Ami Arroyo Privacy Policy  

Talentful privacy policy

  1. General
  2. Talentful Limited and its operating groups, subsidiaries, and affiliates (Talentful, we or us) is the Data Controller of the personal data that you provide to us or that we receive. Talentful is registered in England with company number 09683024.
  3. Talentful is committed to protecting and respecting your privacy. This notice sets out the basis on which any personal data we collect from you, or that you provide us, will be processed by us.
  4. Right to Object:
  5. You have a legal right to object at any time to:
  • use of your personal information for direct marketing purposes; and
  • processing of your personal information which is based on our legitimate interests, unless there are compelling legitimate ground for our continued processing.
  1. Who We Are and What We Do
  2. We are a recruitment agency that (i) provides onsite internal HR support and (ii) operates recruitment business. We collect personal data from the following types of people to allow us to undertake our business and to source candidates for our clients:
  • Prospective and placed candidates for permanent and contract roles
  • Prospective and live client contacts
  • Supplier contacts to support our services
  • Employees, consultants, temporary workers
  1. Types of Data We Collect
  2. In order to provide the best possible employment opportunities we need to process certain information.
  3. The information about you we may collect, hold and process is set out below:
  • name
  • contact details such as an address, email and telephone number
  • education details
  • employment history
  • immigration status
  • reference and background check
  • other relevant information you may choose to share
  1. Where appropriate, and in accordance with local laws and requirements, we may also collect information related to diversity, security clearance status or details of any criminal convictions.
  2. If you are a Talentful client, we need to collect and use information about you, or individuals at your organisation, in the course of providing you with our recruitment services. This can include finding candidates to fill your roles, providing you with internal recruitment services or notifying you of content published by Talentful which may be relevant to you.
  3. Talentful will also in accordance with data protection laws store information relating to previous dealings with us, including job applications, email and telephone communications, job interviews and placements.
  4. We collect a limited amount of data from the users of our website which we use to help us to improve your experience when using our website and to help us manage the services we provide. This includes information such as how you use our website, the most popular referrers and website responsiveness. You can read more about this in our Cookies Policy.
  5. For individuals in California, please refer to Talentful’s specific California Privacy Policy for what information we collect about job applicants and how we use and disclose it.
  6. We also receive personal information concerning candidates from customers that are used by Talentful to provide placement services. The personal information Talentful receives in this business to business transaction is used for this limited purpose and is subject to the data protections principles.
  7. Where We Obtain Your Information
  8. We may obtain candidate information from any number of locations:
  • When you register or apply for jobs
  • When you correspond with us by phone, email or otherwise
  • When you visit our website
  • When you register your CV on a job board and it matches certain criteria
  • When you apply for a role via a job board
  • When you are referred by a friend or colleague
  • Through your online profiles
  1. When we obtain your information from external sources such as LinkedIn, corporate websites and job boards we will contact you within a reasonable timeframe to ensure that our services are appropriate or relevant to you.
  2. There are two main ways in which we collect client data:
  • Directly from you
  • From third parties such as candidates, online search engines, online job boards, LinkedIn and networking.
  1. Data Retention
  2. The length of time we will hold or store your personal information for will depend on the services we perform for you and for how long you require these. As we often support candidates with placements over an extended period the purpose for which we retain data is often an ongoing purpose. We conduct regular data-cleansing and updating exercises with our candidates to ensure that (i) the data that we hold is accurate, (ii) we are not holding data for too long and (iii) the data remains relevant for the purposes for which it was collected.
  3. We will consider there to be meaningful contact with you if you submit your updated CV onto our website, apply for jobs or we receive an updated CV from a job board. We will also consider it meaningful contact if you communicate with us about potential roles, either by verbal or written communication or engage with any of our marketing communications.
  4. Under new data protection regulations (GDPR), we are required to keep the data we hold accurate and, where necessary, up to date. As such, we will make an effort to regularly communicate with you to ensure your data is up to date and accurate.
  5. We endeavour to permanently erase your personal data on expiration of the retention period or where we receive a valid request from you to do so.
    For a list of all data categories and retention periods, please contact     data@talentful.com
  6. Legal Basis for Processing
  7. Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.
  8. We will rely on contractual provisions if there is a legal document between the parties.
  9. We will rely on legal obligation if we are legally required to hold information on to you to fulfil our legal obligations.
  10. We will, in some circumstances, rely on consent for particular uses of your data and you will be asked for your express consent, if legally required. Examples of when consent may be the lawful basis for processing include permission to introduce you to a third party.
  11. Legitimate Interests
  12. At Talentful, we take your privacy seriously and will only use your personal information for administration purposes and to provide our recruitment services. The information we have collected is used to provide our services to you in our capacity as an employment business, agency or onsite recruitment provider to find you suitable work whether on a temporary or permanent basis based on your requirements.
