Caroo Ltd (we) are committed to protecting your personal data and respecting your privacy.

Introduction

This policy (together with our terms and conditions as set out at https://caroo.co.uk/pages/terms-conditions (Terms) and any additional terms of use incorporated by reference into the Terms, together our Terms of Use) applies to your use of:

• The ‘CAROO’ mobile application software (App) and caroo.co.uk/portal.caroo.co.uk (the App Sites),once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device) or access the App Sites.
• Any of the services accessible through the App, which are candidate and worker algorithmic matching services to match opportunities with potential parties looking for workers (Services) that may also be available on the App Sites or other sites of ours (Services Sites). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

This App and our Services are not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

This policy is provided in a layered format so you can click through to the specific areas set out below.

• IMPORTANT INFORMATION AND WHO WE ARE
• THE DATA WE COLLECT ABOUT YOU
• HOW IS YOUR PERSONAL DATA COLLECTED?
• HOW WE USE YOUR PERSONAL DATA
• DISCLOSURES OF YOUR PERSONAL DATA
• INTERNATIONAL TRANSFERS
• DATA SECURITY
• DATA RETENTION
• YOUR LEGAL RIGHTS
• GLOSSARY
• DESCRIPTION OF CATEGORIES OF PERSONAL DATA

Caroo Ltd is the controller and is responsible for your personal data (referred to as "Caroo", "we", "us" or "our" in this policy).

We have appointed a data privacy officer. If you have any questions about this privacy policy, please contact them using the details set out below.

Contact details

Our full details are:

• Full name of legal entity: Caroo Ltd
• Name or title of DPO: Gareth Peterson
• Email address: mydata@caroo.co.uk
• Postal address:Optimise Capital, PO Box SK9 5BQ, Hesketh House, Water Lane, Wilmslow, Cheshire, United Kingdom, SK9 5BQ

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO),the UK supervisory authority for data protection issues or other competent supervisory authority of an EU member state if the App is downloaded outside the UK.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated on 09/01/2020. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the App or log onto one of the Services Sites. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third party links

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

We may collect, use, store and transfer different kinds of personal data about you as follows:

• Identity Data.
• Contact Data.
• Work Skill Data.
• Work History Data.
• Education Data.
• Device Data.
• Content Data.
• Profile Data.
• Usage Data.
• Location Data

We explain these categories of data below and more specifically in the table describing our ‘uses’ and legal basis.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.  Please do not upload any such data or data that could be used to construe this information, using the App or Services.

We will collect and process the following data about you:

• Information you give us. This is information (including Profile, Identity, Contact, Financial, Work History, Education, Content, Work Skill Data).  You may also provide Location Data, which will be as notified by yourself, rather than using any function of your Device – see below) you consent to giving us about you by filling in forms on the App and/or the Services Sites, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App and or Service Site, download or register an App, subscribe to any of our Services, search for an App or Service, make an in-App enquiry relating to a job or position, share data via an App's social functions or with a potential employer or brand, and when you report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.
• Information we collect about you. Each time you visit one of Our Sites or use one of our Apps we will automatically collect personal data including Content, Device and Usage Data. We collect this data using ‘Firebase Analytics’, ‘AppsFlyer’ and Google Analytics’ cookies and ‘Google Tag Manager‘ tracking solutions.
• Location Data. We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your setting.
• Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

• Device Data from the following parties:

analytics providers such as Google based outside the EU;

• Identity Data:

when you agree to integrate/combine a social media site (such as Facebook) with your account with us.

Cookies

For more information about how we use Cookies, and your ability to either accept or decline Cookies, please see our Cookie Policy.

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

• Where you have consented before the processing.
• Where we need to perform a contract we are about to enter or have entered with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Click here [LINK TO GLOSSARY: LAWFUL BASIS] to find out more about the types of lawful basis that we will rely on to process your personal data.

We will not send you direct marketing communications by email or text, nor will we share your personal data with any third party for marketing purposes.  Should this change, we will obtain your consent first and, even if you give consent at that time, you have the right to withdraw that consent at any time by contacting us.

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table [Purposes for which we will use your personal data]:

• Third Parties as set out in the Glossary.
• Third parties listed in the table including third party brands or companies who are seeking individuals to fill roles and opportunities (the types of data disclosed are as set out in the table, above).  Please note that any information or data you chose to disclose to a third party via the App will be accessed, used and stored by that third party under their own privacy policies and notices.  Where you express an interest in a role please consider the employer’s privacy notice before doing so – when you express an interest we may be required to facilitate the transfer of your data to a third party database for the employer to monitor (e.g. “Workable”).  Always carefully consider what you disclose, and the terms of any third party privacy notice.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy

Some of our external third parties (for example, Digital Ocean Inc who we use for hosting) are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield. Due to ongoing legal reviews of this legal basis, we do not rely on it as the sole basis for international transfers. 

Digital Ocean Inc is a supplier who we have deemed suitable on the basis of their use of the ‘model contracts’ – the Standard Contractual Clauses and the EU-US Privacy Shield (though this is, due to recent legal findings, not the only basis we rely on, but rather one factor we consider). 

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

All information you provide to us is stored on our secure servers or those of our third party suppliers (see above regarding Digital Ocean Inc).  Where we have given you (or where you have chosen) a password that enables you to access certain parts of the App, the Services or the Service Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We will collect and store personal data on your Device using application data caches.  This includes photographs and videos you wish to upload (which are included within ‘Content Data’). The temporary file created on your device is then deleted; depending on what operating system your Device uses, this may be immediately (or very soon) after the file is uploaded to our servers (Android) or at some other indeterminate point in the future (iOS).

On iOS devices you may also use the Device’s key chain function to store your Profile Data, being passwords and usernames (where it is encrypted in accordance with your Device’s standards and policies) and where the App can access them. 

Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.

In some circumstances you can ask us to delete your data.  When you delete your account from the App and or Service, we will delete all of your data within our databases and control: see [Your legal rights] below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below),where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  1. 1. if you want us to establish the data's accuracy;
     2. where our use of the data is unlawful but you do not want us to erase it;
     3. where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
     4. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You can exercise any of these rights at any time by contacting us at mydata@caroo.co.uk.

Lawful basis

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third parties

Service providers acting as processors based in the USA and UK who provide IT and system administration services.  These include Digital Ocean Inc (see comment on international transfers and our grounds to do so) and Apposing Ltd.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, legal, insurance and accounting services.

• Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender.
• Contact Data: address, email address and telephone numbers.
• Work Skill Data: details regarding your experience and skills and tools.
• Work History Data: details of previous and past employers, years’ experience, contracting parties or placements.
• Education Data: qualifications, schools, universities, certifications, diplomas and other information relating to, and support, your education and skillset.
• Content Data: includes information that you upload via the App or Our Sites including photos, videos, url links, details of target salary, your interests, preferences, hobbies, professional status, or other digital content that you decide to share.
• Profile Data: includes your username and password, App usage history, feedback and survey responses.
• Usage Data: includes details of your use of our App (such as last use) or your visits to any of Our Sites including, but not limited to, traffic data and other communication data.
• Location Data: includes your current location disclosed by GPS technology.  
• Device Data: includes details of the device, operating system and other technical information regarding the mobile or other computer device used to access the App or Services.