Protecting your personal data is our priority. This Privacy Policy tells you the types of information we collect about you when you visit our website or use our services, how we use that information, and when we may share your information. By using the Snap.hr website or services, you consent to the data practices described in this Privacy Policy. If you do not agree with any part of this Privacy Policy, then we cannot make our website or services available to you and you should stop accessing and using them. This Privacy Policy may change from time to time so please check this policy regularly.
This website and our products and services are not intended for children under the age of 16 and we do not knowingly collect data relating to children under the age of 16.
This Privacy Policy is provided in accordance with Snap.hr’s obligations under applicable privacy and data protection law, including the Data Protection Act 2018 and Regulation (EU) 2016/679 (GDPR) (Applicable Data Protection Law). Definitions in this Privacy Policy shall be as set out in the Applicable Data Protection Law. For the purposes of this Privacy Policy, the term “personal data” means any information which identifies you or which allows you to be identified when combined with other information. It does not include data where the identity has been removed (anonymous data).
This Privacy Policy applies to the website and services of Snap HR Limited ( Snap.hr, we us or our ), registered in England with number 06797548 and with its registered office at Suite 23, 5th Floor 63 - 66 Hatton Garden, London, England, EC1N 8LE. Our ICO registration reference number is ZA544307.
Depending on the circumstances, Snap.hr may be a data controller (for example, when collecting personal data from candidates to send them information regarding suitable job openings and marketing information and collecting personal data from our staff and consultants) and data controller-in-common (for example, when processing personal data on the instructions of a customer, employer, or recruiter where they are a data controller). In cases where you are a data controller, you will ensure that you are lawfully permitted to transfer to us any such personal data and we will only use such data to provide the services or as necessary to comply with Applicable Data Protection Law.
If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the details set out below:
Attn: Privacy Manager
Snap.hr
Suite 23, 5th Floor 63 - 66 Hatton Garden,
London, England, EC1N 8LE
Email:
support@snap.hr
We may collect and use your personal data, to operate our website and to deliver the services you have requested. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. 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 use different methods to collect data from and about you including through:
Direct interactions. You may give us your name, email address and contact details in person, or by filling in forms on our website or by corresponding with us by post, phone, email, social media or otherwise. This includes personal data you provide when you:
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, IP address, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy https://snap.hr/cookies for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
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 what our legitimate interests are where appropriate.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
---|---|---|
To register you as a new or prospective customer |
(a) Identity
(b) Contact |
(a) Performance of a contract with you
(b) Necessary for our legitimate interest (for running our business and to provide our services) |
To process and deliver
services to you including:
(a) Matching you as a candidate for a suitable role with a customer or employer (b) Manage payments, fees and charges (c) Collect and recover money owed to us | (a) Identity
(b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (f) Employment | (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us) |
To manage our relationship
with you which may include
(a) Notifying you about changes to our terms of business or privacy policy (b) Asking you for a testimonial or feedback or to take a survey | (a) Identity
(b) Contact (c) Profile (d) Technical (e) Marketing and Communications | (a) Performance of a contract with
you
(b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity
(b) Contact (c) Technical | (a) Necessary for our legitimate
interests (for running our
business, provision of
administration and IT services,
network security, to prevent fraud
and in the context of a business
reorganisation or group
restructuring exercise)
(b) Necessary to comply with a legal obligation |
To deliver relevant website content and measure or understand the effectiveness of the such content | (a) Identity
(b) Contact (c) Profile (d) Technical (e) Marketing and Communications | Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy) |
To use data analytics to improve our website, services (including candidate matching), marketing and customer relationships and experiences | (a) Technical
(b) Profile (c) Employment | (a) Necessary for our legitimate interests (to define types of customers for our services, match candidates to roles, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about goods, services or a role that may be of interest to you | (a) Identity
(b) Contact (c) Technical (d) Profile (e) Employment | Necessary for our legitimate interests (to develop our products/services and grow our business) |
Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you do not provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service you have with us but we will notify you of this at the time.
Newsletters and marketing communications You will receive newsletters, legal updates, news and information about our services and/or other marketing communications from us if you have requested information from us, purchased our services or if you provided us with your details when you registered with us and, in each case, you have not opted out of receiving that information. We may also inform you of products or services available from our carefully selected partners. We may also contact you via surveys to conduct research about your opinion of our websites, services or future services.
We do not sell, rent or lease or provide in any other way our customer lists to third parties.
Opt-out or unsubscribe We respect your privacy and give you an opportunity to opt-out of receiving announcements of certain information. Users may opt-out of receiving any or all communications from us by contacting us (as set out above) or selecting and following the “Unsubscribe” option in any communication from us.
Cookies Our website uses cookies and similar technologies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our website. You can set your browser to refuse all or some browser cookies. For more information about the cookies we use, please go to https://snap.hr/cookies.
Third-party links and services Our website may include links to third-party websites and/or plug-ins. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites or services and are not responsible for their privacy practices or privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:
We require all third parties to respect the security and confidentiality 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. A list of third party services providers that act as sub-processors of your personal data are available in Schedule 1 below.
We will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to:
Our third-party service providers may be based outside the EEA and when they are 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 or UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
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, consultants, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have 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.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements. For example, we will generally keep your personal data for the longer of six years from the date of the last interaction with you or until the applicable statutory limitations period has expired. We will also keep any emails on our mailing list until we no longer have a legitimate interest to do so. We regularly review the personal data we hold taking into account the lawful purpose for which we hold it and any data that is deemed no-longer relevant or required is deleted.
You have the right to:
No fee usually required
You will not have to pay a fee to access your personal data (or to
exercise any of the other rights). However, we may charge a reasonable fee if your request is
clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request
in these circumstances.
What we may need 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 of your other rights). 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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally
it may take us longer than a 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.
Effective as of 11th January 2019
List of subprocessors: