Simply Hired Privacy Policy

Effective Date: May 25, 2018

This Privacy Policy was last updated: August 3, 2018

1. Introduction

THIS IS A NEW PRIVACY POLICY, WHICH IS IN EFFECT AS OF August 3, 2018. BY USING THE SITE, YOU ACCEPT THESE NEW TERMS.

Simply Hired ("SH Inc." or "Simply Hired") has drafted its Privacy Policy to ensure that you can clearly understand our data and security practices and policies as you use Simply Hired's websites, apps and mobile services (the "Site" or "Sites"). This Privacy Policy describes the types of Personal Data we collect, how we use the information, with whom we share it, and the choices you can make about our collection, use and disclosure of your Personal Data. The phrase "Personal Data" refers to information that personally identifies you, such as your name, address, telephone number, email address, credit card number or other billing information. We also describe the measures we take to protect the security of your Personal Data and how you can contact us about our privacy practices.

This Privacy Policy incorporates by reference the Terms Of Use for the Sites, which apply to this Privacy Policy. When you visit the Sites or provide us with information, you consent to our use and disclosure of the information we collect or receive, as described in this Privacy Policy, unless separate terms are offered by you in writing and accepted in writing by Simply Hired.

Personal data (“Personal Data”) refers to any information that identifies you as a specific individual, and non-personal data (“Non-Personal Data”) refers to any information that does not identify you as a specific individual. Please note that at all times Simply Hired will adhere to the applicable statutory definition in determining what is and is not Personal Data for the purposes of this Privacy Policy. Where this Privacy Policy refers to “information” or “your information” this may include both Personal and Non-Personal Data.

Please review this Privacy Policy periodically, as we may update it from time to time without prior notice to reflect changes in our data practices. We will post a notice on our Sites to notify you of any significant changes to our Privacy Policy and will indicate when it was most recently updated.

2. Information We Collect

We collect information about you when you use our Sites. We may also obtain information about you from our business partners, other third parties and publicly available information.

The types of information we may obtain include:

Your Personal Data, if you choose to provide it or if we obtain it in the manner described above. If you wish to receive an email job alert, you must provide an email address. If you do not wish to continue to receive job alerts, please unsubscribe by pressing the unsubscribe link at the bottom of any job alert.
Job search behavior and preferences and a record of the searches that you make on our Sites. We do this in order to present you with recommendations based on your interests as expressed previously through your activities on our Sites.
Other details that you may submit to us or that may be included in the information provided to us by third parties, which is provided in the course of the hiring process. Such third parties may include Simply Hired affiliates sharing certain information with Simply Hired where you have agreed in advance to such sharing. Any Personal Data that Simply Hired may obtain from other third-party sources will be processed by Simply Hired in accordance with this Privacy Policy and all applicable laws.
We may collect information stored in your social media profile that you authorize us to access when you use your social media profile to invoke features on the Sites. Simply Hired provides software applications ("Apps") available to the public. If you decide to download one of our Apps, we may collect your profile information, which will be limited to your social network site user ID, email address, name, city, state, social network site profile image URL, and employment history, including job titles and company names.

2.1 Storage of your Information

Simply Hired shall retain users’ Personal Data to the extent such retention is adequate, relevant and limited to what is necessary for the purposes for which they are processed. In particular, Simply Hired shall not retain Personal Data for any longer than necessary to perform the services outlined in this Privacy Policy.

Simply Hired may also store the information detailed in section 2 of the Privacy Policy on its equipment or the equipment of third parties that Simply Hired has a relationship with. Such storage services will be governed by appropriate protections, as required by applicable rules.

2.2 What Personal Data is Required

Simply Hired will indicate to you at the point of provision as to whether or not particular Personal Data provided by you is required in order to provide particular Simply Hired services or features to you. Where Personal Data that is required is not provided by you then the particular feature or service may not be available to you.

