Privacy Policy

Welcome to Candidly Limited's platform privacy policy.

Candidly Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you utilise the Candidly platform (“our platform”) and tell you about your privacy rights as well as how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary for further information regarding some of the terms used in this privacy policy.

1. Important Information and Who We Are

This privacy policy seeks to give you information regarding how Candidly Limited collects and processes your personal data through your use of our platform.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

Controller

Candidly Limited is the data controller and responsible for your personal data (collectively referred to as “Candidly”, “we”, “our”, or “us” in this privacy policy).

We are an online application provider and applicant tracking system (ATS) for assisting with your recruitment processes.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact Details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO as follows:

Full Name of Legal Entity: Candidly Limited

Email Address: hello@wearecandidly.com

Postal Address: 14b Thane Villas, London, England, N7 7PA

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO) – the UK regulator for data protection issues (www.ico.org.uk). However, we would appreciate the chance to address your concerns before you approach the ICO, so please do contact us at the first instance of an issue.

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 20th February 2022.

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 your relationship with us.

2. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data: includes first name, last name, username or similar identifier, marital status, title or position, date of birth, and gender.
• Contact Data: includes address, private and business email addresses, and telephone numbers.
• Eligibility Data: includes right to work information, citizenship, and criminal background checks.
• Technical Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our platform.
• Profile Data includes your username and password, your interests, preferences, feedback, and survey responses.
• Usage Data: includes information about how you use our platform.
• Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use, store, 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 is anonymised/pseudononymised and will not directly or indirectly reveal your identity. For example, we may aggregate your Professional Data to develop analytics with respect to a specific platform feature or component. 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.

If You Fail to Provide Personal Data

Where we need to collect personal data by law, or under our platform terms of use, and you fail to provide that data when requested, you may not be able to use our platform or receive related services and information. In this case, we may be required to restrict your access to our platform but we will notify you if this is the case at the time.

3. How Your Personal Data is Collected

We use different methods to collect data from and about you, including:

• Direct Interactions. You may give us your Identity and Contact Data by filling in forms and fields on our platform, and you may give us your Professional and Eligibility Data by uploading material to our platform. This includes personal data you provide when you:
  1. register to use our platform
  2. create an account for our platform;
  3. subscribe to our services or publications;
  4. request marketing information be sent to you;
  5. enter a competition, promotion, or survey; or
  6. provide us with feedback or contact us.
• Automated Technologies or Interactions. As you interact with our platform, we will automatically collect Technical Data about your equipment, preferences, and patterns.
• Third parties or Publicly Available Sources. We may receive personal data about you from various third parties and public sources as set out below:
  1. Professional Data from professional profiles available in the public domain (for example, LinkedIn, Twitter, or corporate website); and
  2. Identity and Contact Data from publicly available sources.

4. How We Use Your Personal Data

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

• Where we need to perform the contract (terms of use) we are about to enter into or have entered into 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 obligation.

Click here to learn more about the types of lawful bases that we will rely on to process your personal data.

Purposes For Which We Will Use Your Personal Data

We are an online application provider and applicant tracking system (ATS) for assisting with recruitment processes.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified our legitimate interests where appropriate.

Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis on which we are relying to process your personal data where more than one basis has been set out in the table below.

Marketing

We may use your Identity, Contact, Professional, Eligibility, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which additional services and offers may be relevant for you (we call this marketing).

You have the right to ask us not to process your personal data for marketing purposes. We will typically inform you (before collecting your personal data) if we intend to use your data for such purposes. We will obtain your explicit opt-in consent before we share your personal data with any third-party for marketing purposes.

You can exercise your right to accept or prevent such processing on our platform. You can also exercise the right at any time by contacting us at hello@wearecandidly.com.

