the CCPA, CPA and CTDPA
Advertising
This type of service allows User Data to be utilized for advertising communication purposes.
These communications are displayed in the form of banners and other advertisements on this Application, possibly based on User interests.
This does not mean that all Personal Data is used for this purpose.
Information and conditions of use are shown below. Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Application.
For more information, please check the privacy policies of the relevant services.
Services of this kind usually offer the possibility to opt out of such tracking.
In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section “How to opt-out of interest-based advertising” in this document.
Taboola (Taboola Inc.)
Taboola is an advertising service provided by Taboola Inc.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA;
a sharing according to the CCPA;
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA.
Demandbase (Demandbase Ltd.)
Demandbase is an advertising service provided by Demandbase Ltd.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA;
a sharing according to the CCPA;
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA.
Salesforce (Salesforce.com, Inc.)
Salesforce is an advertising service provided by Salesforce.com, Inc.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA;
a sharing according to the CCPA;
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA.
Meta ads conversion tracking (Meta pixel) (Meta Platforms, Inc.)
Meta ads conversion tracking (Meta pixel) is an analytics service provided by Meta Platforms, Inc. that connects data from the Meta Audience Network with actions performed on this Application.
The Meta pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Meta Audience Network.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA.
NextRoll (NextRoll, Inc.)
NextRoll is an advertising service provided by NextRoll, Inc. NextRoll, Inc. performs a hash of the User’s email address in order to serve targeted advertising to other devices connected to them (i.e. cross-device tracking).
Personal Data processed: device information; purchase history; Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example);
Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of personal information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
a sharing according to the CCPA
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
Demandbase conversion tracking (Demandbase Ltd.)
Demandbase conversion tracking is an analytics service provided by Demandbase Ltd. that connects data from the Demandbase advertising network with actions performed on this Application.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – https://www.demandbase.com/privacy-policy/#information-choices.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA.
Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Meta Events Manager (Meta Platforms, Inc.)
Meta Events Manager is an analytics service provided by Meta Platforms, Inc. By integrating the Meta pixel, Meta Events Manager can give the Owner insights into the traffic and interactions on this Application.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA.
Google Analytics 4 (Google LLC)
Google Analytics 4 is a web analysis service provided by Google LLC (“Google”).
Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server.
Users can learn more by consulting Google’s official documentation.
In order to understand Google’s use of Data, consult Google’s partner policy.
Personal Data processed: Trackers.
Place of processing: United States – Privacy Policy – Opt Out.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA.
Collection of privacy-related preferences
This type of service allows this Application to collect and store Users’ preferences related to the collection, use, and processing of their personal information, as requested by the applicable privacy legislation.
iubenda Consent Database (iubenda srl)
The iubenda Consent Database allows to store and retrieve records of Users’ consent to the processing of Personal Data, and information and preferences expressed in relation to the provided consent.
In order to do so, it makes use of a Tracker that temporarily stores pending information on the User’s device until it is processed by the API.
The Tracker (a browser feature called localStorage) is at that point deleted.
Personal Data processed: Data communicated while using the service; Trackers.
Place of processing: Italy – Privacy Policy.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
iubenda Privacy Controls and Cookie Solution (iubenda srl)
The iubenda Privacy Controls and Cookie Solution allows the Owner to collect and store Users’ preferences related to the processing of personal information, and in particular to the use of Cookies and other Trackers on this Application.
Personal Data processed: Trackers.
Place of processing: Italy – Privacy Policy.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
Content performance and features testing (A/B testing)
The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of this Application.
Firebase Remote Config (Google LLC)
Firebase Remote Config is an A/B testing and configuration service provided by Google LLC.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: identifiers.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA.
Data transfer outside the EU
The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis.
Any such Data transfer is based on one of the legal bases described below.
Users can inquire with the Owner to learn which legal basis applies to which specific service.
Data transfer to countries that guarantee European standards (this Application)
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out according to an adequacy decision of the European Commission.
The European Commission adopts adequacy decisions for specific countries whenever it considers that country to possess and provide Personal Data protection standards comparable to those set forth by EU data protection legislation.
Users can find an updated list of all adequacy decisions issued on the European Commission’s website.
Personal Data processed: various types of Data.
Category of personal information collected according to the CCPA: identifiers.
Data transfer abroad based on standard contractual clauses (this Application)
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation.
For further information, Users are requested to contact the Owner through the contact details provided in the present document.
Personal Data processed: various types of Data.
Category of personal information collected according to the CCPA: identifiers.
Data Privacy Framework SmartRecruiters adhesion
SmartRecruiters, Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S.
DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.
SmartRecruiters, Inc. has certified to the U.S.
Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S.
DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.
SmartRecruiters, Inc. has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S.
Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S.
DPF.
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S.
DPF, SmartRecruiters commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S.
DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF in the context of the employment relationship.
If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S.
DPF Principles, the Principles shall govern.
To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/
Data Transfers under EU-US Data Privacy Framework and its UK and Swiss extension
Data Transfers. SmartRecruiters complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S.
DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.
SmartRecruiters has certified to the U.S. Department of Commerce that it adheres to the EU-U.S.
Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S.
DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.
SmartRecruiters has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S.
Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S.
DPF.
If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S.
DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/s/participant-search.
SmartRecruiters U.S. entities adhering to the DPF principles:
-SmartRecruiters, Inc.
Where applicable law requires that international data transfers are governed by a data transfer mechanism, SmartRecruiters uses one or more of the following: EU Standard Contractual Clauses with a data recipient outside the EEA or the UK, verification that the recipient has implemented Binding Corporate Rules, or verification that the recipient adheres to the EU-U.S.
Data Privacy Framework, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S.