2.3 The Basis on Which Simply Hired Collects Your Personal Data

Simply Hired collects and processes your Personal Data on the basis of different legal grounds, depending on the nature of the Personal Data being provided and the type of processing involved. More information is provided on this here.

Performance of a Contract

Most of the Personal Data processed by Simply Hired is performed on the basis that it is necessary for the performance of our agreement with you, or in order to take steps at the request of the user prior to entering such an agreement.

Legitimate Interest

A second ground relied upon by Simply Hired for other types of processing of your Personal Data is that it is necessary for the purposes of legitimate interests pursued by Simply Hired. Such legitimate interests will include where we believe you have a reasonable expectation that we will perform a particular type of processing on your behalf, or where such processing is strictly necessary for fraud detection and prevention.

Compliance with a Legal Obligation

A third ground relied upon for certain types of processing is that it is necessary in order to allow Simply Hired comply with a legal obligation.

Consent

Finally, in certain limited situations, Simply Hired relies on your consent in order to process your Personal Data. Where Simply Hired requires your consent in order to collect and process certain Personal Data, we seek your consent at the time of provision, and such processing will only be performed where consent is secured.

2.4 Children's Privacy

The Sites are not directed to individuals under the age of fourteen (14), but if you are under the age of 18 or the age of majority in your jurisdiction, you must use Simply Hired under the supervision of a parent or legal guardian, or responsible adult. Simply Hired does not knowingly collect or solicit information from anyone under the age of 14. In the event that we learn that we have collected Personal Data from a child under the age of 14, we will delete that information as quickly as possible.

3. How We Use the Information We Collect

We may use the information we obtain about you to:

Provide the products or services you request;
Maintain a record of the jobs you view or apply to on our Sites;
Inform you of relevant job postings that may be of interest to you;
Provide administrative notices or communications applicable to your use of the Sites;
Respond to your questions and comments and provide customer support;
Contact you and deliver information to you that we believe is targeted to your interests (such as relevant services, educational or other career development opportunities); enable you to communicate with us through our blogs, social networks and other interactive media; and solicit your feedback and input;
Operate, evaluate and improve our business and the products and services we offer;
Analyze and enhance our marketing communications and strategies (including identification of when emails we have sent to you have been received and read);
Analyze trends and statistics regarding visitors' use of our Sites, mobile applications and social media assets, and the jobs viewed or applied to on our Sites;
Protect against and prevent fraud, unauthorized transactions, claims and other liabilities, and manage risk exposure, including by identifying potential hackers and other unauthorized users;
Enforce our Sites' Terms Of Use; and
Comply with applicable legal requirements, industry standards and our policies, including as is reasonably necessary to comply with legal process (including subpoenas, search warrants, court orders) and law enforcement instructions and orders.

We also use non-personally identifiable information and certain technical information about your computer and your access of the Sites in order to operate, maintain and manage the Sites. We collect this information by automated means, such as cookies and web beacons, as described in more detail below.

4. Information We Share

The Sites may track the total number of visitors to our Sites, the number of visitors to each page of our Sites, IP addresses, External Web Sites linked to, search terms and the domain names of our users' Internet Service Providers, operating system and browser type, and we may analyze these data for trends and statistics in the aggregate, but such information will be maintained, used and disclosed in aggregate form only and it will not contain personally identifiable information. We also may collect aggregate demographic information. Such aggregate information may be collected from data that you have provided to us via usage of the Sites and/or public records, and is not unique to you nor is it linked to any Personal Data that can identify any individual person. We may use such aggregate information to analyze trends, administer the Sites, track users' movements, and gather broad demographic information for aggregate use. We may share this aggregate information with third parties, including our affiliated and parent companies, for various reasons related to our business to assist them in targeting advertisements to appropriate audiences.

Other than instances in which users opt to provide their Personal Data via a job application, include it in a job posting or otherwise provide permission to share it, we do not sell our users' Personal Data to anyone for any reason.

