LAST UPDATED: Wednesday, May 8, 2024
We are delighted that you have shown interest in the services of DCG IT Ltd trading as Recann. and its Affiliates listed below (hereinafter collectively referred to as “Recann”, “we”, “us”, and “our”), which services are provided via https://www. Recann.com/ or our other websites, through our software, or otherwise (collectively the “Services” or “Service”). Data protection is a particularly high priority for Recann. The use of the Recann website is possible without any indication of personal data; however, if a data subject wants to use our Services, processing of personal data may become necessary. Recann provides recruitment related services and we will, therefore, use your personal data in order for us to be able to deliver these services to you whether you are a candidate, client, or website user. Recann is deeply committed to ensuring the privacy and protection of your personal data. This includes any information that may be collected during the process of finding you a job, maintaining a relationship with you after placement, offering a service to you, receiving a service from you, utilizing your data to request assistance in relation to one of our candidates, or during your visit to our website or Services. Recann recognizes the importance of privacy and takes great care to uphold the confidentiality of all personal information that is collected.
This Privacy Policy covers Recann Ltd., 3rd Floor Eastgate, Castle Street, Castlefield, M3 4LZ as well as the following affiliated entities (the “Affiliates”):
- Recann Limited, Clarence House, Clarence Street, Manchester, M2 4DW
- DCG IT GmbH, Enderstr. 94/ Haus A, 01277 Dresden
- Recann BV. Kabelweg 57, 1014BA, Amsterdam
- DCG IT Inc, 535 Fifth Avenue, New York, NY 10017
- Recann AB, Box 45087, 104 30 Stockholm.
The Privacy Policy sets out how we look after your personal data. It informs you about your privacy rights and how some data protection and privacy laws, including but not limited to the European Union General Data Protection Regulation (GDPR) and the California Consumer Privacy Act of 2018 (CCPA) (collectively, “Data Privacy Law”) protect you. Utilizing this Privacy Policy, we would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process.
If we do not maintain information in a manner that identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular individual or household, such information is not considered personal data and this Privacy Policy will not apply to our processing of that information.
As the controller, Recann strives to take reasonable technical and organizational measures to ensure the complete protection of personal data processed. However, Internet-based data transmissions may, in principle, have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g., by telephone.
We strive to make our Privacy Policy comprehensible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used. In this Privacy Policy, we use, among other things, the following terms:
A) Personal data or personal information
Personal data or personal information has the meaning given in the Data Privacy Law applicable to you, and includes any information relating to an identified or identifiable natural person (“data subject”).
B) Data subject
Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
C) Processing
Processing is any operation or set of operations which are performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
D) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
E) Profiling
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular, to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
F) Pseudonymization
Pseudonymization means processing of personal data in a way that it can no longer be linked to a specific data subject without the use of additional information, provided that such additional information is kept separate and protected with special measures to make sure that the personal information cannot be linked back to an identified or identifiable natural person.
G) Controller or ”business”
Controller or ”business” is the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by applicable law, the controller or the specific criteria for its nomination may be provided for by such applicable law.
H) Processor
Processor is a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
I) Recipient
Recipient is a natural or legal person, public authority, agency, or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data during a particular inquiry in accordance with applicable law shall not be regarded as recipients; the processing of those data by those public authorities must adhere to the applicable data protection rules according to the purposes of the processing.
J) Third-party
Third-party is a natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
K) Consent
Consent of the data subject is any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which the data subject, through explicit declaration or clear positive action, indicates agreement to the processing of personal data relating to the data subject.
3 ENTITIES COVERED BY THIS PRIVACY POLICY
Recann is made up of different legal entities affiliates, partners, licensors, subsidiaries, or related companies. When we mention Recann, "we," "us," or "our" in this notice, we are referring to the relevant Recann group entity responsible for processing your personal data.
4 Recann’S ROLE REGARDING PERSONAL DATA
We process personal data either for own purposes or on behalf of our customers. This means that we do not always have the same degree of decision-making with respect to why and how each piece of personal data will be processed.
? Regarding the Personal Data of job applicants, contractors, users of our website(s), apps, or our services, or business contacts and prospects of Recann, we decide the purposes and means of processing, and consequently act as a data controller or “business”.
