EU Privacy Policy

Last Revised August, 2020


NOTICE: If you are in US, or any country outside the European Union (EU) and European Economic Area (EEA), this EU User Privacy Policy does not apply to you. Instead please review our General Privacy Policy.

When we use the term “EU data”, “EU user” and “EU data subject”, we refer to data, users and data subjects from both EU and EEA.

HelioScout takes information privacy extremely seriously. We have prepared this EU User Privacy Policy to explain how we collect, use, protect, and disclose your information and data if you are in the EU or EEA (an “EU data subject”), including when EU users use the www.helioscout.com website (the “Site”) and any mobile application, application programming interfaces, and other services offered by HelioScout, Inc. (collectively the “Services”). This EU User Privacy Policy also explains your choices for managing your information preferences, including opting out of certain uses of your Personal Data (defined below). This Privacy Policy applies to all EU users of the Site and Services. The Site and Services are provided by HelioScout, Inc. (“HelioScout” “the Company,” “HS,” “we,” “our,” or “us”).

 

1. Information We Collect and HS’s Role under General Data Protection Regulation (“GDPR”).

Personal Information Collected through Our Website

We may collect Personal Data when you use our Site or Services. In order to register your HS account and use the Services, you provide information that personally identifies you, such as your name, address, phone number, mobile phone number, e-mail, payment information, company name and other personally identifiable information that you choose to provide us with or that you choose to include in your account. You may be asked to provide us with Personal Data when you register with the Site or use any of our Services, when you communicate with us, and at other times.

 

Usage Data and Site Activity

We automatically collect the following information about your device and your use of our Site or Services through cookies, web beacons, and other technologies: the functions you use when using the Services; browser agent name and version; links you click; your IP address; the length of time you visit our Site and or use our Services; and the referring URL, or the webpage that led you to our Site (“Usage Data”). We use this information to monitor and improve the Site and Services, enhance your online experience and to enable us to provide you with an easier and more personalized experience and level of service. We may combine Usage Data with Personal Data that you have provided to us.

 

Cookies and Anonymous Identifiers

We use cookies (a small text file placed on your computer to identify your computer and web browser) and may use anonymous identifiers (a random string of characters that is used for the same purposes as a cookie). We use cookies and other anonymous identifiers for authentication purposes (to keep track of the fact that you have logged in) and to analyze use of and improve the Site and Services. Please see our Cookie Policy for further information about the cookies we use, and your choices regarding cookies.

 

Employer, Educational Institution, and Community Data

HS strives to provide additional information to our clients regarding active and passive job candidates so they can make the best decision possible in the most efficient manner. This also helps job seekers by creating a more meritocratic, efficient, labor market. To serve these ends, HelioScout looks for information about prior employers, educational institutions, and locations that appear on an individual’s profile, application, or resume. HS does not search for profiles or resumes independently, and we only reference profiles/resumes provided by our clients. Additionally, the incremental information we retrieve is not about the individual specifically, does not include any personal information, and could not be used directly or indirectly to identify the individual.

In addition, we recognize that you may not wish to have information about prior employers, educational institutions, or locations which appear in your profile appear in our platform, and we will honor your request to opt out. To opt out, please provide your name and email address along with the subject line “Opt Out” in an email to info@helioscout.com and we will remove your information from our system, or follow-up with you if we need further information in order to honor your request.

 

Please note, we may need to retain certain data about you in order to ensure that we can continue to honor your request to opt out. We will maintain the minimum amount of information necessary for this purpose, and will not share this information with employers, recruiters or any other users of our services.

 

Information You Input or Upload while Utilizing Our Services

As part of utilizing our Services you may input or upload information, you may provide us with your credentials to third-party sites or services in order to synchronize certain functions or other information with our Services, and may provide us with other information (collectively “Customer Data”). HS will only process Customer Data according to your instructions, and to deliver the Services to you. We treat Customer Data as confidential and will not share it with any third parties and other HS users.

 

2. Our Purposes and Legal Bases for Processing

As explained in more detail below, we may process Personal Data under GDPR Article 6(1)(b), where such processing is necessary to deliver the Services you have requested, under GDPR Article 6(1)(a) where we seek your consent for the processing, and under GDPR Article 6(1)(f) where it is necessary for our legitimate interests, or the legitimate interests of a third party, and those legitimate interests are not overridden by your rights and freedoms.
 

  • We process the Personal Data you provide to us as a user of our Services where such processing is necessary to deliver the Services you have requested. Thus, we process Personal Data to establish and maintain your account, to provide you notices and other communications relating to the Services, provide you customer support, and otherwise provide the Services to you.

