Candidate Privacy Policy – Aug 13 2020

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As of today's date, SmartRecruiters has not received a request for customer data from the United States Government.

Last reviewed: August 13, 2020

California residents please also see CCPA Privacy Notice.

What Personal Data (“Your Personal Data”) are we Collecting?

Data that you (“You”, “Your”) input during the application process or job alert creation (contact information, experience and education, attachments, screening questions answers).
Your IP Address.
Your login information (email address and encrypted password) for your Candidate Portal.
Cookies, which allow us to know how our services are accessed and used

For more details, click here.

What is the Purpose of Collecting Your Personal Data?

Help You manage Your job opportunities within the Candidate Portal: when You apply to one of our Customers, You have access to a Candidate Portal, where You can find Your profile information and applications information.
Receive jobs suggestions available from and through SmartRecruiters.
Conduct surveys: SmartRecruiters may also contact You via surveys to conduct research about Your opinion of current or future SmartRecruiters functionalities and user experience.
Improve and develop services and products: SmartRecruiters may use the Personal Data to improve and develop its services and products to the extent this is necessary.

In this case, we are the data controller.

Please remind : when You apply to one of our Customers’ jobs, our Customer (the recruiter or hiring manager) can consider You for any job opportunities they have and can use any SmartRecruiters tools to track, manage and make a decision. In this case, the Customer is the data controller and is responsible for the process of Your Personal Data and SmartRecruiters is the data processor processing the data on behalf of the Customer.

SmartRecruiters is not a headhunting company. We only provide a talent acquisition technology to our customers and the services to You as mentioned above.

Because SmartRecruiters and its affiliates (“SmartRecruiters”) offer You real choice and control over how You use Your Personal Data, and wants to build trust and engagement with You, consent is the legitimate basis for processing Your Personal Data.

You can withdraw your consent at any time by deleting your Candidate Portal account.

How Your Personal Data for Candidate Portal will be used

You can set up a personal account (“Candidate Portal”) which allows You to manage Your job opportunities and track your different applications of several Customers.
In Your Candidate Portal, which is accessible on https://my.smartrecruiters.com/, You may register through the email you received after applying, or if your consent was requested. This is operated by SmartRecruiters under its own responsibility. The registration requires your email address and a password.
Your profile will be made available and visible to the Customer to which you applied. You will receive job alerts from the Customers to which You applied.
In order to provide world-class services to You and the Customer, SmartRecruiters uses third-party providers to help perform statistical analysis, technical support and data hosting. To learn more, click here
Your application information will be collected by SmartRecruiters and be made available to You through the Candidate Portal.
You can find more details here. SmartRecruiters will never sell, rent, or lease the collected Personal Data.

How can You self-manage Your Personal Data?

Candidate Portal: You can see all Your profile and applications You’ve made
- Right to rectification: You can modify Your profile by going to the “My SmartProfile” section
- Right to be forgotten: You can withdraw and delete Your profile at each company You applied for:
  Please note that SmartRecruiters will transmit your request to the Customers You applied. In some cases, they may decide to keep your application data in compliance with their own legal obligations. To find more about these obligations, we encourage you to contact them directly. Contact information should be found in each company’s privacy policy linked at the bottom of your application or via their corporate website.
- Right to data portability: You can export Your profile in a machine readable format
- Right to object to processing: You can decide whether or not you wish to create a Candidate Portal and to delete it as mentioned above. You will still be able to apply to the job of Your choice without creating a Candidate Portal.
- Right to restriction of processing: Your Personal Data will be used solely for the purposes mentioned above and You can decide whether or not to create a Candidate Portal .You will still be able to apply to the job of Your choice without creating a Candidate Portal.
If You have any questions on how Your Personal Data is used or how You can self-manage Your Personal Data, feel free to contact

Use of Your Personal Data

Help You manage Your job opportunities within the Candidate Portal: when You apply to one of our Customers, You have access to a Candidate Portal, where You can find Your profile information and applications information.
Receive jobs suggestions available from and through SmartRecruiters.
Conduct surveys: SmartRecruiters may also contact You via surveys to conduct research about Your opinion of current or future SmartRecruiters functionalities and user experience.
Improve and develop services and products: SmartRecruiters may use the Personal Data to improve and develop its services and products to the extent this is necessary.