? In certain instances, we process personal data as “service provider” or data processor on behalf of our customers, who use our services. Where you give your data to one of our customers or where we collect your personal data on their behalf, our customer’s privacy notice, rather than this Notice, will apply to our processing of your personal data. If you have a direct relationship with one of our customers, please contact them to exercise your privacy rights
The website and/or Services of Recann uses cookies. Cookies are text files that are placed[DS1] on a user’s browser or device. For more information, see our cookie policy.
Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. A specific Internet browser or device can be recognized and identified using the unique cookie ID.
Through the use of cookies, Recann can provide the users with more user-friendly services that would not be possible without the cookie setting.
By means of a cookie, the information and offers can be optimized with the user in mind. Cookies allow us, as previously mentioned, to recognize our users. The purpose of this recognition is to make it easier for users to access and utilize our website or Services. Recann uses cookies, so that the user does not have to enter access data each time our website or Service is accessed, because this is taken over by the Services, and the cookie is thus stored on the user’s computer system or device.
You may, at any time, prevent the setting of cookies through our website or Services subject to applicability, by employing a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject disables the setting of cookies in the Internet browser used, not all functions of our website or Services may function optimally or be entirely usable.
You may also set your browser to send a Do Not Track (DNT) signal. For more information, please visit https://allaboutdnt.com. Please note that our services do not have the capability to respond to “Do Not Track” signals received from web browsers.
We do not engage in cross-context behavioural advertising.
6 COLLECTION OF GENERAL DATA AND OTHER SPECIFIC INFORMATION
Recann collects various types of information when a data subject or an automated system interacts with its Services. This information is generally considered to be data and is used in line with the terms of this Privacy Policy. This general data and information are stored in the server log files.
General Data:
• The browser types and versions used,
• The operating system used by the accessing system,
• The website from which an accessing system reaches our Services (so-called referrers),
• The sub-websites,
• The dates, times, and frequency with which you access our service,
• An Internet protocol address (IP address),
• The Internet service provider of the accessing system,
• Names,
• Email address,
• Phone numbers and,
• Any other similar data and information that may be used in the event of attacks on our information technology systems.
Data collected from Candidates:
Depending on the relevant circumstances in line with local laws and obligations we will most likely collect some or all of the information detailed below in order for us to offer you employment options in line with your circumstances and interests:
• Name,
• Photograph,
• Contact Details,
• Registered address,
• Date of birth,
• Professional profiles available in the public domain, e.g., LinkedIn, Twitter, or Facebook (We may also collect data from reviewing market and business trends through the analysis of online and offline media and from delegate lists at events),
• Skillset (if not already covered in your CV),
• Job preferences (if not already covered in your CV),
• Current employer/client,
• Your right to work, when requested by our client which may include a photograph, nationality, place of birth, birth certificate, driving license, etc,
• Current salary/employment conditions,
• Desired salary/employment conditions,
• Other documentation, if requested by our clients (e.g., references),
• Marital status,
• Bank account and national insurance number (so we can make payments to you and account for tax if you are working as an agency worker supplied through Recann),
• Online skill tests,
• Details of health/disabilities (where you choose to provide this data and it is relevant),
• Marketing and Communications Data: data that we capture when you sign up for our newsletters, including your preferences regarding receiving marketing communications from us,
• Education Details,
• Employment History,
• Emergency Contact Details,
• Referee Details,
• Your right to work status,
• Nationality,
• A copy of your driving license/passport /identity card (if requested by a client to fulfil our obligations with them on your behalf),
• Financial Information (if allowed by applicable law, where we need to carry out financial background checks if requested by a client to fulfil our obligations with them on your behalf),
• National Insurance Number (if requested by a client to fulfil our obligations with them on your behalf),
• Details of Criminal Convictions if allowed by law and this is requested for a role that you are interested in applying for,
• Details about your current and expected salary, pensions & benefits arrangements,
• Information on your interests and needs regarding future job opportunities,
• Any additional information you choose to disclose to us, and any additional information your referees disclose to us,
• Any additional information our clients disclose to us or that we find from a third party such as a job board,
• A lot of the above data will only be collected as part of a pre-screening call with one of our consultants. Upon initial contact, we will process the data that you have made available on your CV or third-party profiles such as profiles filled out on a job board or networking site.
