Privacy Policy

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Infinitely People Limited is committed to safeguarding the privacy of our Products' visitors and users. We are committed to protecting and respecting your privacy, and to acting in compliance with the General Data Protection Regulation ((EU) 2016/679) ("GDPR").

This Privacy Policy applies to websites, applications, events and other services operated by Infinitely People Limited. For simplicity we refer to these as our “Products” in this policy (see definitions). Some Products may require their own privacy policy and if a particular Product has its own privacy policy then that policy supersedes this one and will apply.

Please read the following Privacy Policy to understand what information, personal or non-personal you provide us with, how this information is collected, processed, used and disclosed when you access or use our Products. The policy also seeks to outline how we safeguard personal information that you may provide us with when you visit or use our Products.

Simply visiting our Products does not require you to provide us with any personal information, however if you request more information from us, register with or order from us, or use any of our Products or services, we collect any personal information you provide and the details of the transaction between both parties. This policy together with our Terms and Conditions of Use and Terms of Business explain how we collect, use and process the data you may provide us with. Please at no point provide us with any personal data which belongs to someone else without their expressed written permission.

Please read the following Privacy Policy carefully. By using Infinitely People Products and/or registering your interest in us or our services online, you consent to its terms. If you do not agree with the terms of the Privacy Policy, you should refrain from using any of our Products.

The content of our Privacy Policy includes:

1. Definition of terms
2. Key privacy principles
3. Collection and usage of personal information
4. Disclosure of personal information
5. Length of storage of information
6. Security of data and international transfers
7. Cookie usage
8. Marketing
9. Access to data held about you
10. Links to other sites
11. Applicable jurisdiction
12. Changes to our Privacy Policy
13. Contacting us

Definitions

In this Disclaimer

• "we" "us" "our" means Infinitely People Limited;
• "Product" and "Products" means Infinitely People (including Infinitely People's online and/or mobile services, websites and mobile applications and software provided by Infinitely People on or in connection with such services or websites) and Infinitely People's product Bounce (including Bounce's online and/or mobile services, websites and mobile applications and software provided by Infinitely People on or in connection with such services or websites) and any other features, apps, technologies, software, products, or services offered by Infinitely People Limited
• "Use of the products" and "Use the products" means accessing, browsing or registering to use our Products in whatever manner;
• "Terms of Use", "Terms and Conditions of Use" means the Terms and Conditions of Use policy of Infinitely People Products;
• "Terms of Business" means our terms of business which can be found at Terms of Business policy;
• "Privacy Policy" means our privacy policy which can be found at Privacy Policy;
• "Cookies Policy" means our cookies policy which can be found at Cookies Policy;
• "Materials" or "Content" means information, data, profiles, cv’s, selection and assessment solutions, performance management solutions, surveys and questionnaires or any human capital products provided by us;
• "Personal data" means any information that relates to an identified or identifiable individual, such as but not exclusively your name, profile, work experience, languages spoken and contact details. Please note that at all times will adhere to the applicable statutory definition in determining what is and is not personal data for the purposes of this Privacy Policy
• "Non-personal data" means any information that does not identify you as a specific individual.
• "information" or "your information" this may include both Personal and Non-Personal Data.
• "Assessment data" means your responses to assessments and/or questions needed for the effective running of our various human capital Platforms. It may include but is not exclusively information such as motives, opinions, competencies, behaviour, preferences, skills, strengths, aptitudes, interests and talents and work experience;
• "Research data" means responses about yourself and may include data such as your age, gender, cultural background, educational, job / work related experience;

Key privacy principles

The following three key privacy principles guide our use of data:

1. Notice
   We are committed to making information concerning our data practices readily available to you so you can make an informed decision concerning your activities on our Products (please see the collection and usage of personal information sections below). We actively encourage our customers to do the same when we collect data in the course of providing a service or Products to them.
2. Choice
   We provide you with the opportunity to elect not to participate in certain data collection activities through our Products (please see the collection and usage of personal information sections below).
3. Access
   All visitors and users of our Products are provided with the opportunity to access, review, modify and delete any personal information which may have previously been provided or collected.

Collection and usage of personal information

The Products contain business-related content and we do not solicit or collect personal information relating to or from minors/children. Depending on how you use or interact with our Products, the following types of information may be collected, processed, used and stored.

Information collected when you visit, use or interact with our Products

Like most website and/or application providers, some information is collected automatically concerning your computer or smart device, when you visit and/or use any of our Products, in order for us to:

• Provide our services, products and features in helping job seekers find jobs and Employers find candidates
• Understand our Products usage including which areas of our Products users prefer;
• Protect our users and provide them with customer support
• Administer our Products and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• Measure and improve our Products to ensure that content is presented in the most effective manner for you and for your computer, smart phone, and/or tablet; and
• Keep our Products safe and secure.

When you use our Products we collect the following information. It is stored in log files, in an anonymous form, where no individual is identifiable or identified, and may but not exclusively include the following:

• Device information – We collect information from and about the devices you use to access our service including
  • hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs (such as Google’s AAID and Apple's IDFA, both of which are randomly generated numbers that you can reset by going into your device’ settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address);
  • wireless and mobile network connection information, like your service provider and signal strength;
  • device sensors such as accelerometers, gyroscopes and compasses information

• Usage Information –
  • We collect information such as the source address that the page request is coming from, including your login information, Internet protocol (IP), domain name, date and time of the page request, the referring website or app (if any) and other parameters in the full Uniform Resource Locators (URL) including, clickstream to, through and from our Website (including date and time); advertising that you click on, features you have been using, pages you viewed or searched for; page response times; download errors; length of visits to certain pages; page interaction information (such as scrolling, clicks, and mouse-overs); methods used to browse away from the page.
  • Any phone numbers, emails or messages used to contact our customer service/support teams and how you interact with them.
  • Any interactions with other users (e.g., users you connect and interact with, time and date of your exchanges, number of messages you send and receive) are also collected as is weblogs and other communication data, required for our own billing and administration purposes;

• Other information with your consent- Provided you have given us permission, we can collect your precise geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including GPS, Bluetooth or Wi-Fi connections. If you decline permission for us to collect your geolocation, we will not collect it.