In this case, we are the data controller.

SmartRecruiters does not sell, rent or lease the collected Personal Data to third parties.

SmartRecruiters may share Your Personal Data with trusted partners in order to perform usage statistical analysis, customer support, technical operations and provide data hosting services. Our trusted partners are prohibited from using Your Personal Data except to provide these services to SmartRecruiters, and they are required to maintain the confidentiality of Your Personal Data. For more information, please click here.

Tracking Cookies

Please visit https://www.smartrecruiters.com/legal/cookie-policy/ for all cookie information as it relates to SmartRecruiters.

Retention of Your Personal Data

SmartRecruiters will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy.

GDPR Compliance

SmartRecruiters is committed to full compliance with the GDPR, including GDPR Article 13. Below is where we comply with Article 13 in this policy:

GDPR Article 13 Section 1

Section 1(a): See “Data Protection Questions” section below for the email to contact SmartRecruiters, the name of the controller, and SmartRecruiters address.
Section 1(b): See “Data Protection Questions” section below for the email of our data protection officer.
Section 1(c): See section “What is the purpose of collecting your personal data?” for the purposes SmartRecruiters collects personal data as well as the legal basis.
Section 1(d): This section is not applicable to SmartRecruiters because we process personal data based on consent.
Section 1(e): See “Onward Transfer” section for the categories of recipients of personal data.
Section 1(f): See “Onward Transfer” section for third country and international organization transfers, and our transfer mechanism in accordance with Article 46(2)(c).

GDPR Article 13 Section 2

Section 2(a): See the “How Can You Self-Manage Your Personal Data” section for how SmartRecruiters determines the criteria used to determine how long we retain personal data.
Section 2(b): See the “How Can You Self-Manage Your Personal Data” section for the right of a data subject to access, rectify, erase, or move personal data.
Section 2(c): See the “How Can You Self-Manage Your Personal Data” section for the right to withdraw consent.
Section 2(d): See “Data Protection Questions” section for the notice of the right to lodge a complaint with a supervisory authority.
Section 2(e): This is not applicable to SmartRecruiters.
Section 2(f): SmartRecruiters does not make automated profiling decisions.

Onward Transfer

SmartRecruiters uses a limited number of third-party providers in the US and in Europe to help to perform usage statistical analysis, customer support and technical operations and provide data hosting services.

Our Sub-processors for the Candidate Portal (i.e. your personal account with SmartRecruiters) are:

SmartRecruiters (SPOLKA AKCYJNA) Oddzial w Polsce (Poland): our branch in Poland is used for operation, maintenance, support and testing of the Candidate Portal and our platform;
Amazon Web Services, Inc. is used for hosting of the data. Hosting location is the cluster AWS Germany.
SendGrid, Inc. (US) is used to power the sending and receiving of emails from Your Candidate Portal.
Textkernel B.V. (The Netherlands) is used to parse the Candidate’s CV and documents and parse the data into the database field.
Google Analytics by Google LLC (US) is used to gather behavioral analytics on how candidates use the My SmartRecruiters Candidate Portal. SmartRecruiters will not use the data to identify individual users and will not merge the data with other data to identify individual users.
Hotjar LTD (Malta) is used to gather behavioral analytics on how candidates use the My SmartRecruiters Candidate Portal, NPS and surveys answers. SmartRecruiters will not use the data to identify individual users and will not merge the data with other data to identify individual users.