  13. We think it’s reasonable to expect that, if you are looking for employment or have posted your professional CV information on a job board or professional networking site, you recognise that it is fair to collect that public information and otherwise use your personal data to provide our recruitment services, use that to approach you as an onsite recruiter, to share that information with prospective employers and assess your skills against our live vacancies. During the job offer process, your potential employer may also want to confirm your references, qualifications and criminal record which we will ensure is in accordance with the laws and regulations.
  14. We therefore think it’s reasonable for us to process your data and to contact you in order to propose relevant roles or available opportunities.
  15. We may also need to use your data for our internal administrative activities.
  16. Data Storage and Processing
  17. All of the personal data we hold about you will be processed consistent with EU data protection legislation and, in particular, the GDPR. We take all reasonable steps to ensure that your personal data is processed securely and prevent unauthorised access to, and misuse of your personal data. For more information, please see our security policy.
  18. Data Sharing
  19. As required under GDPR, we will only share your information with the particular client which made the approach or, to the extent appropriate, with prospective employers.
  20. Unless you specify otherwise, we may also share your information with any of our group companies and associated third parties such as our service providers where we feel this will help us to provide you with the best possible service and we have the appropriate processing agreement in place.
  21. Onsite Clients
  22. We will obtain and control your information with our clients where we are operating or acting as an internal onsite HR support function.
  23. Trusted Third Parties
  24. We will share your personal information and, where necessary, your sensitive personal information with trusted third parties where we have retained them to provide services that you or our clients have requested, such as:
  • employment reference checking
  • qualification checking
  • criminal reference checking
  • verification of details you have provided from third party sources
  • psychometric evaluations or skills tests
  1. We will also share your personal information with third parties who perform functions on our behalf and provide services:
  • professional advisors
  • data analytics providers
  • IT consultants carrying out testing and development work on our business technology systems
  • research and mailing houses
  • function co-ordinators
  1. We require minimum standards of confidentiality and data protection from such third parties. To the extent that any personal information is provided to third parties outside the EEA, or who will access the information from outside the EEA, we will ensure that approved safeguards are in place, such as the approved Model Clauses or the EU/US Privacy Shield.
  2. Your Rights in Respect to Your Information
  3. You have certain rights in relation to personal information we hold about you. Details of these rights and how to exercise them are set out below. We will require evidence of your identity before we are able to act on your request.
  4. You have the right at any time to ask us for a copy of the personal information about you that we hold. Where we have good reason, and if the GDPR permits, we can refuse your request for a copy of your personal information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.
  5. Right of Correction or Completion
  6. If personal information we hold about you is not accurate, out of date or incomplete, you have a right to have the data rectified, updated or completed. You can let us know by contacting us contacting us at data@talentful.com.
  7. Right of Erasure
  8. In certain circumstances, you have the right to request that personal information we hold about you is erased and there are no other legal grounds on which we may process the information.
  9. Right to Object to or Restrict Processing
  10. In certain circumstances, you have the right to object to our processing of your personal information by contacting us at data@talentful.com. For example, if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests. You also have the right to object to use of your personal information for direct marketing purposes.
  11. You may also have the right to restrict our use of your personal information, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy.
  12. Right of Data Portability
  13. In certain instances, you have a right to receive any personal information that we hold about you in a structured, commonly used and machine-readable format. You can ask us to transmit that information to you or directly to a third-party organisation.
  14. The above right exists only in respect of personal information that:
  • you have provided to us previously; and
  • is processed by us using automated means.
  1. Please note we are not able to guarantee technical compatibility with a third party organisation’s systems and, in certain circumstances, we may be unable to comply with requests that relate to personal information of others without their consent.
  2. You can exercise any of the above rights by contacting us using any of the methods identified in this Privacy Notice.
  3. Please be aware that most of the above rights are subject to limitations and exceptions. We will provide reasons if we are unable to comply with any request for the exercise of your rights.
  4. Data Subject Access Requests
  5. You may ask us to confirm what information we hold about you at any time, and request us to modify, update or delete such information. If you wish to access your data at any time, there will be no administration charge and the request will be fulfilled as set out in the relevant data protection legislation appropriate to the jurisdiction. To make such a request, please email data@talentful.com.
  6. Changes to our Privacy Notice
  7. Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy notice.
  8. Regulatory and Law Enforcement Agencies
  9. In the event that we receive a request from a regulatory body or law enforcement agency and, if permitted under GDPR or other applicable laws, we may disclose certain personal information to such bodies or agencies.
  10. Concerns
  11. If you have a concern about the way we are collecting or using your personal data, you should raise your concern with us in the first instance or directly to Information Commissioners Office at https://ico.org.uk/make-a-complaint.
  12. Contact
  13. Please address any questions, comments and requests regarding our data processing practices to data@talentful.com.