  • Our legitimate interests, and the legitimate interests of others, include: (i) the interests of employers and recruiters to have pertinent information about active and passive job candidates in order to make an informed decisions (ii) the interests of employers and recruiters to have pertinent information provided to them in a timely and efficient manner (iii) the interests of individuals to be evaluated by employers based upon sufficient, accurate information (iv)  the interests of individuals to be evaluated by employers in a timely, efficient manner (v) the interests of individuals to be contacted regarding employment opportunities (vi) the societal and labor market interests of efficiently and accurately matching job seekers with job openings and  (vii) our interests in helping our clients make better hiring decisions in an efficient manner. These legitimate interests provide are our basis for searching for and collecting public information

  • In addition to legitimate interests, we may also rely on consent from third parties who legally sell or share data with us. These third-party data vendors will have certified to us or been verified by us as GDPR- compliant vendors. They will have provided data to us based on their legitimate interests or consent obtained from data subjects to share the data. They also will have provided data subjects sufficient protections including but not limited to allow data subjects to opt out from such sharing.

  • We may also process personal data based on our legitimate interests, or the legitimate interests of others in the following circumstances: (1) to seek individuals' consent for sharing personally identifiable information with others; (2) to comply with laws and regulations that apply to HS; (3) in the case of information provided as a user of our Services: (a) to administer our business and improve the Service quality; (b) to improve user experience and our customer relationships; (c) to communicate with you about the Services or other services we offer that might be of interest to you; (d) to protect our Service and users from threats such as fraud or security threats; and (4) to facilitate necessary business transactions such as mergers or acquisitions.

 

3. When We May Share and Disclose Information

  • We allow our registered users (recruiters and employers) to view retrieved data relying on our legitimate interests and consent obtained as above mentioned 

  • From time to time, we may utilize other businesses whom we believe trustworthy and who have confirmed that their privacy practices are consistent with ours (“Service Providers”). For example, we may use a payment processor to process payments. We may contract with other Service Providers to provide certain services, such as hosting and maintenance, data storage and management, and marketing and promotions. We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider must agree to use reasonable security procedures and practices, appropriate to the nature of the information involved, in order to protect your Personal Data from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Data other than as specified by us.

  • HS uses Amazon Web Services (AWS) as a Service Provider to host the Site and Services and store Personal Data and Customer Data. Your information is not disclosed to AWS, but is transferred through, and resides on, computers owned by AWS. AWS is ISO/IEC 27018 certified and has a system of controls in place that address the privacy protection of HS content.

  • In the event we transfer data subject to the EU-US Privacy Shield such transfer is governed by the principles of Accountability for Onward Transfer (discussed below).

  • We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose personal data and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate in order to respond to legal requests (including court orders and subpoenas), to protect the safety, property, or rights of our organization or of any third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with the law.

  • We may share Personal Data and Usage Data with businesses controlling, controlled by, or under common control with our Company. If our Company is merged, acquired, or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Data and Usage Data in connection with such transaction. You will have the opportunity to opt out of any such transfer if it will result in the handling of your Personal Data in a way that differs materially from this Privacy Policy.

  • We will not disclose Personal Data to third parties, including for their direct marketing purposes, without your consent. We may disclose to third parties, certain Usage Data regarding the Site and Services. However, in such cases, your Usage Data is aggregated with the Usage Data of others and does not identify you individually.

 

4. Cross-border Transfers and Safeguards

HS stores and processes personal data in the United States. In the event HS transfers personal data from the EU or EAA to the United States, such transfer will be pursuant to the Standard Contractual Clauses approved by the European Commission or other framework such as the EU-US Privacy Shield.

 

Standard Contractual Clauses

Where a customer transfers Customer Data from the EU to us in the US, and we and our customer have agreed, we will use European Commission-approved Standard Contractual Clauses as a legal mechanism for data transfers from the EU. These clauses are contractual commitments between companies transferring Personal Data (for example, from our customer’s EU office to HS), binding the parties to protect the privacy and security of the data.

HS commits to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding this privacy policy should first contact info@helioscout.com OR


HelioScout Inc.

1301 Lowman Street

Baltimore, Maryland 21230

 

5. How Long We Process and Store Information

We will store your information until you choose to close and delete your account.

 

6. Managing Your Personal Account Data

You can review, correct, update, delete, or change most of your Personal Data used to establish your account or opt out of receiving certain e-mails and other communications from us by contacting your account manager or e-mailing us at info@helioscout.com. You are able to opt out of receiving marketing e-mails from us, however, you cannot opt out of receiving all e-mails from us, such as e-mails about the status of your account with us. If you have questions or concerns regarding this Privacy Policy, please e-mail us at info@helioscout.com.

