INTRODUCTION
This Privacy Policy describes the policies and procedures of Sourcing Square LTD, here referred also as “Sourcing Square”, “Company”, “we”, “our” or “us”, on the collection, use and disclosure of information of any person who wishes to procure the Services (“Your” or “You”) on www.sourcingsquare.com, or any applications created by us on third party websites (the “Site”) and the services, features, content or applications we offer (collectively with the Site, the “Services”). You can access several features of the Site and/ or the Services being offered by the Company. This document contains the terms and conditions to facilitate Your use/access of our Services. If and when You continue to use or/and access Site and / or Services, then such use or/and access shall constitute Your consent to be bound by the terms and conditions of Sourcing Square’s Privacy Policy contained herein.
OUR COMMITMENT TO PROTECT YOUR PRIVACY
At Sourcing Square, we firmly uphold the belief that the Internet thrives when websites and businesses honour the privacy of their users. Simultaneously, we acknowledge that websites often necessitate the collection of certain personal information from users to create a bespoke and tailored user experience. We commit ourselves to use any data we gather from you solely for the purpose of enhancing your experience with the Sourcing Square Site and Services. As elaborated in the following sections, we fully comprehend that your decision to share information with us does not imply a desire to share it with the broader public. Consequently, safeguarding the information you entrust to us remains our utmost priority. Our main objective is to ensure that your experience with the Site and Services is both gratifying and secure.
COMPLIANCE WITH APPLICABLE LAWS
Sourcing Square strives to be in compliance with all applicable data protection laws and to operate within the UK and EU General Data Protection Regulation (GDPR)
When you access our website online, we store some information about you. This is anonymous and used for statistical purposes.
When you create an account and log-in to your “My Account” area, it is protected by your password and may only be accessed by you. You can manage the content and information in your Account at any time, by logging in to your “My Account”.
Your CV can be viewed by Sourcing Square customers, if you have consented to this within the profile section. This is the default setting. Further, when your profile is searchable your application activity (e.g. number of applications, job titles, locations & salaries) will be visible to Sourcing Square customers. Such visibility can also be provided through browser plugins or other software that we or our group companies offer if our customers visit certain social media websites about you. This is also the default setting.
As a registered user, if you decide to exercise your right to erasure under Article 17 of General Data Protection Regulation, we will remove your data stored and processed by us, including any applications made or saved for recruiters to view.
Please note that we reserve the right to remove from our database, CVs which include any content that we consider to be illegal or offensive.
However, if you would like to permanently delete your account, you can send an email to our Data Protection Officer (DPO) (see below) with the subject line “Permanently delete my information and account”. Please do not forget to tell us who you are.
It is important for you to protect against unauthorised access to your password and to your computers, devices, and applications. Be sure to sign off when you finish using a shared computer.
Further, You have the right to restrict your Personal Information from being processed in the event that you contest the accuracy of the Personal Information, contest the means of processing or find us having no legitimate claim to do so.
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 authorised. To request to limit the use and disclosure of Your Personal Information, please submit a written request to info@sourcingsquare.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.
l. WHAT IS SOURCING SQUARE
Sourcing Square is an advertising technology platform registered in England, Reg # 11773798. Sourcing Square runs a technology buying platform for digital media. Our 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 fulfils 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 our 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.
For any queries regarding this Privacy Policy and the collection and use of data collected or processed under this Privacy Policy, the Company can be contacted by email at info@sourcingsquare.com
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.
ll. 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 Sourcing Square 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, ethnic origin, email address (including where in the case of a company, similar information as relevant to that company) (“PII” or “Personal Information”). 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.
(ii). Information automatically collected in addition to the PII submitted by You to Us, to identify real time trends in the marketplace so they can reach targeted audiences more effectively, as opposed to collecting information on an individual’s internet usage, We may use other technologies (including cookies) to collect certain information (“Usage Information”) whenever You access the Site. This usage Information may include the browser that You are using, the URL that referred You to the Site and information regarding the devices used by You to access the Site, among other information. Usage Information may be non-identifying or may be associated with You. Whenever we associate Usage Information or a device identifier with Your PII, we will treat it as PII and the conditions relating to PII under this Privacy Policy will be followed. Ad Tags Companies that work with us use our core algorithms and technology, which place ad tags on their websites. These ad tags are used to customise a user’s advertising experience, but they do not contain any PII. Rather, ad tags usually contain anonymous information about the web site, section of the site and size of the ad that the Services are optimizing.