We share Personal Data with our service providers, including affiliated companies and our parent company, which are located in jurisdictions outside your own. This helps us in the delivery of our own products and services to you. These service providers may only use or disclose the information as necessary to perform services on our behalf or as otherwise required by law. Any such sharing is performed in full compliance with applicable data protection rules and subject to appropriate safeguards, primarily through the use of extensive data protection agreements, in order to ensure adequate protection of users’ Personal Data. If you do not wish your information to be transferred in this way you should not use this Site.

Simply Hired also may disclose specific user information when we determine, in good faith, that such disclosure is necessary to comply with the law, to cooperate with or seek assistance from law enforcement, to prevent a crime or protect national security, or to protect the interests or safety of Simply Hired or other users of the Sites. This means, for example, that Simply Hired may honor subpoenas, search warrants, law enforcement or court-mandated requests to reveal a user’s electronic address and identity, or other properly requested information.

Personal Data we have collected may be passed on to a third party in the event of a bankruptcy or another corporate reorganization of Simply Hired. In addition, if we are acquired by or merged with another company, or in the event of any sale of assets or other transfer of ownership by Simply Hired to a third party (whether by merger, sale or otherwise), or any other reorganization or joint venture, or assignment, transfer or other disposition of all or any of Simply Hired’s business, assets or stock (including in connection with any bankruptcy or similar proceeding), the Personal Data we have collected may be transferred to such third party as well as such third party’s affiliates and subsidiaries, and may be used by such third party in accordance with this Privacy Policy.

Please note that the Resume and Saved Jobs products are no longer available on the Sites. Any resume or job application you sent to an Employer via a job application may be kept by the Employer, and you should check such Employer’s privacy policy to understand how they keep your Personal Data.

5. Exercising Rights With Respect to Personal Data

Simply Hired users that provide their Personal Data in the EU, and those that provide their Personal Data in any other jurisdictions that adopt laws affording equivalent protections to those in the EU, may avail of the rights detailed below.

5.1 The Right to Rectify Your Personal Data, or Restrict or Object to the Processing of Your Personal Data

You may make a formal request to have Simple Hired rectify, restrict or object to the processing of your Personal Data by sending an email to privacyoffice @ simplyhired.com (please remove spaces when sending email) from the email address associated with your account.

5.2 The Rights of Access to and Portability of Your Personal Data

You can access most of your data through the site. However, you may make a formal request to access your Personal Data held by Simply Hired. In order to do so, please send an email to privacyoffice @ simplyhired.com (please remove spaces when sending email) from the email address associated with your account, and paste the following sentence in your email: “I am requesting to access my personal data.” Simply Hired will provide your Personal Data to you in a portable format to allow it to be transmitted to third parties.

5.3 The Right to Delete Your Personal Data

You can delete your data through the site, otherwise a formal request can be made. A formal request can be made by writing to: privacyoffice @ simplyhired.com (please remove spaces when sending email). This email should come from the email address associated with your account. Please include your name and email address in email requests.

6. International Data Transfers

When we obtain Personal Data about you, we will process and store the information outside of the country in which you are located, including in the United States. Such transfers are performed in full compliance with applicable data protection rules and subject to appropriate safeguards, primarily through the use of extensive data protection agreements, in order to ensure adequate protection of users’ Personal Data. The services provided to you and the functionality of the Site could not be provided without such a transfer. If you do not wish your information to be transferred in this way you should not use this Site.

7. Privacy Shield Frameworks

Simply Hired complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland transferred to the United States pursuant to Privacy Shield. Simply Hired has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Simply Hired is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also may correct, amend, or delete the personal information we hold about you. In order to exercise these rights, please follow the steps outlined in Section 5 of this policy. If requested to remove data, we will respond within a reasonable timeframe.

As noted in Section 4 of this policy, Simply Hired may share your data with third parties. If you do not wish for your data to be shared with third parties, please follow the steps outlined in Section 5.3 of this policy and we will delete your personal data and cease the processing of said data.