The table below describes the categories of personal data we have collected about you in the last twelve months.
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Identifiers A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. |
You provide it directly to us when:
We receive it:
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Special categories of Personal Data A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Data included in this category may overlap with other categories. |
You provide it directly to us when:
We receive it:
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Protected characteristics Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). |
You provide it directly to us when:
We receive it:
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Professional or employment-related information Current or past job history or performance evaluations, job title. |
You provide it directly to us when:
We receive it:
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We must have a valid reason to use your personal data. This is called the "lawful basis for processing".
When we act as a data controller, we may process your personal data on the basis of:
- the need to perform a contract with you;
- our legitimate interests or those of a third party;
- any other ground, as required or permitted by law.
We rely on our legitimate interests when, for example, we process the personal data we collect from you to send you marketing communications and to tell you about Recann and its services as well as about job opportunities, to communicate with you about changes to our services, and to provide, secure, develop, and improve our services. We also rely on our legitimate interest in carrying out our business operations and ensuring that our business runs smoothly.
Within the scope of this Privacy Policy, we may also process personal data based on the instructions of our customers. To learn about their lawful bases for processing your personal data, please read the privacy notice(s) of our customers.
Our main focus is on providing recruitment services. Therefore, the main purpose of processing personal data is centred on providing candidates.
When using these general data and information, Recann does not draw any conclusions about the data subject. Rather, this information is needed for:
• Storing your details on our database so that we can contact you about recruitment services,
• Keeping records of conversations and meetings so that we can tailor our services to you,
• Processing your data for the purpose of targeting appropriate marketing campaigns,
• Deliver the content of our Services correctly,
• Optimize the content of our Services as well as its advertisement,
• Ensure the long-term viability of our information technology systems and website technology,
• For analytics purposes,
• To facilitate account creation and logon process,
• Request feedback,
• As necessary for the basic functionality of the Services and account management (billing our clients),
• Providing law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack,
• Offering a recruitment service that includes a dedicated account manager and up-to-date job listings,
• Managing access to our Services and personalize your experience of it,
• Responding to your communications and send you email newsletters, alerts, etc. that you have subscribed to. You can unsubscribe at any time by clicking on the unsubscribe link in every email,
• Analysing your use of our Services and gather feedback to improve it and your user experience,
• Collecting data from you and other sources, such as LinkedIn, to store your details on our database so that we can contact you regarding recruitment,
• Providing you with recruitment services and assisting you in the recruitment process,
• Assessing your data against vacancies that could be of interest and suitable to you,
• Sending your information to clients to apply for jobs we have discussed with you and evaluate your eligibility for those jobs,
• Allowing you to upload your CV to client online portals to introduce you to opportunities,
• For fulfilling contractual agreements entered into and carrying out agreements on your behalf with third parties and clients in relation to recruitment,
• Processing payments through payroll or invoice processes,
• Carrying out customer satisfaction questionnaires,
• Processing your data to update you with relevant job opportunities that align with your expectations,
In some cases, we may be legally required to collect certain data, and we will not be able to provide you with our services without such data.
If you no longer wish for your details to be shared in this way please let us know by sending an email to privacy@Recann.com.
Recann analyses anonymous data and information statistically, with the goal of enhancing the protection and security of Recann data and to achieve the best level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
We may gather, apply, and share anonymous information, such as statistical or demographic data, for any purpose. This data, which is derived from your personal data, is not considered personal information under the law because it does not directly or indirectly reveal your identity. For instance, we may merge your usage information to determine the percentage of users who utilize a specific feature. However, if we combine or connect this data with your personal information so that it can directly or indirectly identify you, we will consider the combined data as personal information, which will be handled according to this Privacy Policy.
9 SHARING OF YOUR PERSONAL DATA
The following table describes, in the last twelve months, the categories of information we have disclosed to third parties for business purposes, and the categories of those third parties.
