November 4th, 2019
We are VidCruiter Inc. (“VidCruiter”), a Canadian registered company. We provide online Applicant recruitment and selection services, as more fully described on our websites (our “Services”), including the online recording of text, audio and video responses to questions selected by Clients along with reference checking. The Service utilizes a number of dynamic products, including, VidTracking, VidInterviewing, VidLiveinterviewing, VidRating, VidReferencing, VidTrainer, VidOnboarding, VidTesting, VidAdmissions and VidHiring as further described on the Website (the “VidCruiter Offerings”). We operate the website available at vidcruiter.com (the “Websites”).
Our Privacy Officer may be contacted using the contact details set out at the bottom of this policy.
2. Compliance Certification Programs
VidCruiter is committed to helping our customers support their regulatory compliance requirements. Our Information Security Risk Management Program is built on a solid foundation of widely accepted frameworks for Information Security and Risk Management, including ISO 27001, ISO 27017 and SOC2 Type2. VidCruiter adheres to Fair Information Practice Principles of notice, choice, access, security, and enforcement.
It is always your choice whether or not to provide Personal Information. However, if You choose not to provide requested Personal Information, You will not be able to use certain features of the Website, Apps and/or Services. We set out in detail below the information that we collect about You and Your use of our Website.
4. The Information We Collect About You
Personal data, or personal information, means any information relating to an identifiable person who can be directly or indirectly identified. It does not include data which cannot be related to an identifiable person (anonymous data).
We may collect, use, store and transfer different kinds of personal information about you which we have grouped together follows:
- Identity Data includes first name, last name or similar identifier.
- Contact Data includes email address and telephone numbers.
- Technical Data includes internet protocol (IP) address, browser type and version, operating system and platform.
- Usage Data includes information about how you use our Website, app(s) and Services, such as the buttons, controls, products and ads you click on, pages of our Website that you visit, the time spent on those pages, your search queries, the dates and times of your visits, but also about the webpage you were visiting before you came to our Website(s) and the webpage(s) you go to next
- Social Media Data includes information that we may collect from third party social media sites such as Facebook or LinkedIn
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences, demographic information about you.
We also collect, use and share Derived Data such as statistical data for any purpose. Derived Data may be derived from your personal information but is not considered personal information in law as this information does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
5. How Is Your Personal Information Collected
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you :
- sign up for a demo of our services;
- subscribe to our email alerts;
- request marketing to be sent to you; or
- give us some feedback.
- Third parties or publicly available sources. We may receive personal information about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- analytics providers such as Google Analytics;
- search information providers such as Google.
- Identity and Contact Data from our partners, data brokers or aggregators.
- Identity and Contact Data from publicly available sources such as LinkedIn, Facebook, and other social networking sites.
- Technical Data from the following parties:
6. Purposes for Which We Will Use Your Personal Information
We have set out below, in a table format, a description of all the ways we plan to use your personal information. Please contact us if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below.
|Purpose/Activity||Type of Data|
|To deliver relevant website content to you (including by recognizing users across the devices they use)|| |
|To register you as a prospective customer|| |
|To manage our relationship with you which will include: || |
|To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)|| |
|To use data analytics to improve our website, services, marketing, customer relationships and experiences|| |
|To make suggestions and recommendations to you about services that may be of interest to you|| |
|To improve our Website and Marketing: including: || |
|For marketing purposes, including: || |
- To our subsidiaries and affiliates where they are providing.
- To contractors, service providers, and other third parties we use to support our business solely for the purpose of them providing services to us.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of VidCruiter’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by VidCruiter about our Site or App users is among the assets transferred.
- To fulfill the purpose for which You provide it.
- For any other purpose expressly disclosed by us when You provide the information.
We may also disclose Your Personal Information:
- To comply with any court order, law or legal process, including to respond to any government or regulatory request.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of VidCruiter, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Upon request, VidCruiter will provide You with information about whether we hold any of Your Personal Information. VidCruiter enables customers and website visitors with the ability to access and correct Personal Information we have collected. If You have any concerns or suspect unauthorized activities associated with Your account, please contact us at security (@) vidcruiter.com. We will respond to Your request within a reasonable timeframe, and in any event within 30 days of receipt of request.