Our platform may, from time to time, contain links to and from websites of our partner networks, advertisers, and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and we do not accept any responsibility or liability for these policies and practices. Please check these policies before you submit any personal data to such websites.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of Your Personal Data

We will disclose your personal data to third parties:

• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
• If we or substantially all of our assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets. If such an acquisition occurs, then the new owners may use your personal data in the same way as set out in this privacy policy.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Candidly, our clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

The lawful bases for third party processing of your personal data include:

• Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs;
• satisfaction of their contractual obligations to us as our data processor;
• for the purpose of a contract in place or in contemplation;
• to fulfil their legal obligations.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We will only use access to allow you to write and send Gmail messages and attachments from your Candidly account and read only messages from your Gmail account associated to messages sent from your Candidly account. We will not store or transfer this email data to any third party under any circumstances.

Candidly's use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

6. International Transfers

The personal data which we collect from you may be transferred to, and stored at, a destination outside of the UK or European Economic Area (“EEA”). Such personal data may be transferred to third parties outside of the UK or EEA for the purpose of our recruitment services and may also be processed by staff operating outside the UK or EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our recruitment services and the provision of support services. By submitting your personal data, you agree to this transfer, storage, and/or processing. Whenever we transfer your personal data outside of the UK or EEA, we will take all steps reasonably necessary to ensure that your data is treated securely in accordance with this privacy notice, which includes implementing at least one of the following safeguards:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use in the UK and EEA which give personal data the same protection it has in the UK and EEA.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our platform; any transmission is at your own risk.

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data in accordance with our instructions and they are subject to a duty of confidentiality.

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

8. Data Retention

For How Long Will We Use Your Personal Data?

We understand our legal duty to retain accurate data and only retain your personal data for as long as we require it for our legitimate business interests and that you are happy for us to do so. We may retain your personal data for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may also retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

We may archive and store part or all of your personal data, or retain it on our financial systems only. We may pseudonymise parts of your personal data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data in our platform, unless requested to do so.

We may anonymise your personal data (so that it can no longer be associated with you and becomes non-personal data) for archival and analytics purposes, and we may store, process, and use this non-personal data indefinitely without further notice to you.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

9. Cookies

Our site may use session and persistent cookies. The cookies placed by our servers are readable only by us, and cookies cannot access, read or modify any other data on your computer. We may use web beacons alone or in conjunction with cookies to compile information about your usage of our site and interaction with emails from us. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to our site, in order to improve our site and email communications.

Our site and the Subscription Services may contain links to other website including share and/or “like” buttons. These other website and services may set their own cookies on users' computers, collect data or solicit personal information. You should refer to their cookie and privacy policies to understand how your information may be collected and/or used.

PREFERENCE COOKIES

We use preference cookies to collect information about your choices and preferences, and to allow us to remember preferred settings and customize our site accordingly.

ANALYTICAL COOKIES

We also use analytics cookies to collect information about your use of our site, and to enable us to improve the way our site works. For example, analytics cookies show us which are the most frequently visited pages on our site, help us record any difficulties you have with our site, and show us whether our advertising is effective or not. This allows us to see the overall patterns of usage on our site, rather than the usage of a single person. We use the information to analyze the site traffic, but we do not use information to identify individuals.

CONTROLLING COOKIES

Most web browsers have a “help” menu where you can review how to prevent your browser from accepting new cookies, how to have your browser alert you when you receive a new cookie or how to fully disable cookies on your browser. You can learn more about cookies at sites like www.aboutcookies.org. If you use your browser settings to block all cookies, you may not be able to access all or parts of our site.

10. Your Legal Rights

In certain circumstances, you have rights under data protection laws in relation to your personal data which include 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:
  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful, but you do not want us to erase it.
  • 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.
  • 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 services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at data@wearecandidly.com.

No Fee Usually Required

You will not have to pay a fee to access your personal data (or to exercise any other right). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive, or, alternatively, we may refuse to comply with such a request.

Information Possibly Required From You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any other right). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Response Time Limit

We try to respond to all legitimate requests within one (1) month. Occasionally, it might take us longer than one (1) month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.