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Personal Data Disclosed for Business Purposes? |
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Category |
Yes or No |
Categories of Third Parties Receiving Personal Data |
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Identifiers |
Yes |
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Special categories of personal information |
Yes |
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Internet or similar network activity |
No |
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Sensory data |
No |
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Professional or employment-related information |
Yes |
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Non-public education information |
Yes |
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Inferences drawn from other personal data |
Yes |
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10 OTHER DISCLOSURES OF YOUR PERSONAL DATA
Your personal data will be kept on our company's CRM database and can be accessed by our employees in various international locations. Additionally, we may disclose your personal data if we sell or transfer all or some of our company’s business interests, assets, or both, or in connection with a corporate restructuring. Further, we may disclose your personal data to our subsidiaries or affiliates, but only if necessary for business purposes. We may share your personal data to comply with legal obligations or if we have a good-faith belief that we need to disclose it in order to comply with official investigations or legal proceedings (whether initiated by governmental/law enforcement officials, or private parties). If we have to disclose your personal data to governmental/law enforcement officials, we may not be able to ensure that those officials will maintain the privacy and security of your personal data. We may also disclose your personal data to defend against legal claims, or protect the rights and safety of Recann and others.
We may use your data for marketing purposes, such as informing you about similar job opportunities to the one you applied for or submitted your CV for, when you have supplied your data by applying for a job or submitting your CV to us and when you have made your CV available via a third-party online job board. We may also reach out to you if we have had previous engagements with you, and we are promoting recruitment-related services. We will most likely only contact you by email to suggest other jobs that could be of interest, in line with the original role we gathered your details for, in order to increase the chances of finding you a new position.
You have the right to object to us processing your data for the purposes of direct marketing and you can do so by sending us an email at privacy@Recann.com. If you do not wish to receive further marketing emails, you can also use the unsubscribe option in our marketing emails.
12 CONTACT POSSIBILITY VIA THE WEBSITE (Services)
Recann’s website (Services) provide information for quick electronic communication with Recann, as well as direct communication with us, which also includes an email address. If a data subject contacts Recann by email or via a contact form, the personal data sent by the data subject are automatically stored. Such personal data sent on a voluntary basis by a data subject to Recann are stored for the purpose of processing or contacting the data subject.
We are strongly committed to keeping your personal data safe. We have implemented and will maintain technical, administrative, and physical measures that are reasonably designed to help protect your personal data from unauthorized processing. We are also delighted to have been awarded Cyber Essentials accreditation for adhering to good practice in information security.
Whilst we take reasonable commercial steps to ensure that personal data is protected, we cannot guarantee the security and integrity of the information that has been transmitted to our Services.
You have specific rights regarding your personal data that we collect and process. Please note that you can only exercise these rights with respect to personal data that we process about you when we act as a data controller or as a “business” under the CCPA. To exercise your rights with respect to information processed by us on behalf of one of our customers, please read the privacy notice of that customer.
In this section, we first describe those rights and then we explain how you can exercise those rights.
Right to Know What Happens to Your Personal Data
This is called the right to be informed. It means that you have the right to obtain from us all information regarding our data processing activities that concern you, such as how we collect and use your personal data, how long we will keep it, and who it will be shared with, among other things.
We are informing you of how we process your personal data with this Privacy Policy.
We will always try to inform you about how we process your personal data. However, if we do not collect the personal data directly from you, the GDPR exempts us from the obligation to inform you (i) when providing the information is either impossible or unreasonably expensive; (ii) the gathering and/or transmission is required by law, or if (iii) the personal data must remain confidential due to professional secrecy or other statutory secrecy obligations.
Right to Know What Personal Data Recann Has About You
This is called the right of access. This right allows you to ask for full details of the personal data we hold on you.
You have the right to obtain from us, including confirmation of whether or not we process personal data concerning you, and, where that is the case, a copy or access to the personal data and certain related information.