 

7. Your Right to Opt Out

As explained above, HS strives to provide additional information to our clients regarding active and passive job candidates so they can make the best decision possible in the most efficient manner. This also helps job seekers by creating a more meritocratic, efficient, labor market. However, we recognize that you may not wish to have information about prior employers, educational institutions, or locations which appear in your profile appear in our platform, and we will honor your request to opt out. To opt out, please provide your name and email address along with the subject line “Opt Out” in an email to info@helioscout.com and we will remove your information from our system, or follow-up with you if we need further information in order to honor your request.

Please note, we may need to retain certain data about you in order to ensure that we can continue to honor your request to opt out. We will maintain the minimum amount of information necessary for this purpose, and will not share this information with employers, recruiters or any other users of our services.

 

8. Your Rights Regarding Your Personal Data under the GDPR

You have the following rights with respect to your Personal Data. When exercising any of the rights listed below, in order to process your request, we may need to verify your identity for your security. In such cases we will need you to respond with proof of your identity before you can exercise these rights.

  • The right to access information we hold on you

    • At any point you can contact us to request access to and be provided with information on the processing of your personal information. Once we have received your request we will respond within one month. There are no fees or charges for the first request but additional requests for the same data may be subject to an administrative fee.

  • The right to correct and update the information we hold on you

    • If the data we hold on you is out of date, incomplete or incorrect, you can inform us and your data will be updated.

  • The right to have your information erased

    • If you feel that we should no longer be using your data or that we are illegally using your data, you can request that we erase your data.

    • In particular, you have the right to opt-out of our Service as explained above in Section 7.

  • The right to object to processing of your data

    • You have the right to request that we stop processing your data for direct marketing or for processing based on our legitimate interests. Furthermore, you have the right to opt-out Service as explained above in Section 7.

  • The right to data portability

    • To the extent that the legal basis for our processing of your personal data is: (i) consent; or (ii) that the processing is necessary for the provision of services to you or to take steps at your request to provide you services, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format, or to have us transfer your data to another controller.

  • The right to withdraw your consent to the processing at any time where the legal basis for our processing is your consent.

    • In particular, even if you have consented to the processing of your data, you have the right to withdraw your consent at any time. Please see Section 7.

  • The right to restrict processing of your data

    • You have the right to restrict the processing of your data in certain circumstances including: (i) if you contest its accuracy; (ii) if the processing is unlawful and you oppose the erasure; (iii) if it is no longer needed for the purposes for which it was collected, but you require it for the defense of a legal claim.

  • The right to lodge a complaint with the supervisory authority, in the Member State where you have your habitual residence, place of work, or where an alleged infringement of the GDPR has taken place.

 

9. Be Careful When You Share Information with Others

Please be aware that whenever you share information on any public area of the Site or Services, that information may be accessed by others. In addition, please remember that when you share information in any other communications with third parties, that information may be passed along or made public by others. This means that anyone with access to such information can potentially use it for any purpose, including sending unsolicited communications.

 

10. Security

We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of information transmitted to us. However, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through the Site or Services, we cannot and do not guarantee the security of any information you transmit on or through the Site or Services, and you do so at your own risk.

 

11. Links

Our Site and Services may contain links to other websites or allow others to send you such links. A link to a third party’s website does not mean that we endorse it or that we are affiliated with it. We do not exercise control over third-party websites. You access such third-party websites or content at your own risk. You should always read the privacy policy of a third-party website before providing any information to the website.

 

12. Children’s Privacy

The Site and Services are intended for EU users who are 16 years old or older. We do not knowingly collect Personal Data from children under the age of 16. If we become aware that we have inadvertently received Personal Data from a child under the age of 16, we will delete such information from our records.

 

13. Updates or Changes in Processing

If we wish to use your personal data for a new purpose, not covered by this Privacy Policy, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.

In other circumstances, if we decide to change this Privacy Policy, we will inform you by posting the revised Privacy Policy on the Site. Those changes will go into effect on the “Revised” date shown in the revised Privacy Policy. By continuing to use the Site or Services, you are consenting to the revised Privacy Policy.

 

14. Contact Information

If you have any questions, feedback or to report a violation regarding the EU Privacy Policy, you may email us at info@helioscout.com or contact us by mail addressed to:

HelioScout Inc.

1301 Lowman Street

Baltimore, Maryland 21230

In order to exercise your right regarding your personal data including right to access, correction (rectification), erasure, restriction of processing, objection to processing, and portability, you can contact us at, at info@helioscout.com.

 

PLEASE PRINT A COPY OF THIS PRIVACY POLICY FOR YOU RECORDS AND PLEASE CHECK THE SITE FREQUENTLY FOR ANY CHANGES.