VidCruiter acknowledges that You have the right to access, update, revoke permission to process, or request the deletion of Your Personal Information. Any such query can be directed to VidCruiter’s Data Protection Officer at dpo (@) vidcruiter.com. If requested to remove data under either scenario, we will respond within a reasonable timeframe.
9. Security and Enforcement
The security of Your Personal Information is important to us. We use security safeguards appropriate to the sensitivity of the information to ensure that Your Personal Information is stored and maintained in a secure environment. VidCruiter exercises managerial and technical safeguards designed to protect against the loss or unauthorized use or disclosure of Personal Information belonging to our customers and website visitors, as more fully described here https://vidcruiter.com/security/. These safeguards include encryption, malware protection, logical and physical access controls, and detection of social engineering attacks.
10. Retention of Data
Data we collect about website visitors: what, where, when, and why
What Web log data (IP addresses, cookies)
Where Server logs
Retention Period 7 days
What Information You submit through web forms, buttons, hyperlinks, etc.
Where Social media sites
Retention Period 6 years
What Demographic marketing information
What Aggregated in the VidCruiter analytics infrastructure used for analyzing and improving marketing campaigns.
Where Analytics data repository
Retention Period Indefinitely
User-Configurable Options for Processing Personal Data
Options for managing Your Personal Information
Marketing Communications: Removal from all communications
unsubscribe (@) vidcruiter.com
Removal of Personal Information:
Request to be forgotten **
dpo (@) vidcruiter.com
security (@) vidcruiter.com
** VidCruiter is required to maintain records of consent and requests for correcting or deleting Personal Information for 6 years.
11. Managing the Online Collection of Additional Data
As You navigate through and interact with our Website and Services, we may use automatic data collection technologies to collect certain information about Your equipment, browsing actions and patterns, location, and workplace usage patterns, including:
- Details of Your visits to our Website or App and other communication data and the resources that You access and use on the Site or App.
- Information about Your computer and Internet connection, including Your IP address, operating system, and browser type.
- We also may use these technologies to collect information about Your online activities over time and across third-party websites or other online services (behavioral tracking).
- When You access and use the App, we may automatically collect certain details of Your access to and use of the App, including traffic data, location data, and other communication data and the resources that You access and use on or through the App.
- We may collect information about Your mobile device and Internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information and the device’s telephone number.
- Our App collects real-time information about the location of Your device.
We and our third-party service providers may collect information about You in a variety of ways. We and/or our third-party partners may employ various tracking technologies, such as cookies, web beacons and analytics software, that help us better manage content on our Service by informing us what content is effective.
- 11.1 Advertising
Similarly, we or a third-party data partner may associate cookies with hashed (non-human readable) versions of Your registration data (e.g., Your email address), along with other interest-based or demographic data. You can learn more about or opt out of this type of advertising through the links in the following paragraph.
- 11.2 Mobile Opt-Out
You can opt out of having Your Mobile Ad IDs used for interest-based mobile advertising by accessing the settings on Your Apple or Android mobile device, as follows:
- Apple Devices: If You have an Apple device, You can opt out of most cross-app advertising by updating to iOS 6.0 or higher and setting Limit Ad Tracking to ‘ON.’ You can do this by clicking on Settings > General > About > Advertising, and toggling Limit Ad Tracking to ‘ON.’
- Android Devices: If You have an Android device, You can opt out of most cross-app advertising by clicking on Google Settings > Ads, and selecting the option to opt-out of interest-based ads.
Please note that these platforms control how these settings work, so the above instructions may change. Likewise, if Your device uses other platforms not described above, please check the settings for those devices.
- 11.3 Web-Based Opt-Out
If You wish to opt-out of many of the ad platforms that serve or support interest-based advertising (or learn more about this type of advertising), go to http://www.networkadvertising.org/managing/opt_out.asp, http://www.aboutads.info/choices and http://preferences-mgr.truste.com/ to opt out in desktop and mobile web browsers. You may download the AppChoices app at www.aboutads.info/appchoices to opt out in mobile apps. For individuals in the EU, please also visit http://www.youronlinechoices.eu/. Please note that opting out does not opt You out of being served advertising. You will continue to receive generic ads.