Once we receive and confirm that the request came from you or your authorized agent, we will disclose to you:
- The categories of your personal data that we process;
- The categories of sources for your personal data;
- Our purposes for processing your personal data;
- Where possible, the retention period for your personal data, or, if not possible, the criteria used to determine the retention period;
- The categories of third parties with whom we share your personal data;
- If we carry out automated decision-making, including profiling, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you;
- The specific pieces of personal data we process about you in an easily-sharable format;
- If we disclosed your personal data for a business purpose, the categories of personal data and categories of recipients of that personal data for disclosure;
Under some circumstances, we may deny your access request. In that event, we will respond to you with the reason for the denial.
The CCPA does not allow us to disclose Social Security numbers, driver’s license numbers or other government-issued identification numbers, financial account numbers, any health insurance or medical identification numbers, account passwords, or security questions and answers. We can inform you that we have this information generally, but we may not provide the specific numbers, passwords etc. to you for security and legal reasons.
Right to Change Your Personal Data
This is called the right to rectification. It gives you the right to ask us to correct without undue delay anything that you think is wrong with the personal data we have on file about you, and to complete any incomplete personal data. If you would like to change your personal data, please contact us at privacy@Recann.com.
This is called the right to erasure, right to deletion, or the right to be forgotten. This right means you can ask for your personal data to be deleted. If you would like to delete your personal data, please contact us at privacy@Recann.com.
Sometimes we can delete your information, but other times it is not possible for either technical or legal reasons. If that is the case, we will consider if we can limit how we use it. We will also inform you of our reason for denying your deletion request.
Right to Ask Us to Limit How We Process Your Personal Data
This is called the right to restrict processing. It is the right to ask us to only use or store your personal data for certain purposes. You have this right in certain instances, such as where you believe the data is inaccurate or the processing activity is unlawful.
Right to Ask Us to Stop Using Your Personal Data
This is called the right to object. This is your right to tell us to stop using your personal data. You have this right where we rely on a legitimate interest of ours (or of a third party). You may also object at any time to the processing of your personal data for direct marketing purposes.
We will stop processing the relevant personal data unless: (i) we have compelling legitimate grounds for the processing that override your interests, rights, or freedoms; or (ii) we need to continue processing your personal data to establish, exercise, or defend a legal claim.
Right to Port or Move Your Personal Data
This is called the right to data portability. It is the right to ask for and receive a portable copy of your personal data that you have given us or that you have generated by using our services, so that you can:
- Move it;
- Copy it;
- Keep it for yourself; or
- Transfer it to another organization.
We will provide your personal data in a structured, commonly used, and machine-readable format. When you request this information electronically, we will provide you a copy in electronic format.
Right Related to Automated Decision Making
We sometimes use computers to study your personal data. We might use this personal data so we know how you use our services. For decisions that may seriously impact you, you have the right not to be subject to automatic decision-making, including profiling. But in those cases, we will always explain to you when we might do this, why it is happening and the effect.
Right to Withdraw Your Consent
Where we rely on your consent as the legal basis for processing your personal data, you may withdraw your consent at any time. If you withdraw your consent, our use of your personal data before you withdraw is still lawful.
If you have given consent for your details to be shared with a third party and wish to withdraw this consent, please also contact the relevant third party in order to change your preferences.
- Deny you goods or services;
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits or imposing penalties;
- Provide you a different level or quality of goods or services; or
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
15 HOW CAN YOU EXERCISE YOUR PRIVACY RIGHTS?
To exercise any of the rights described above, please submit a request by either:
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In order to correctly respond to your privacy rights requests we need to confirm that you made the request. Consequently, we may require additional information to confirm that you are who you say you are.
For requests sent by other means, we will verify your identity by asking you for information that matches the information that we already hold about you. We may also send you an e-mail or text message containing a confirmation code.
We will only use the personal data you provide us in a request to verify your identity or authority to make the request.
If you are submitting a request on behalf of somebody else, we will need to verify your authority to act on behalf of that individual. When contacting us, please provide us with proof that the individual gave you signed permission to submit this request, a valid power of attorney on behalf of the individual, or proof of parental responsibility or legal guardianship. Alternatively, you may ask the individual to directly contact us by using the contact details above to verify their identity with Recann and confirm with us that they gave you permission to submit this request.
Response timing and format of our responses
We will confirm the receipt of your request within ten (10) business days and, in that communication, we will also describe our identity verification process (if needed) and when you should expect a response, unless we have already granted or denied the request.
Please allow us up to a month to reply to your requests (except requests to stop selling your personal data) from the day we received your request. If we need more time (up to 90 days in total), we will inform you of the reason why and the extension period in writing.
If we cannot satisfy a request, we will explain why in our response. For data portability requests, we will choose a format to provide your personal data that is readily useable and should allow you to transmit the information from one entity to another entity without difficulty.
We will not charge a fee for processing or responding to your requests. However, we may charge a fee if we determine that your request is excessive, repetitive, or manifestly unfounded. In those cases, we will tell you why we made that determination and provide you with a cost estimate before completing your request.
Your right to appeal
If we decline to take action regarding a request that you have submitted, we will inform you of our reason for doing so, and for Virginia, Colorado, and Connecticut residents, provide instructions for how to appeal the decision. If we decline to comply with a data subject rights request, residents of the above states will have the right to appeal our refusal within a reasonable period of time after receiving our decision. Within 60 days of the time provided by applicable U.S. state law, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, we will also provide you with an online mechanism, if available, or other method through which you may contact the your state’s regulatory authority to submit a complaint.
Our website and services are not directed at, or intended for use by, children under the age of 13. We do not sell the personal data of individuals that we know are less than 16 years old.
17 DATA PROTECTION PROVISIONS ABOUT THE APPLICATION AND USE OF THE FOLLOWING SERVICE PROVIDERS
Recann uses or has integrated (in the Services) the components of:
• BullHorn CRM – BullHorn CRM is used for customer management and helping match candidates with appropriate positions. The data will be stored securely and is protected by Privacy Shield protocols of the service provider. BullHorn is committed to protecting your data and the applicable data protection provisions of BullHorn CRM may be retrieved here: https://www.bullhorn.com/gdpr-commitment-statement/
• Microsoft 365 – Microsoft 365 is cloud-based productivity software used encompassing online services such as Outlook.com, OneDrive, Microsoft Teams. Data is store securely with Microsoft 365 and the protocols of the service provider complies with the EU-U.S., UK Extension to the EU-U.S., and Swiss-U.S. Data Privacy Frameworks, for more information please visit https://privacy.microsoft.com/en-gb/privacystatement
• Xero – is a cloud based accounting platform. The applicable data protection provisions of Xero may be retrieved here: https://www.xero.com/uk/legal/privacy/.
• Broadbean – Broadbean online recruitment software is used for job posting and distribution, CV database search, social referral, job alerts, and data analysis. The applicable data protection provisions of Broadbean may be retrieved here: http://info.broadbean.com/broadbean-gdpr.
• Lusha – Lusha is utilized by us to enrich social profiles and attribute contact details to social media profiles. We will occasionally copy details from Lusha to notify the data subject of relevant jobs. The applicable data protection provisions of Lusha may be retrieved here: https://www.lusha.co/gdpr.
• Hunter.io –Hunter.io or email hunter is utilized by us to verify correct email addresses against a pseudonymised and speculative email address verification process. The applicable data protection provisions of Hunter.io may be retrieved here: https://hunter.io/gdpr.
• Reed – Reed is an online job portal and recruitment service. We use Reed to post jobs, find candidates and match them to job opportunities for employers. Reed data storage policies can be found here: https://www.reed.co.uk/policies. We will often process data from Reed by copying contact information from the service and matching these to our current records or creating a new data subject record to match.
• CV Library – We use CV Library to post jobs, find candidates and match them to job opportunities for employers. CV Library’s data storage policies can be found here: https://www.cv-library.co.uk/gdpr-statement. We will often process data from CV Library by copying contact information from the service and matching these to our current records or creating a new data subject record to match candidates to jobs.
• Stepstone & its Subsidiaries – (CW Jobs, Total Jobs, JobSite, Mahiba) – We use CW Jobs, Total Jobs and JobSite to post jobs, find candidates and match them to job opportunities for employers. This group’s data storage policies can be found here: http://recruiters.cwjobs.co.uk/page/gdpr, https://www.totaljobs.com/privacy-policy, https://www.jobsite.co.uk/privacy We will often process data from this group of websites by copying contact information from the service and matching these to our current records or creating a new data subject record to match candidates to jobs.
