Your Privacy Matters

Table of Contents:
  1. Introduction
  2. Information We Collect
  3. How We Use Your Data
  4. How We Share Information
  5. Your Choices & Obligations
  6. 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 personally identifiable information. 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, 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, please do not access or use our Services and 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 personally 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 will vary depending on whether you are a Candidate User or Corporate User and 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.

In relation to a Candidate User, we will also collect information about you from recruiters 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 name, email and telephone number as well as the contents of your message.

2.4 Service Use

We log usage data when visitors or you visit or otherwise use our Services, including our sites, app and platform technology (e.g., our off-site plugins), 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 recognize 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 get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your 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 may also modify this Policy.

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 personalize, including with the help of automated systems (described below), our Services so that they can be more relevant and useful to you.

3.1 Creating an Account

We use your information to authorize your access to the Services, verify your identity, authenticate your visits, deliver our Services, including to personalize 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 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, 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 an automated decision, and ask that a person reviews it. If you want to know more about these rights, please contact us.

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

We 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, level of permissions and 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. 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 depersonalized or aggregated form.

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 or unlawfully held);
  • 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 accordingly. 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 fulfill 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.

If you withdraw your consent, we may not be able to provide certain products or Services to you. If this is so, we will tell you.

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.

6.3 Lawful Bases for Processing

We will only collect and process personal data about you where we have lawful basis. Lawful basis include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you - e.g. You create an Account to use our Services) and legitimate interests.

Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful basis upon which we collect and use your personal data, please contact us. Our contact detail sare below.

7. Contact details

You can contact our Data Protection Officer at dpo@headstart.io

Cookies

We use cookies to distinguish you from other users using our services. This helps us to provide you with a good experience when you use our services and also allows us to improve our services.

Information the use of cookies

When accessing the services, we use cookies to distinguish you from other users. This helps us to provide you with a good experience and also allows us to improve our Services. By continuing to use the Services or otherwise browse our website, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your Device if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our Services. They include, for example, cookies that enable you to log into secure areas.
  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Services Sites when they are using it. This helps us to improve the way our business works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our Services Sites. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies. You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

We may process your personal data for the purposes of our legitimate interests or for the legitimate interests of third parties (e.g., your employer or company), provided that such processing shall not outweigh your rights and freedoms.

  1. Protect you, us, or others from threats (such as security threats or fraud)
  2. Comply with laws that apply to us
  3. Enable or administer our business, such as for quality control, consolidated reporting, and customer service
  4. Manage corporate transactions, such as mergers or acquisitions
  5. Understand and improve our business or customer relationships generally
  6. For legal and audit purposes
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