Simply Hired’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Simply Hired remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Simply Hired proves that it is not responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, Simply Hired commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact Simply Hired at privacyoffice @ simplyhired.com (please remove spaces when sending email), or by mail to Simply Hired Privacy Department, 6433 Champion Grandview Way, Austin, Texas, 78750.

Simply Hired has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction

8. How We Protect Personal Data

Simply Hired seeks to use reasonable security measures to help protect against the loss, misuse and alteration of the Personal Data under Simply Hired’s control. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. In addition, please note that emails, messages sent via your web browser, and other similar means of communication with other users, are not encrypted. Therefore, while we strive to protect your information, we cannot guarantee its security.

Please also be aware that we may use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that may be nonnegotiable; these service providers have informed us or the general public that they apply security measures they consider adequate for the protection of information within their system, or they have a general reputation for applying such measures. However, we will not be liable (to the fullest extent permitted by law) for any damages that may result from the misuse of any information, including Personal Data, by these companies. Please see the section on International Data Transfers of this Privacy Policy for liabilities pertaining to the transfer of Personal Data of individuals in the EU and Switzerland.

9. Contacting Simply Hired and Complaints

You can direct questions regarding this Privacy Policy or any privacy concerns to Simply Hired by emailing us at: privacyoffice @ simplyhired.com (please remove spaces when sending email). Please include your name and email address in email requests. You may also send written correspondence to: Simply Hired Privacy Department, 6433 Champion Grandview Way, Austin, Texas, 78750. We aim to respond in a reasonable time. Our Data Protection Officer will manage your complaint and will give you additional information about how it will be handled.

10. Links to Other Websites

Our Sites may contain links to other websites that are owned or operated by other companies, including but not limited to affiliated third party entities. If you choose to visit any linked websites, we encourage you to review their privacy statements carefully, as they may differ from ours. We are not responsible for the content or privacy practices of websites that are owned by companies outside of Simply Hired’s affiliate and parent companies.

Our Sites may also link to co-branded websites that are maintained by Simply Hired and one or more of our business partners or third party affiliates who are collecting your Personal Data pursuant to their own privacy practices. We encourage you to read the privacy statements on any co-branded site to which you link for information on the privacy practices of that site.

Please note that no electronic transmission of information can be entirely secure. We cannot guarantee that the security measures we have in place to safeguard Personal Data will never be defeated or fail, or that those measures will always be sufficient or effective. Simply Hired seeks to use reasonable security measures to help protect against the loss, misuse and alteration of the Personal Data under Simply Hired’s control. As a user of the Sites, you understand and agree that you assume all responsibility and risk for your use of the Sites and the internet generally, the documents you post or access and for your conduct on and off the Sites.

California, USA Residents

California law permits its residents to, once per calendar year, request and receive information about a business' disclosure of certain categories of Personal Data to other companies for direct marketing purposes. If you are a California resident and a user of any of the Sites, you can request a copy of this information from Simply Hired by sending an email to privacyoffice @ simplyhired.com (eliminate spaces when sending email). Please include your name and email address in email requests.

About Cookies, Tracking Choices, and Third Party Advertisers

By using or accessing the Sites, you are consenting to Simply Hired's use of Cookies as follows:

Introduction: What is a cookie?

This Cookie policy helps to explain the occasions when and why cookies may be sent to visitors to the Sites (referred to in this policy as "we", "us" or "our"). "Cookies" are text-only pieces of information that a website transfers to an individual's hard drive or other website-browsing equipment for record-keeping purposes, and allow the Sites to remember important information that will make your use of Simply Hired more convenient. A cookie will typically contain the name of the domain from which the cookie has come, the "lifetime" of the cookie, and a randomly generated unique number or other value.

Session Cookies are temporary cookies that remain in the cookie file of your browser until you leave the Site.