• Monster Jobs – We use Monster to post jobs, find candidates and match them to job opportunities for employers. Monster’s data storage policies can be found here: http://inside.monster.co.uk/fullpolicy/inside2.aspx. We will often process data from this group of websites by copying contact information from the service and matching these to our current records or creating a new data subject record to match candidates to jobs.
• Indeed – We use Indeed to post jobs, find candidates and match them to job opportunities for employers. Indeed’s data storage policies can be found here: https://hrtechprivacy.com/brands/indeed#privacypolicy We will often process data from Indeed by copying contact information from the service and matching these to our current records or creating a new data subject record to match candidates to jobs.
• Cognism - The data we are using to contact you with has been sourced through Cognism using publicly available sources. Recann may have obtained some or all of your personal information about you from Cognism. For more details about the types of business-to-business information Cognism collects and shares with third parties, see this page on the Cognism website: https://www.cognism.com/b2b-data.
• Appollo.io - Apollo.io is a prospecting and sales automation tool. It provides users with access to a large database of verified contact information. This data can then be searched and transferred to established sequences. Recann may have used services provided by Appollo to contact you. To find out more about their services please visit https://www.apollo.io/privacy-policy.
• Zoominfo - The data we are using to contact you with has been sourced through Zoominfo.com using publicly available sources. ZoomInfo processes only business contact information in the EU: company, job title, work email address, work phone number, etc. It does not provide sensitive personal information of any kind. It simply provides the type of information that is typically found on a business card, an email signature block, or a public professional pro?le. To find out more visit https://www.zoominfo.com/about-zoominfo/privacy-policy.
• Selligence - Selligence may share your personal data with us to contact you. Selligence provides limited access of its database. We may use the information provided by Selligence to contact individuals in relation to recruiting activities or business opportunities. To find out more visit https://www.selligence.com/privacy-policy.
• Rocket Reach - We may use your information provided by Rocket Reach to contact you. RocketReach processes data in the USA and guarantees compliance with data protection regulations in the EU via [EU Standard Contractual Clauses] https://rocketreach.co/privacy https://rocketreach.co/gdpr
- GrowMeOrganic - We may use your information provided by GrowMeOrganic to contact you. GrowMeOrganic processes data in the USA and guarantees compliance with data protection regulations in the EU via [EU Standard Contractual Clauses] https://www.growmeorganic.com/privacy-policy/ https://www.growmeorganic.com/gdpr/
• Contactout - We may use your information provided by Contactout to contact you. To know more about the features of Contactout, visit https://contactout.com/ . Contactout’s privacy practises may be found at https://contactout.com/privacy_policy.
• SignalHire - SignalHire offers various services and tools designed specifically for recruiters, marketers, and HR specialists who are seeking to make contact with business professionals for employment or marketing purposes, or to obtain industry, market or competitor analysis. We may use your information to contact you. To know more about the privacy practises of SignalHire, visit https://www.signalhire.com/privacy.
• Google Analytics (with anonymization function) – Recann has integrated the component of Google Analytics in the Services (with the anonymizer function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behaviour of visitors to websites. A web analysis service gathers, among other things, information about the website from which a person originated. (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.
In addition, the data subject has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of the Services, as well as the processing of this data by Google and the chance to preclude any such. For this purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through JavaScript that any data and information about the visits of the website (Services) may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser extension was removed or disabled by the user or any person under their authority, it can be reinstalled or reactivated.
Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/.
• YouTube – Recann has integrated components of YouTube in the Services. YouTube is an Internet video portal that enables video publishers to set video clips and other users free of charge, which also provides free viewing, review and commenting on them.
Further information about YouTube may be obtained at https://www.youtube.com/yt/about/en/.
YouTube and Google will receive information through the YouTube component that the data subject has visited our website (Services) if the data subject at the time of the call to our Services is logged in on YouTube; this occurs regardless of whether the person clicks on a YouTube video or not. If the transmission of this information to YouTube and Google is not desired by the user, it can be prevented by logging out of their YouTube account before accessing our Services.