For Your complete information, when You apply to one of our Customers’ jobs, SmartRecruiters as data processor uses the following third-party providers for the services provided to our Customers:

SmartRecruiters (SPOLKA AKCYJNA) Oddzial w Polsce (Poland): our branch in Poland is used for operation, maintenance, support and testing of our talent acquisition platform;
Amazon Web Services, Inc. is used for hosting of the data. Hosting location is the cluster AWS Germany.
SendGrid, Inc. (US) is used to power the sending and receiving of emails from our talent acquisition platform to You and our Customer.
Textkernel B.V. (The Netherlands) is used to parse the Candidate’s CV and documents and parse the data into the database field.
Jitterbit, Inc. (US, service optional) is the cloud connector hosted in our hosting location in Germany and used to host and maintain any custom integrations between Customer’s system and SmartRecruiters platform.
ClickBoarding, LLC (US, service optional) is used by our Customers subscribing to the onboarding add-on.
Google Analytics by Google LLC (US) is used to gather behavioral analytics on how candidates apply to the customers’ job offers. SmartRecruiters will not use the data to identify individual users and will not merge the data with other data to identify individual users.

SmartRecruiters shall remain responsible in case of onward transfers to third parties.

SmartRecruiters shares the Personal Data with these third-party providers to support SmartRecruiters’ Services only. Any other use of the Personal Data by third-party providers is prohibited.

SmartRecruiters ensures that all personal data is handled, processed, transferred and stored in accordance with relevant EU data protection law, and that adequate safeguards and procedures providing protection to Users’ personal data are in place.

All third-party providers receiving Personal Data from the European Union, the United Kingdom and/or Switzerland agree to (i) process the Personal Data only to the extent required by SmartRecruiters’ Services and in accordance with SmartRecruiters’ instructions and (ii) comply with the applicable data protection laws for transfer and processing of Personal Data and (iii) provide adequate technical and organization measures to protect the Personal Data.

To this end, we use the European Standard Contract clauses (http://ec.europa.eu/justice/data-protection/international-transfers/index_en.htm) with our sub processors in order to guarantee the privacy and the security of Your Personal Data.

When You submit Your application, You agree to this Privacy Policy and, in particular, You expressly agree to the transfer of Your Personal Data for the purposes described in that Privacy Policy.

Security of Your Personal Data

SmartRecruiters is ISO 27001 certified.

SmartRecruiters uses industry-standard technologies when transferring and receiving consumer data exchanged between SmartRecruiters and third parties to help ensure its security. SmartRecruiters’ website has security measures in place to protect the loss, misuse and alteration of information.

Personal Data may be hosted on servers maintained by Amazon Web Services and subject to their security safeguards, which are continuously audited, with certifications from accreditation bodies across geographies and verticals. You can read more about Amazon Web Services’ security and compliance at https://aws.amazon.com/compliance/.

Children Under Thirteen

SmartRecruiters does not knowingly collect Personal Data from children under the age of thirteen. If You are under the age of thirteen, You must ask Your parent or guardian for permission to use smartrecruiters.com. If a child under 13 submits Personal Data to Company and we learn that the Personal Data is the information of a child under 13, we will attempt to delete the information as soon as possible. If You believe that we might have any Personal Data from a child under 13, please contact us at

Changes to our Privacy Policy

We reserve the right to change this Privacy Policy and our Terms of Use at any time. We will notify You of significant changes to our Privacy Policy by sending a notice to the primary email address specified in Your account or by placing a prominent notice on our site. Significant changes will go into effect following such notification. Non-material changes or clarifications will take effect immediately. We encourage You to check our site and this Privacy Policy for updates.

Disclosure of Your Personal Data

SmartRecruiters may disclose Your Personal Data, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on SmartRecruiters or the site; (b) protect and defend the rights or property of SmartRecruiters; and, (c) act under exigent circumstances to protect the personal safety of users of SmartRecruiters, or the public.

Inquiries – How to Contact Us ?

If You have any queries related to one of Your applications for our Customer, please contact them directly. You will find the Customer’s contact showed in the Candidate Portal.

Data Protection Questions

If You have any further queries, please send an email to our Data Protection Officer at: .

SmartRecruiters will respond in a timely manner.

In case of unresolved privacy or data use concern, You have the right to lodge a complaint with Your data protection supervisory authority.

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SmartRecruiters, Inc.
225 Bush Street
Suite #300
San Francisco CA 94104
USA