Privacy Policy

We don’t care about your data,

we care about your privacy.

Hiring Tool, registered with the Delaware Companies Registration Office under the name Repladev Inc (“Hiring Tool”, “we”, “us”, “our”) are committed to protecting and respecting your privacy. This privacy notice explains how we collect, use and share personal data about you if you are (i) an authorized user or representative of a company which is a customer and/or partner of Hiring Tool; (ii) visiting our website; or (iii) in contact with us in any other way, e.g., through our customer service. In addition, this privacy notice explains how you can exercise your rights.

In order for you to easily find the sections that interest you, we have divided this privacy notice into a number of headings. To go directly to a section, just click on the heading in question in the list below.

Your rights and how you can exercise them
What type of personal data do we collect, for what purpose and what legal basis do we rely on?
With whom do we share your personal data?
For how long do we process your personal data?
How do we protect your personal data?
Third party websites
Use by minors
Changes to this privacy notice
Contact information

1. Your rights and how you can exercise them

You have several rights in accordance with the General Data Protection Regulation (“GDPR”), the California Consumer Privacy Act (“CCPA”) and other applicable data protection legislation. These rights are:

Right to access your information: You can get information from Hiring Tool about what personal data we have collected, why we have collected it and so on.

Right to rectification: If any of your personal data that we process is inaccurate, you are entitled to have it corrected.

Right to erasure (“right to be forgotten”): You can request that Hiring Tool erase personal data that we have gathered about you. Hiring Tool will then, if no exceptions to this rule is applicable, remove the requested personal data.

Right to restriction: You can request that Hiring Tool restricts the processing of your personal data under certain circumstances, e.g. if you contest the accuracy of the personal data processed by us. We must then restrict the processing while verifying the accuracy of your request.

Right to object: You can object to the processing of your personal data that Hiring Tool carries out based on the legal basis of our legitimate interest as specified above in this privacy notice, including profiling that we carry out on the basis of our legitimate interest, whereby we must assess if we can continue to process your personal data. You also have the right to object to processing of your personal data for direct marketing purposes.

Right to data portability: You can request that Hiring Tool provides all the personal data that Hiring Tool processes about you in an easy and accessible format.

If you contact us and ask us to provide you with the information we have collected about you or exercise any other rights mentioned in this privacy notice, we will ask you to verify yourself in order to prevent disclosure of personal data to the wrong person. The legal basis for such processing is based on legal obligations under the GDPR and our legitimate interest of verifying your identity in order to prevent disclosure of personal data to the wrong person.

CALIFORNIA CONSUMER NOTICE
Under California Civil Code Section 1789.3, California users must receive the following specific consumer rights notice: The Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs may be contacted in writing at 1020 N Street, #501, Sacramento, California 95814, or by telephone at 1-916-445-1254.

CALIFORNIA AND NEVADA – SHINE THE LIGHT LAW & YOUR PRIVACY RIGHTS
California and Nevada residents may request and obtain from us, once a year, free of charge, a list of third parties, if any, to which we disclosed their Personal Information (as defined in the Shine the Light Law, Cal. Civ. Code § 1798.83 or under Nevada law) for direct marketing purposes during the preceding calendar year and the categories of Personal Information shared with those third parties. If you are a California or Nevada resident and wish to obtain that information, please submit your request by sending us an email at [email protected] we will confirm your identity and response in accordance with legal requirements.

2. What type of personal data do we collect, for what purpose and what legal basis do we rely on?

2.1 You who are a representative of a Hiring Tool customer and/or partner

If you are an HR representative or hiring manager using our platform to manage job applications and/or employee data, we will process your personal data in connection with the onboarding of your company and to administer our relationship with and fulfil our agreement with your organization. This may include processing data related to your job titles, contact information, and role within the company.

Categories of personal data

Name
Phone number

Purpose

To provide services and support, and to administer the agreement with the company that you are representing.
To set-up user accounts and user roles.
To send marketing to you, inter alia, through email. You can opt-out from further marketing by clicking on a link in each message sent through email, or by contacting us via the contact information set out below.
To fulfil legal obligations (e.g. accounting requirements) and to report criminal activity.

Legal basis

Legal obligation: To fulfil our legal obligations, e.g. accounting and tax legislation.
Legitimate interest: To pursue a legitimate and compelling interest, e.g. to fulfil an agreement with our customers, to set up use accounts and roles and to communicate with you.

2.2 You who visit our website

Whenever you visit our website, we collect information that you choose to submit to us, e.g. name, e-mail address and phone number. We may also collect personal data through cookies. Hiring Tool’s use of cookies is described in our cookie policy.

Categories of personal data

Contact information: name, phone number and email address.
Surfing habits and visiting history: which pages you have visited on our (and others) website, and for how long.
Demographic information: age, gender, civil status, address and education.
Login credentials: e-mail address and password.
Profiling- and movement patterns: choices and purchases made, number of clicks, location data, preferences, custom audience and profile.
Technical data: technical equipment used, timestamps, metadata, cookie-ID and IP-address.

Purpose

To maintain, provide, test and improve our website.
To offer you support when facing a problem on our website.
To send marketing to you, inter alia, through email. You can opt-out from further marketing by clicking on a link in each message sent through email, or by contacting us via the contact information set out below.
To create reports, review the effect of marketing campaigns and create anonymized statistics regarding the usage of our website.
For management, development and testing of our IT systems in order to ensure that our website upholds high quality as well as identifying and preventing security attacks such as viruses.
To provide relevant and tailored offerings and advertisements to you.