III. COOKIES
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 Your time by eliminating the need to repeatedly enter the same information and to display Your personalised content. 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 analyse the data collected through cookies pursuant to contractual relationships with Us. The processing of such data is done to analyse 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 optimise our products and Services and customise the Site for You and for the purpose of providing Our Services.
Please note that our Privacy Policy covers only Your use of our Site and Services and does not cover the use of cookies by third parties, such as our clients. We do not control when or how third parties place cookies on Your device. For example, third party websites to which a link points may set cookies on Your device. We encourage You to take note of other sites’ Privacy Policies.
Opting out of Cookies
If You would like to opt-out from having Sourcing Square 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.
Location Tracking
When using Sourcing Square, 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).
lV. 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:
V. DATA TRANSFER
Your PII collected through the Site may be stored and processed in the UK 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 without limitation 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.Should You have an objection to such transfer, then kindly write to us at info@sourcingsquare.com and we shall ensure to not undertake such transfer of Your PII.
Vl. 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, we do share your information with third parties with whom we have tied up to enhance the Services and offerings to You. Such third parties will also comply with the obligations set out under this Privacy Policy. Further, 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 Sourcing Square 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,
(ii) enforce this Privacy Policy, including investigation of potential violations hereof,
(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 organisations for fraud protection and spam/malware prevention.
VI. HOW DOES SOURCING SQUARE KEEP MY INFORMATION SECURE?
Sourcing Square 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.
VII. WHAT ARE MY DATA PROTECTION RIGHTS?
This Privacy Policy is effective from 1st October 2023 for all users, provided that enhanced data protection rights in this Policy required by the EU and UK General Data Protection Regulation (GDPR) became effective on 25th May 2018 for all EU-resident users who are natural persons. You have the following data protection rights in relation to the PII provided by You on the Site:
(a) obtain confirmation and reasons 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 use 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.
(f) if we have collected and processed Your PII with Your consent, then You can withdraw Your consent at any time. Withdrawing Your consent will not affect the lawfulness of any processing we conducted prior to Your withdrawal, nor will it affect processing of Your PII conducted in reliance on lawful processing grounds other than consent. To request access, correction, deletion or transfer of Your personal information or withdrawal of consent to the processing described in this Privacy Policy, please email us at info@sourcingsquare.com
(g) to restrict processing of your PII in case of inaccuracy, employment of unlawful means of processing or illegitimate reasons for processing of your data. In such cases we shall continue to store your PII but shall not use it in any way.
(h) to transfer your PII stored with us to another entity in a structured, commonly used and machine-readable form.
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
VIII. 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 info@sourcingsquare.com
IX. WHAT HAPPENS WHEN THERE ARE CHANGES TO THIS PRIVACY POLICY?
We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make any material changes in the way we collect or use information, we will notify You by posting a notice on the Site prior to the change becoming effective or sending You an email to Your registered email address. Please note that You are bound by any changes to our Privacy Policy when You use the Site or Services after such changes have been first posted.
X. LIMITATION OF LIABILITY
YOU UNDERSTAND AND AGREE THAT ANY DISPUTE OVER THE PRIVACY OF SOURCING SQUAREDATA OR SOURCING SQUARE’S PRACTICES IS SUBJECT TO THE PROVISIONS OF THIS PRIVACY POLICY, EXCEPT AS REQUIRED UNDER PRIVACY SHIELD. YOU AGREE THAT SOURCING SQUARE’S LIABILITY FOR ANY BREACH OF THIS PRIVACY POLICY SHALL BE LIMITED TO THE GREATER OF THE VALUE OF THE TRANSACTIONS OR SERVICES PROVIDED TO YOU BY SOURCING SQUARE FOR £200 TO THE EXTENT SUCH CLAIM IS NOT OTHERWISE BARRED. YOU FURTHER AGREE THAT THIS PRIVACY POLICY AND THE AGREEMENTS HEREUNDER ARE GOVERNED BY THE LAW OF ENGLAND AND WALES.
You also agree that You have provided notice to, and obtained consent from, any third party individuals whose personal data You supply to Sourcing Square 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.
XI. WHAT IF I HAVE QUESTIONS OR CONCERNS?
If You have any questions or concerns regarding this Privacy Policy or privacy using the Services, please send us a detailed message to info@sourcingsquare.com We will make every effort to resolve Your concerns.
If You have questions or concerns regarding this statement, email us at info@sourcingsquare.com. We are providing this privacy policy to inform You about how our technology platform processes information on behalf of online advertisers (direct employers), recruitment media agencies, website owners, job boards, data providers and other businesses that use our technology and services.
