Privacy Policy

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).

1. Who we are

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

2. Data we collect about you

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:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, and social media accounts.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
• Technical Data includes information about how you use our website, internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device model and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Employment Data includes your current and past employment experience, qualifications, skills, interests and any other information disclosed by you in relation to an application for a role available on the Snap.hr platform or within Snap.hr.

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.

3. How is your personal data collected?

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:

• request our services or book a class;
• meet with one of our employees or consultants;
• participate in a cooking class or event which we have organised;
• complete a form on our website requesting us to contact you;
• subscribe to our publications or newsletter;
• request information about our services or other information or materials to be sent to you;
• respond to a survey;
• submit an application for a role within Snap.hr; or
• make a complaint or give us some feedback.

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:

• Technical Data from analytics providers or search information providers; and
• Employment, Identity and Contact Data from third party recruitment agencies or your previous employers.

4. How we use your personal data

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:

• Where we need to perform the contract 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 or regulatory obligation.

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.

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.

5. How we may share your personal data

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:

• Our third-party service providers who perform functions on our behalf in connection with the operation of our business such as applicant tracking systems, recruitment agencies, IT service providers and system administrators, third parties who host, store and manage data or provide programming or technical support, deliver our services, conduct reference checks on candidates on our behalf etc.
• Our professional advisers including lawyers, bankers, auditors and who provide consultancy, banking, legal, insurance and accounting services.
• Our third-party analytics partners to analyse website traffic and understand customer needs and trends or our third-party marketing service providers to help us to communicate with.
• Third parties if we are required to do so by law, or if we believe that such action is necessary to: (a) fulfil a government, or regulatory authority request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our websites or customers.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

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:

• conform to the edicts of the law or comply with legal process served on Snap.hr or the site;
• protect and defend the rights or property of Snap.hr; and
• act under exigent circumstances to protect the personal safety of users of Snap.hr, or the public.

6. International transfers

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 will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

7. Security of your personal data

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.

8. Data retention

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.

9. Your legal rights

You have the right to:

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

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

Schedule 1

List of subprocessors:

• Intercom
• Salesforce
• Amazon Web Services
• Google Cloud
• Algolia
• Workable
• Mailchimp
• Fullstory
• Segment
• Greenhouse
• Candu
• Google Maps API(s)