YouTube’s data protection provisions, available at https://www.google.com/intl/en/policies/privacy/, provide information about the collection, processing and use of personal data by YouTube and Google.
• LinkedIn – Recann has integrated components of LinkedIn on the website (Services). LinkedIn is a web-based social network that enables users with existing business contacts to connect and make new business contacts. We may use your information provided by LinkedIn to contact you. The applicable privacy policy for LinkedIn is available at https://www.linkedin.com/legal/privacy-policy.
• Solvex Solutions – A recruitment consultancy that has access to Recann’s database for sourcing and matching candidates to job opportunities. Solvex Solutions may also share candidate profiles sourced from third-party platforms like LinkedIn, which may include publicly available professional details such as job history, contact information, and skills. Solvex Solutions acts as a data processor when sharing these profiles, ensuring compliance with Recann’s data protection policies and applicable data protection laws.
Your data will be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein).
Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). If we do store or transfer data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between us and any third parties we engage and the use of the EU-approved Model Contractual Arrangements. If we intend at any time to transfer any of your data outside the EEA, we will always obtain your consent beforehand and we have put in place safeguards to protect your personal data.
19 Sharing of personal data with third-parties
In compliance with all local laws and regulations, your data may be shared for any of the following reasons:
• Individuals and companies that have information about your reference or application to work with Recann, including current, past, and potential employers, educational institutions, examination bodies, and employment and recruitment agencies.
• Tax, audit, or government bodies when requested by law.
• Third-party service providers who carry out work on our behalf, such as professional advisers, IT service providers, and outsourced IT and document storage providers with whom we have a processing agreement or similar protection in place.
• Potential employers to process your application for roles.
• Third parties for technical testing or clients that use online talent management systems.
• If relevant and with your prior active consent, we may share your data with companies that have relevant job openings for each job.
• We may contract with third parties to supply some services to you on your behalf. These may include payment processing, search engine facilities, advertising, and marketing. In every circumstance, your data will be encrypted and only contractors who have been thoroughly vetted will be able to see your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.
20 PERIOD FOR WHICH THE PERSONAL DATA WILL BE STORED
We will retain your personal data for as long as is necessary to fulfil the purpose for which we collected your personal data and any other permitted linked purpose and in compliance with our data retention policies. For example, we will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
Generally, we retain usage data for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our services, or we are legally obligated to retain this data for longer time periods.
If your personal data is used for more than one purpose, we will retain it until the purpose with the longest retention period expires; but we will stop using it for the purpose with a shorter retention period once that period expires. Our retention periods are also based on our business needs and good practice.
In cases where we act as a data processor, we hold the personal data for as long as we provide services to the customer or as long as necessary to fulfil the purpose for which it was initially collected and thereafter until such time as we delete the Customer’s account unless we need to preserve it for a longer period, for example, because of our obligations under tax laws or in connection with any anticipated litigation.
Your personal data may need to be retained in our backup systems and will only be deleted or overwritten at a later time. This may be the case even when you or a Supervisory Authority has validly asked us to delete your personal data or when we do not no longer have a legal basis for processing such personal data. Please note that our backups are protected.
21 Updates to Our Privacy Policy
We frequently update our Privacy Policy. If we make any significant changes, we may notify you by email or text message and/or ask you to review and sign a new Registration Form that includes a link to this Privacy Policy.
Updates will be posted on our website for your review, and if any major changes are made, we will display a notice of the revised Privacy Policy for 30 days on our website or Services homepage with a link back to this page.
You can print a copy of the entire Privacy Policy by using the keyboard shortcut Ctrl + P, or by going to the Print Page option in your browser.
22 Right to Lodge a Complaint with a Supervisory Authority
If the GDPR applies to our processing of your personal data, you have the right to lodge a complaint with a supervisory authority if you are not satisfied with how we process your personal data. Specifically, you can lodge a complaint in the Member State of the European Union of your habitual residence, place of work, or the alleged violation of the GDPR.
If you have any queries on any aspect of our Privacy Policy, please contact our Data Protection Team atprivacy@Recann.com