Legal basis

Legitimate interest: we have a legitimate and compelling interest for processing your personal data, e.g. to provide you with marketing, to obtain anonymized statistics, and to manage, develop, test and improve our IT system and services.

2.3 You who contact our customer service or otherwise interact with us

When you contact us, e.g. with queries to our customer service or when you otherwise interact with us, we process the personal data that you choose to submit to us.

Categories of personal data

Contact information: name, phone number and email address.
Customer service requests: information which you choose to submit to us, and information related to your inquiry.

Purpose

To communicate with you and administer your request.
To analyze conversations in order to improve our communication and for your and our security.
To obtain anonymized statistics regarding the usage of Hiring Tool’s communication channels.
To maintain, develop, test and improve Hiring Tool’s services and the technical platforms on which they are provided.

Legal basis

Legitimate interest: we have a legitimate and compelling interest for processing your personal data, e.g. to provide you with marketing, to obtain anonymized statistics, and to manage, develop, test and improve our IT system and services.

3. With whom do we share your personal data?

In connection with one or more of the purposes outlined in this privacy notice, Hiring Tool may disclose your personal data to:

Other entities within the Hiring Tool group of companies.
Third parties that provide services to us, such as system hosting, management, and support; data analysis; facilitation of advertisements; data backup; and data security and storage services.
Other third parties as we believe necessary or appropriate under applicable law (such as, but not limited to a government order or a subpoena, which we will take steps to contest prior to disclosing), or if we believe in good faith that it is reasonably necessary (i) to respond to claims asserted against us or to comply with the legal process (for example, discovery requests, subpoenas or warrants); (ii) to enforce or administer our policies and agreements with users; (iii) for fraud prevention, risk assessment, investigation, customer support, product development and debugging purposes, including investigation of violation of our terms or agreements with others; or (iv) to protect our rights, property or safety, its users, business partners or members of the general public.

We also may sell, transfer or otherwise share some or all of its assets, including your personal data, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy. Under such circumstances, we will use commercially reasonable efforts to notify our users if their personal data is to be disclosed or transferred and/or becomes subject to a different privacy notice.

The disclosures described in this section may result in the transfer of your data to countries or regions with data protection laws that differ from those in your country of residence.

In cases where your data is transferred outside of your country of residence, we take steps to ensure that appropriate safeguards are in place to protect such data. If you are based in the EU/EEA, such safeguards may include a data transfer agreement with the data recipient based on standard contractual clauses or such other mechanism as is approved by the European Commission for transfers of personal data to third countries. For further details relating to the transfers described above and the adequate safeguards used with respect to such transfers, please contact via the contact details below.

Subprocessors

Entity Name	Subprocessing Activities	Entity Country
Google, Inc	Analytics Services	United States
Crisp IM SAS	Customer Support	France
LOU Web Technologies Inc	User Onboarding	United States
Cloudflare	Web monitoring, Denial of Service protection	United States
OpenAI	Evaluate candidate CVs and relation to applied job postings	United States
Amazon Web Services	Cloud Service Provider	United States

4. For how long do we process your personal data?

We will only process your personal data for as long as we need to fulfil the purpose the personal data was collected for or to fulfil legal obligations, such as storing specific information in accordance to bookkeeping or tax requirements.

5. How do we protect your personal data?

We take appropriate measures to ensure that your personal data is kept secure in accordance with industry best practices and applicable laws to protect data we collect from loss, alteration, destruction, misuse, and unauthorized access or disclosure.

To prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of the personal data we collect, we have implemented physical, electronic, and administrative procedures. We utilize hashing and encryption techniques to help ensure your personal data is safeguarded.

We have policies to help maintain control and physical security of the facilities used to store data and only allow access to authorized personnel, restrict access to data to only those employees, contractors and agents that require it to provide and support our services. All our employees are bound by confidentiality obligations and may be subject to disciplinary or legal action if they fail to meet these responsibilities.

We process information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable steps to ensure that any information in our care is accurate, complete, current, and reliable for its intended use.

User Data on CVs that are processed through OpenAI

Each customer has the option to enable AI features. By doing so, The CVs are processed by this entity. Before processing the data using external AI subprocessors, such as OpenAI, we anonymize user data by removing personally identifiable information like names and contact details. No private data is shared with the subprocessors, ensuring the privacy and security of user information.

6. Third party websites

Our website may contain links to third-party owned and/or operated websites including, without limitation, websites owned and/or operated by third parties. We are not responsible for the privacy practices or the content of such websites. These third-party websites have separate privacy and data collection practices and we have no responsibility or liability relating to them.

7. Use by minors

Visitors under sixteen years of age are not permitted to use and/or submit their personal information into this website. If you become aware of someone sixteen years old or younger submitting information into this website, please contact us at [email protected] so we can take steps to investigate and remove their information.

8. Changes to this privacy notice

Hiring Tool has the discretion to update this privacy notice at any time. We encourage you to frequently check this page for any changes to stay informed about how we process and protect your personal data.

This privacy notice was last updated: November 30, 2023.

9. Contact information

All questions or requests regarding this privacy notice should be addressed to Hiring Tool’s Customer Success Team [email protected].