Data Privacy Framework (Swiss-U.S. DPF) as set forth
by the U.S. Department of Commerce.
If SmartRecruiters shares EU Personal Information with a third-party service provider that processes Personal Information solely on SmartRecruiters’s behalf, then we may be held liable for that third party’s processing of EU Personal Information in violation of the Principles, unless SmartRecruiters can prove that it is not responsible for the event giving rise to the damage.
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S.
DPF, SmartRecruiters commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S.
DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S.
DPF to https://feedback-form.truste.com/watchdog/request, an alternative dispute resolution provider based in the United States (at no cost to you).
If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.dataprivacyframework.gov/s/article/How-to Submit-a-Complaint-Relating-to-a-Participating-Organization-s-Compliance-with-the-DPF-Principles-dpf for more information or to file a complaint.
SmartRecruiters is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) and under certain conditions, you have the right to invoke binding arbitration as set forth under Annex I of these Principles.
Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Wistia widget (Wistia, Inc.)
Wistia is a video content visualization service provided by Wistia, Inc. that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
Gravatar (Automattic Inc.)
Gravatar is an image visualization service provided by Automattic Inc. that allows this Application to incorporate content of this kind on its pages.
Please note that if Gravatar images are used for comment forms, the commenter’s email address or parts of it may be sent to Gravatar – even if the commenter has not signed up for that service.
Personal Data processed: email address; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
Google Fonts (Google LLC)
Google Fonts is a typeface visualization service provided by Google LLC that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes: a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA.
Handling payments
Unless otherwise specified, this Application may process any payments by credit card, bank transfer or other means via external payment service providers, only for customers who choose to use Stripe for payment purposes.
In this case, Users are requested to provide their payment details and personal information directly to such payment service providers.
This Application isn’t involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.
Stripe (Stripe, Inc.)
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
Heat mapping and session recording
Heat mapping services are used to display the areas of this Application that Users interact with most frequently.
This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.
Some of these services may record sessions and make them available for later visual playback.
Crazy Egg (Crazyegg)
Crazy Egg is a heat mapping service provided by Crazy Egg, Inc.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes: a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA.
Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application.
Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Amazon Web Services (AWS) (Amazon Web Services, Inc.)
Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Germany – Privacy Policy.
Category of personal information collected according to the CCPA: identifiers.
Infrastructure monitoring
This type of service allows this Application to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of this Application.
Sentry (Functional Software, Inc.)
Sentry is a monitoring service provided by Functional Software, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: identifiers.
Crashlytics (Google LLC)
Crashlytics is a monitoring service provided by Google LLC.
Personal Data processed: crash data; device information; Universally unique identifier (UUID).
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: identifiers; internet or other electronic network activity information.
Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Twilio (Twilio, Inc.)
Twilio Inc. operates the servers on which the SmartRecruiters’ customer is storing the messaging data it has used to communicate with the customer’s candidates through the API between the SmartRecruiters’ solution and Twilio Inc.
Personal Data processed: phone numbers, email address.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: identifiers.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
a sharing according to the CCPA
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
Mailgun (Mailgun Technologies, Inc.)
Mailgun is an email address management and message sending service provided by Mailgun Technologies, Inc.
Personal Data processed: email address.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: identifiers.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
a sharing according to the CCPA
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
Marketo Email Marketing (Adobe Systems Incorporated)
Marketo Email Marketing is an email address management and message sending service provided by Adobe Systems Incorporated
Personal Data processed: Trackers; Usage Data; various types of Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA;
a sharing according to the CCPA;
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA.
Remarketing and behavioral targeting
This type of service allows this Application and its partners to inform, optimize and serve advertising based on past use of this Application by the User. This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity. Some services offer a remarketing option based on email address lists. Services of this kind usually offer the possibility to opt out of such tracking.
In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section “How to opt-out of interest-based advertising” in this document.
LinkedIn Website Retargeting (LinkedIn Corporation)
LinkedIn Website Retargeting is a remarketing and behavioral targeting service provided by LinkedIn Corporation that connects the activity of this Application with the LinkedIn advertising network.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA;
a sharing according to the CCPA;
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA.
Tag Management
This type of service helps the Owner to manage the tags or scripts needed on this Application in a centralized fashion. This results in the Users’ Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager (Google LLC)
Google Tag Manager is a tag management service provided by Google LLC.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
Traffic optimization and distribution
This type of service allows this Application to distribute their content using servers located across different countries and to optimize their performance. Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between this Application and the User’s browser. Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.
jsDelivr (Prospect One Sp. z o.o. sp. k.)
jsDelivr is a traffic optimization and distribution service provided by Prospect One Sp. z o.o sp.k.
Personal Data processed: Trackers; Usage Data.
Place of processing: Poland – Privacy Policy.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA;
a sharing according to the CCPA
targeted advertising according to the VCDPA, CPA, CTDPA, and UCPA.
User database management
This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Application, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks’ profiles) and used to build private profiles that the Owner can display and use for improving this Application. Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Application.
Marketo Lead Generation (Adobe Systems Incorporated.)
Marketo Lead Generation is a User database management service provided by Adobe Systems Incorporated.
Personal Data processed: email address, various types of Data as specified in the privacy notice
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: identifiers.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA.
Freshsales (Freshworks, Inc.)
Freshsales is a User database management service provided by Freshworks, Inc.
Personal Data processed: email address, various types of Data as specified in the Privacy Notice.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: identifiers.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA.
Salesforce Sales Cloud (Salesforce.com, Inc.)
Salesforce Sales Cloud is a User database management service provided by salesforce.com, inc.
Personal Data processed: email address, various types of Data as specified in the Privacy Notice.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: identifiers.
This processing constitutes:
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA.
In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.