Introduction

This Privacy Policy outlines Ami Arroyo (" we ", " our " or " the Company ") practices with respect to information collected from users who access our website at https://www.amiarroyo.com (" Site "), or otherwise share personal information with us (collectively: " Users "). 

Grounds for data collection 

Processing of your personal information (meaning, any information which may potentially allow your identification with reasonable means; hereinafter " Personal Information ") [add explanation regarding the legal grounds for processing personal information, such as:] is necessary for the performance of our contractual obligations towards you and providing you with our services, to protect our legitimate interests and for compliance with legal and financial regulatory obligations to which we are subject.

When you use the Site, you consent to the collection, storage, use, disclosure and other uses of your Personal Information as described in this Privacy Policy.

We encourage our Users to carefully read the Privacy Policy and use it to make informed decisions. 

What information we collect?

We collect two types of data and information from Users. 

The first type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the Site (“ Non-personal Information ”). We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our Site. We may also collect information on your activity on the Site (e.g. pages viewed, online browsing, clicks, actions, etc.).

The second type of information Personal Information which is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual. Such information includes:
  • Device Information: We collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Site.
  • [add types of personal information collected, and respective explanations, such as:]
  • Registration information: When you register to our Site you will be asked to provide us certain details such as: full name; e-mail or physical address, and other information.  
  • …
  • …

How do we receive information about you?

We receive your Personal Information from various sources:
  • When you voluntarily provide us your personal details in order to register on our Site;
  • When you use or access our Site in connection with your use of our services;
  • From third party providers, services and public registers (for example, traffic analytics vendors).

What information we collect?

We do not rent, sell, or share Users’ information with third parties except as described in this Privacy Policy.

We may use the information for the following:
  • [ add types of detailed uses, such as:]
  • Communicating with you – sending you notices regarding our services, providing you with technical information and responding to any customer service issue you may have;
  • To communicate with you and to keep you informed of our latest updates and services;
  • To serve you advertisements when you use our Site (see more under "Advertisements"); 
  • To market our websites and products (see more under "Marketing"); 
  • Conducting statistical and analytical purposes, intended to improve the Site.
  • …
In addition to the different uses listed above, we may transfer or disclose Personal Information to our subsidiaries, affiliated companies and subcontractors.

