OUR COMMITMENT TO PROTECT YOUR PRIVACY
At Joveo, we believe that the Internet is a better place when privacy of the users is respected by websites and businesses. At the same time, we also know that the web is not a ‘one size fits all’ ecosystem and that websites do require collecting some personal information from users so as to create a unique and personalized experience. These principles are close to our heart which is why we promise that if we collect any information from You, it’s because we want to provide You with a superior experience using Joveo’s Site and Services. As explained in detail further below, we recognize that just because You share information with us doesn’t mean You want to share it with the rest of the world. That’s why it is our priority to protect any information You give us. It’s our goal to make Your experience with the Site and Services both rewarding and safe.
COMPLIANCE WITH PRIVACY SHIELD
The Federal Trade Commission has jurisdiction over Joveo’s compliance with the Privacy Shield. Joveo is subject to the investigatory and enforcement powers of the FTC (Federal Trade Commission).
Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to You in the United States. Upon request, we will provide You with access to the personal information that we hold about You. You may also correct, amend, or delete the personal information we hold about You. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to firstname.lastname@example.org. If requested to remove data, we will respond within a reasonable timeframe.
We will provide an individual opt-out choice, or opt-in for sensitive data, before we share Your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of Your personal information, please submit a written request to email@example.com.
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Joveo’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Joveo remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless Joveo proves that it is not responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, Joveo commits to resolve complaints about Your privacy and our collection or use of Your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact Joveo at: firstname.lastname@example.org
Joveo has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If You do not receive timely acknowledgment of Your complaint, or if Your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to You.
If Your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, You may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
Joveo acknowledges and respects the judgment of the Court of Justice of the European Union as on July 16, 2020 as well as the opinion of the Federal Data Protection and Information Commissioner (FDPIC) of Switzerland as on September 08, 2020 regarding the inadequacy of the protection provided under the EU-US Privacy Shield Framework for data transfers from EU and Switzerland to the United States. In furtherance of the same, Joveo agrees and accepts to undertake the following measures including without limitation as additional safeguards for protection of the data :
• maintain a current certification and privacy notice,
• promptly respond to complaints and maintain a free and independent dispute resolution mechanism for EU consumers, and
• continue to handle all data already received under Privacy Shield in accordance with the Privacy Shield Principles, including data transferred to third parties.
I. WHAT IS JOVEO INC
Joveo Inc is an advertising technology platform with its registered office in San Francisco. Joveo runs a technology buying platform for digital media. The Joveo technology allows our customers to buy ad space on websites, mobile apps, video players, and other devices and allows for the use of proprietary and third-party data in the purchase of that ad space. When ad space is bought or sold, our technology fulfills the transaction by delivering the ad to Internet users (job seekers) who visit that site, app, or device. Generally, an Internet user’s device (computer, mobile device or otherwise) comes into contact with Joveo technology when a user views a job ad delivered by our technology or clicks or taps on the ad to visit the advertiser’s website or app.
In accordance with applicable laws and regulations, including the European Union General Data Protection Regulation (EC Regulation 2016/679), the Company controls, collects, owns and directs the use of the PII and Usage Information and, in this regard, the Company is the data controller. The Company is a registered company in Delaware with its registered office at
168 Beach Park Blvd, Foster City CA 94404
168 Beach Park Blvd, Foster City CA 94404; by email at email@example.com or firstname.lastname@example.org
Privacy practices for our technology Advertising supports free content and digital user experiences that we all like. Our goal is therefore to make advertising more effective by helping to display job ads that may be of interest to You. We believe that relevant job ads are more valuable to job seekers than less relevant ads. More relevance also helps the services that depend on advertising because advertisers pay more for effective job ads which in turn leads to higher quality and richer job seeker experiences.
II. INFORMATION THAT WE COLLECT
For the purpose of providing You with Services, we collect information in two manners as given below:
(i). Information collected by Joveo You may be required to provide personally identifiable information which is information that may be used to identify the user personally inter alia Your name, gender, residential address, age, mobile number, email address (including where in the case of a company, similar information as relevant to that company) (“PII”). We may also collect certain information through various social media platforms and other third-party integrations and such PII collected may be stored by Us. Users may also upload their resumes from any device using third party cloud providers/ applications. In an event where You do not upload a resume, We may auto-generate a resume based on the PII provided by You and upload the same for the purpose of Services.
We may use “cookies” to enhance Your experience with the Site. Cookies are text files that we may place in Your computer browser or any other device that You may use to access the Site from to store Your preferences. Cookies record various aspects of Your visit and assist us in providing You with uninterrupted service. One of the primary purposes of cookies is to store Your preferences and other information on Your computer or any other device that You may use to access the Site in order to save You time by eliminating the need to repeatedly enter the same information and to display Your personalized content. However, no PII identifying the User is collected nor any data capture mechanism is employed. You may change Your browser settings to accept or reject cookies on personal preference.
We process the data collected through cookies either independently or with third party service providers, who analyses the data collected through cookies pursuant to contractual relationships with Us. The processing of such data is done to analyze the pages You visit, websites You visited before coming to the Site, and where You go after leaving the Site. The PII may be combined for marketing and for market research purposes, including internal demographic studies, so that we can optimize our products and Services and customize the Site for You and for the purpose of providing Our Services.
Opting out of Cookies
If You would like to opt-out from having Joveo collect Your Non-PII in connection with Our technology, We will place an opt-out cookie on Your device. This cookie tells us not to collect Your Non-PII to tailor our online advertising campaigns. Alternatively, You may disable cookies Yourself through Your browser settings.