Persistent Cookies remain in the cookie file of your browser for much longer (though how long will depend on the lifetime of the specific cookie). When we use session cookies to track the total number of visitors to the Sites, this is done on an anonymous aggregate basis (as cookies do not in themselves carry any personal data). We may also employ cookies so that we remember your computer when it is used to return to the Sites to help customize your Simply Hired web experience. We may associate personal information with a cookie file in those instances.

How Simply Hired uses cookies

Like most websites, we use cookies for a variety of purposes in order to improve your online experience, for analytics and for marketing, but specifically we use Cookies on the Sites for the following purposes:

Purpose	Description
Analytical Purposes	We use cookies to analyze user activity in order to improve the Sites. For example, we can use cookies to look at aggregate patterns like the average number of job searches that users perform. We can use such analysis to gain insights about how to improve the functionality and user experience of the Sites. We also use cookies to track the aggregate number of unique visitors to the Sites.
Your Preferences & User Experience	We use cookies to gather certain information about users in order to store user preferences on our Site to make your user experience more consistent and convenient. For example, we may store the recent searches you have performed in a cookie so that we can allow you to easily repeat those searches when you return to our Site.
Marketing	We use cookies from Facebook and Google for marketing purposes. These cookies allow us to display Simply Hired promotional material to you on other sites you visit across the Internet. Simply Hired may also share information about your behavior on the Sites with third parties (including operators of third-party websites and/or social networking sites) in order to show you targeted advertisements and other content that has been customized for you.
Security Purposes	We use cookies to limit certain types of cyber attacks.
Referral Tracking	We use cookies to associate user activity with the third party website that referred the user to the Sites, or to associate user activity that Simply Hired referred to a third party website. These third party partner websites receive credit for the activity of users they refer to the Sites, or give Simply Hired credit for the activity of users referred to such third party websites. We do not share any personal information or information about individual user activities with these partner entities. We also use cookies to associate user activity with the email campaign that referred the user to our Site.
Testing, Usability, and Performance Improvement Purposes	We use cookies to ensure users receive a consistent user experience while we conduct A/B testing on certain aspects of the Sites in order to improve our product offerings. We also use cookies to improve the performance and reliability of the Sites.

Managing cookies in your browser

Use the options in your web browser if you do not wish to receive a cookie or if you wish to set your browser to notify you when you receive a cookie. You can easily delete and manage any cookies that have been installed in the cookie folder of your browser by following the instructions provided by your particular browser manufacturer.

If your browser is not listed here, consult the documentation that your particular browser manufacturer provides. You may also consult your mobile device documentation for information on how to disable cookies on your mobile device. If you disable all cookies, you may not be able to take advantage of all the features of the Sites.

Third-Party Cookies

The following cookie table lists examples of the third party cookies used on Simply Hired. Although we may update this list periodically, please be advised that the names of cookies, pixels and other technologies are subject to change.

Domain	Cookie Name	Description	Expiration	Opt-out
Third party	UID	Used by Comscore to gather information regarding visitor activity on the Sites. The data gathered is sent to comScore for analysis and reporting and used to improve the Sites.	1 year and 355 days	Scorecard Research cookie opt-out
Third party	UIDR	Used by Comscore to collect anonymous data on the traffic and engagement for the Sites in order to provide information on their competitive performance. Data collected by ScorecardResearch is used only in aggregate form.	1 year and 355 days	Scorecard Research cookie opt-out
Third party	_ga	Used by Google Analytics to track user activity over different browsing sessions	2 years	Google Analytics opt-out
Third party	_gat	Used by Google Analytics to throttle requests	10 minutes	Google Analytics opt-out
Third party	fr	Used by Facebook to track users for marketing purposes	3 months	Facebook opt-out

Changes To Our Cookie Policy

From time to time, it may be necessary for us to change this cookie policy. We suggest that you check here periodically for any changes.

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