In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our trusted third party providers, who may be located in different jurisdictions across the world, for any of the following purposes: 
  • Hosting and operating our Site;
  • [Add and amend relevant types of third parties, such as:]
  • Providing you with our services, including providing a personalized display of our Site;
  • Storing and processing such information on our behalf; 
  • Serving you with advertisements and assist us in evaluating the success of our advertising campaigns and help us retarget any of our users;
  • Providing you with marketing offers and promotional materials related to our Site and services; 
  • Performing research, technical diagnostics or analytics;
We may also disclose information if we have good faith to believe that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including our Agreement), including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.

User Rights

You may request to: 
  1. Receive confirmation as to whether or not personal information concerning you is being processed, and access your stored personal information, together with supplementary information. 
  2. Receive a copy of personal information you directly volunteer to us in a structured, commonly used and machine-readable format. 
  3. Request rectification of your personal information that is in our control.
  4. Request erasure of your personal information. 
  5. Object to the processing of personal information by us. 
  6. Request to restrict processing of your personal information by us.
  7. Lodge a complaint with a supervisory authority.

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. 

If you wish to exercise any of the aforementioned rights, or receive more information, please contact our Data Protection Officer (“DPO”) using the details provided below:
[add contacts details] .

Retention

We will retain your personal information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, account opening documents, communications and anything else as required by applicable laws and regulations. 

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

Cookies

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services. 

A "cookie" is a small piece of information that a website assign to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services. 

The Site uses the following types of cookies:

a. 'session cookies' which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed; 

b. 'persistent cookies ' which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in; 

c. 'third party cookies' which are set by other online services who run content on the page you are viewing, for example by third party analytics companies who monitor and analyze our web access.

Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.

We also use a tool called “Google Analytics” to collect information about your use of the Site. Google Analytics collects information such as how often users access the Site, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Site and services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

Third party collection of information

Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose information to. 

This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals whom we do not employ or manage, including any of the third parties which we may disclose information as set forth in this Privacy Policy. 

How do we safeguard your information?

We take great care in implementing and maintaining the security of the Site and your information. [ explain about your security practices, such as: we employ industry standard procedures and policies to ensure the safety of the information we collect and retain, and prevent unauthorized use of any such information, and we require any third party to comply with similar security requirements, in accordance with this Privacy Policy] . Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Site, and we make no warranty, express, implied or otherwise, that we will prevent such access.

Transfer of data outside the EEA 

Please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.

Advertisements

  We may use a third-party advertising technology to serve advertisements when you access the Site. This technology uses your information with regards to your use of the Services to serve advertisements to you (e.g., by placing third-party cookies on your web browser). 

[Add information regarding opt-out options from personalized advertisements, such as:] You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative ("NAI") and the Digital Advertising Alliance ("DAA"). For more information about this practice by NAI and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: http://optout.networkadvertising.org/#!/ and http://optout.aboutads.info/#!/.

Marketing

We may use your Personal Information, such as your name, email address, telephone number, etc. ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning our services, which we believe may interest you.  

Out of respect to your right to privacy we provide you within such marketing materials with means to decline receiving further marketing offers from us. If you unsubscribe we will remove your email address or telephone number from our marketing distribution lists. 

Please note that even if you have unsubscribed from receiving marketing emails from us, we may send you other types of important e-mail communications without offering you the opportunity to opt out of receiving them. These may include customer service announcements or administrative notices.

Corporate transaction

We may share information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy.

Minors

We understand the importance of protecting children’s privacy, especially in an online environment. The Site is not designed for or directed at children. Under no circumstances shall we allow use of our services by minors without prior consent or authorization by a parent or legal guardian. We do not knowingly collect Personal Information from minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at [add applicable email address] .

Updates or amendments to this Privacy Policy

We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy policy. The last revision will be reflected in the "Last modified" section. Your continued use of the Platform, following the notification of such amendments on our website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

How to contact us

If you have any general questions about the Site or the information we collect about you and how we use it, you can contact us at [add applicable email address] .

Please complete the details of the company

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