2. Mobile Tracking:
a. On Your iOS mobile device enable the “Limit Ad Tracking” setting in Your iOS phone’s settings.
b. On Android devices, Your settings may allow You to “Opt out of Interest-Based Ads.” When You have opted out using this setting on a device and that information is passed to Joveo, Joveo will not use Non-PII data to target interest based ads to You or place You in segments for future marketing.
When using Joveo, We may infer Your non-precise geolocation data based on IP address with us for use in determining which ads to display. We use such data for targeting ads and evaluating their success, and may share it with other parties for similar uses (please see below for circumstances when We may share Your PII with other parties). This non-precise location data is maintained in our logs in accordance with our data retention policy (below).
IV. HOW WE USE THE INFORMATION WE COLLECT
We, our affiliates or third-party service providers may use PII or Usage Information collected in the following ways:
1. To operate and improve the Site and tools associated with the Site;
2. To confirm Your identity in order to determine Your eligibility to use the Site and avail the Services;
3. To provide You the Services;
4. To enable us to show You ads that are relevant to You;
5. To protect against errors, fraud and other criminal activity;
6. To observe, improve, administer the Services and diagnose technical problems;
7. To transmit, share or transfer the PII provided by You to a prospective employer in order to enable Us to provide You with the Services;
8. To enable You to upload Your resume or permit Us to auto-generate a resume on Your behalf, search for job postings, and contact or be contacted by prospective employers who are also clients of Us;
9. To assess Your qualifications and suitability for job opportunities;
10. To allow You to login to Your account to manage Your information and job search;
11. To send You communications regarding status of Your applications, requests that You may have made to Us or any other communication that may be of interest to You by way of emails, or courier, or registered post, or telephone calls, or any other mode of communication;
12. To notify You about changes to our Services;
13. To generate and review reports and data about, and to conduct research on, our user base and Service usage patterns;
14. To use Your information to analyse and show multiple other relevant jobs to You;
15. To apply quickly to multiple jobs without the need to completely fill the application form;
16. To sign-up on Your behalf and hold Your credentials for future sign-ins; and
17. For any other purpose with Your consent.
V. DATA TRANSFER
Your PII collected through the Site may be stored and processed in the USA or any other country in which We or Our subsidiaries, affiliates or service providers maintain facilities. We may transfer information that We collect about You, including PII, to affiliated entities, or to other third parties across borders and from Your country or jurisdiction to other countries or jurisdictions around the world. If Your PII is transferred to another country, We will ensure that Your PII is protected and used according to applicable law in such country.
VI. IS MY INFORMATION EVER SHARED WITH OTHER PARTIES?
Normally, we will never share any of Your PII with a third party unless You give us permission to do so. However, in some cases, we may choose to buy or sell assets. In these types of transactions, Your information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, Your information would be one of the assets that is transferred or acquired by a third party.
We may share Your information with our customers and partners including applicant tracking systems, CRMs, web publishers, job boards, demand side platforms, data management platforms, supply-side platforms, affiliate tracking systems and other third-party service providers that are necessary to perform Joveo and its affiliates services.
By using the Services, You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use Your PII as set forth in this policy. We also reserve the right to access, read, preserve, and disclose any information as it reasonably believes is necessary to
(i) satisfy any applicable law, regulation, legal process or governmental request,
(iii) detect, prevent, or otherwise address fraud, security or technical issues,
(iv) respond to user support requests, or
(v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.
VII. HOW DOES JOVEO KEEP MY INFORMATION SECURE?
Joveo uses industry standard security measures to ensure the security of its data, including any information You have given us. We routinely evaluate our data security practices to identify security threats or opportunities for improvement. Nonetheless, it is impossible to guarantee that the transmission of data through the Internet will be secure. By using the Services, You acknowledge that it may be possible for third parties to intercept or access transmissions or private communications unlawfully.
VIII. WHAT ARE MY DATA PROTECTION RIGHTS?
(a) obtain confirmation from Us that Your Personal Information is being collected and used by Us and to access the Personal Information held about You by Us;
(b) have Your PII corrected or updated at any time in case of inaccuracy or incomplete PII.
(c) block or suppress Us from collecting and using Your PII, which means We can continue to store Your PII but we cannot further collect or us it in any way;
(d) obtain and reuse any PII We hold about You for Your own purposes across different services, which allows You to move, copy or transfer Your PII easily from the Company to another place notified by You to Us in a safe and secure way without hindrance to the usability of Your PII.
(e) erasure, or the right to be forgotten, which means You can request the deletion or removal of any Personal Information We hold about You at any time. Please note that we may impose a small fee for access and disclosure of Your personal information where permitted under applicable law, which will be communicated to You beforehand.
Any request received by Us in relation to the aforesaid shall be acknowledged within 30 (thirty) days of receipt of such request.
You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en
IX. CHILDREN’S PRIVACY
Protecting the privacy of Young children is especially important. For that reason, We do not knowingly collect or solicit PII from anyone under the age of 16. In the event that we learn that we have collected PII from a child under age 16, we will delete that information as quickly as possible. If You believe that we might have any information from or about a child under 16, please contact us at email@example.com or firstname.lastname@example.org
XI. LIMITATION OF LIABILITY
You also agree that You have provided notice to, and obtained consent from, any third party individuals whose personal data You supply to Joveo with regard to: (a) the purposes for which such third party’s personal data has been collected; (b) the intended recipients or categories of recipients of the third party’s personal data; (c) which of the third party’s data are obligatory and which data, if any, are voluntary; and (d) how the third party can access and, if necessary, rectify the data held about them.
XII. WHAT IF I HAVE QUESTIONS OR CONCERNS?