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
Caroo Ltd is the controller and is responsible for your personal data (referred to as "Caroo", "we", "us" or "our" in this policy).
Our full details are:
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.
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.
The data we collect about you
We may collect, use, store and transfer different kinds of personal data about you as follows:
We explain these categories of data below and more specifically in the table describing our ‘uses’ and legal basis.
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.
How is your personal data collected?
We will collect and process the following data about you:
analytics providers such as Google based outside the EU;
when you agree to integrate/combine a social media site (such as Facebook) with your account with us.
How we use your personal data
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:
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.
Categories of data
Lawful basis for processing
To install the App and register you as a new App user.
This is before installation and setting up an account (either as an ‘employer’ or individual seeking roles).
With regard to Contact data, we specifically require your telephone number to validate that you are who you say you are. To do this, your phone number is submitted to our server via HTTPS. Our server then generates a unique code that is sent to the phone number inputted. You then input that code into the App which checks that it is valid.
We must verify your identify using your telephone number, and device details, and you must generate a password at the point of sign up.
The minimum data required to do so is your phone number and password.
Your phone number is not stored on our servers until your identify is validated.
To receive Services and for us to deliver Services via the App based solely on algorithmic calculations (i.e. we may disclose your anonymous profile and the types of data set out here to any of the potential employers/brands who are looking for candidates on the App/via the Services and which we determine there is a more than 40% match based on relevant Data you have submitted, including Work Skill, Work History and Content and Education data).
Where you are an ‘employer’ we only use your Identity Data (being the name and contact details of the contact person provided) to provide the Services to match with candidates.
Content Data (i.e. photos, video biography, links, messages etc)
Necessary to perform our contract with you – to provide Services that use algorithmic matches with parties looking to fill roles (to create opportunities for you using the Services by displaying the ‘Standard’ data described, left, to parties looking for individuals). Please note we do not disclose Contact Data or Identity Data unless you request us to via the App or Service.
Where we identify a match, we disclose the following types of data to the potential employer (within the categories of Data):
Until you express an interest in a role, we do not disclose (within these categories of Data):
Where you express an interest in a role, and your details described above are shared with a third party, please note below the section regarding ‘Disclosure to Third Parties’ and how their privacy notices apply. As part of our relationship with an employer, we may be required to make available your data to a third party database as utilised by the employer (e.g. ‘Workable’) and it is deemed to be a legitimate interest to do so (for you to benefit) and also necessary for the proper use of our platform. However, please pay attention to any employer privacy notice that will describe this before expressing an interest in a role.
To manage our relationship with you including notifying you of changes to the App or any Services
Performance of a contract with you to fulfil our relationship
Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)
Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
To make available to you tailored content and media made available via the App to tailor and focus the Services for you
Content Data (i.e. photos, video biography, links, messages etc)
Performance of a contract with you to fulfil our relationship
Necessary for our legitimate interests (to improve and focus the content we create)
To enable you to participate in a survey
Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)
To administer and protect our business and this App including troubleshooting, data analysis and system testing
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security).
If any abuse is reported – for instance using the messaging system via the Service, we may need to review Content sent or received over the App.
To monitor trends so we can improve the App and Services
Necessary for our legitimate interests (to develop our products/Services and grow our business)
Disclosures of your personal data
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]:
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:
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:
You can exercise any of these rights at any time by contacting us at firstname.lastname@example.org.
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.
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.
Description of categories of personal data
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