- 11.4 Cookies
When You visit our website or otherwise interact with the Service we (or third-party data or ad networks we work with) may send one or more “cookies” to Your computer or other devices. Cookies are alphanumeric identifiers stored on Your computer through Your web browser and are used by most websites to help personalize Your web experience. Some cookies may facilitate additional site features for enhanced performance and functionality such as remembering preferences, allowing social interactions, analyzing usage for site optimization, providing custom content, allowing third parties to provide social sharing tools, and serving images or videos from third-party websites. Some features on this site will not function if You do not allow cookies. We may link the information we store in cookies to any Personal Information You submit while on our site.
Functional cookies, persistent and session type, store information to enable core site functionality.
Analytics cookies allow us to count page visits and traffic sources, so we can measure and improve the performance of our site and our marketing campaigns.
Advertising cookies may be set through our website by our advertising partners. Data may be collected by these companies that enable them to serve up advertisements on other sites that are relevant to Your interests.
- 11.5 Web Beacons
We (or third-party data or ad networks we work with) may use Web Beacons alone or in conjunction with cookies to compile information about our Service, or other information we or they have collected. Web Beacons are tiny graphic objects that are embedded in a web page or email and are usually invisible to the user but allow checking that a user has viewed the page or email. Web Beacons may be used within the Service to track email open rates, web page visits or form submissions. In some cases, we tie the information gathered by Web Beacons to our Users’ Personal Information. For example, we use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.
- 11.6 Flash and HTML5 Storage
We use Local Shared Objects, such as Flash cookies, AND/OR Local Storage, such as HTML5, to store content information and preferences. Third parties with whom we partner to provide certain features on our website or to display advertising based upon Your web browsing activity also use Flash cookies or HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5.
- 11.7 Do Not Track Signals
At this time, we do not respond to browser ‘do not track’ signals.
12. Transfers of Data
VidCruiter’s headquarters in Canada is our primary location for business operations. In addition, VidCruiter maintains a presence in the in the United Kingdom, European Union, Australia and the Philippines. Servers hosting the VidCruiter platform are located in the United States, EU, Canada, and Australia.
For example, regarding normal business operations, VidCruiter may engage a third-party to support our billing, support services, information technology, or mailings on our behalf.
We may also disclose Your Personal Information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect Your safety, or the safety of others, investigate fraud, or respond to a government request.
13. Outside Parties and Sites
14. Additional Privacy Protections for Minors
15. Data Retention
VidCruiter will keep Your Personal Information for as long as it remains necessary for the identified purposes in Section 6 or as required by law, which may extend beyond the termination of our relationship with You. You acknowledge and agree that if You request that Your name be removed from our databases, it may not be possible to completely delete all Your Personal Information due to legal constraints.
16. RESIDENTS OF THE EUROPEAN UNION (EU)
VidCruiter generally processes Personal Information in order to fulfill contracts we have with our customers and end users and to pursue our legitimate business interests listed above. Otherwise, VidCruiter will obtain consent from an individual with respect to the processing of Personal Information if required by law to do so.
Further, individuals located in the EU have certain rights under European law (including under the General Data Protection Regulation) with respect to Personal Information, including the right to request access to, obtain, correct, amend, delete, or limit the use of your personal data. Individual end users, customers or prospective customers located in the EU who wish to exercise these rights, should contact VidCruiter using the contact information below in Section 17. If we are processing your information on behalf of a third party then you should contact that party directly because VidCruiter serves as a data processor on behalf of third party in that instance, and can only forward your request to the buyer to allow them to respond. Individuals also have the right to make complaints to regulatory authorities in respect of our privacy practices.
18. Contact information.
VidCruiter Privacy Officer
100 Cameron St., Suite 4000
Moncton, NB E1C 5Y6
info (@) vidcruiter.com