Information collected from you

In order to facilitate job seekers finding employment and employers finding candidates we need to collect some information about you such as basic profile details and the types of roles you are interested in and would like to be considered for. Information you provide us with when using our products include the following:

• Information when you register for an account including some basic details which are necessary for the Products to work such as your login credentials which include a valid email and password. If you are an employer or someone providing employment opportunities Infinitely People may request that you provide certain Personal Data in order to verify your account. This information may include but not be limited to your Company number, business registration information, or a utility bill, the name and email address of the an employer representative. This information will be used for internal purposes only, subject to any request by law enforcement or a court order
• Information when you complete your profile including additional information such as your display name, name- first and surname, CV/resume, work experience, relevant qualifications, work profile, languages spoken, desired roles and your location and/or desired work location. You can also add and share additional content such as a photograph. In order to load content like a picture, you may allow us to access your camera or photo album. Some of the information you choose to provide us may be considered “special” or “sensitive” in certain jurisdictions, for example, but not exclusively your racial or ethnic origins, or gender. By choosing to provide this information, you consent to our processing of that information. You may also provide specific location data which to help you find more relevant job listings. We ask jobseekers not to include information on their profile or CV that is considered sensitive personal data, for example your, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, your health, sex life or sexual orientation. If you choose to create a profile and upload a CV to our database, we rely on you to ensure that your details are kept up to date. You should update your profile or CV at least every six months, particularly if your contact details have changed. As once you engage with our customers they may wish for you to forward your CV. Please note that Infinitely People reserves the right to remove from our Products or database, CVs or profiles which include any content that we consider to be illegal or offensive.
• Information that you provide when you use some of our Products in order to complete your profile including our assessment questionnaires and/or utilising any of our other Products used in conjunction with our internet-based human capital scoring and delivery platforms. This information might but not exclusively include; your opinions, views, what you consider your strengths and preferences
• Information that you provide us with for the purpose of subscribing to our email notifications and/or newsletters;
• Information you provide when you request Products and/or services;
• Information provided in completing surveys, questionnaires and/or focus groups that we use for research purposes to give us your insights into our Products and services, or responses to our questions and/or testimonials
• Information submitted when you enter any competitions, events or promotions sponsored by ourselves;
• Information you provide when you contact our support team to report a problem or have an enquiry. Sometimes, we monitor or record these interactions for training purposes and to ensure a high quality of service.
• Purchase information you provide when placing an order or making a purchase of our Products, goods and/or services or any other transactions that you enter into through our Products. Information which may be collected in this instance includes your name, email address, contact phone number, physical address and card/payment details;
• We also collect and process your chats with employers and other users as well as the content you publish, as part of the operation of our Products.
• We may, on occasion, acquire information from third parties (e.g. credit reference agencies) who are legally entitled to disclose that information to us.

In summary typically but not exclusively the information we collect about you above when using or interacting with our products is used for the following reasons:

• administration of our Products including notifying you about changes to our services;
• personalisation of the Products and services for you to ensure that content from our Products is presented in the most effective manner for you and your computer, tablet or smart phone;
• enabling your access to and use of the Products;
• providing you with services, and/or goods and products purchased through the Products;
• billing i.e. sending you invoices and statements;
• collecting payments from you;
• providing you with, on request, personalised computer-generated reports following completion of any of our online assessment instruments or questionnaires;
• sending you marketing communications including promotions, surveys and exclusive opportunities offered by us, where you have consented to being contacted for such purposes;
• resolving complaints or responding to enquiries submitted via our Products;
• maintaining and supporting any registered account you may have with us including facilitating your access and providing you with resources and tools/materials available to you;
• seeking your views on products and/or services;
• engaging in research and analysis in order to maintain and improve our Products and services including developing new products;
• providing you with information about further Products such as but not exclusively, assessments, human capital systems and services we offer which are similar to those that you have already purchased or enquired about;
• providing Job Seekers and Employers with the relevant information needed to contact and engage one another in an agreed manner
• using information collected through completion of any of our profiling or assessment instrument questionnaires for research purposes in order to produce statistics such as norms and validity data. You will be asked for your consent prior to this data being collected and can elect to provide it or not. Any data collected is used only for research purposes in the anonymised and aggregated form (i.e. no individual is identified or identifiable from such data);
• sharing your information with third party vendors performing functions on our behalf (e.g. vendors who analyse data, assist us with customer service or process credit card payments); and
• keeping our Products secure and preventing fraud.

Prospective Employers, clients/customers or individuals signed up to use our Products as someone offering employment are entitled to use the personal information we provide to them as part of our services for their own purposes. They are however obliged to process such personal information in accordance with their own obligations under the Act, GDPR and other data protection laws as applicable and in accordance with our Terms and Conditions of Use. You will have rights to the manner in which our clients/customers process such personal information provided by us to them.

Information collected from others

In addition to the information you directly provide us with we do collect information from others concerning you including:

• Other Users – Such as employers and/or candidates may provide information about you as they use our Products. For instance they may rate their interaction with you following a connection in relation to a job or we may collect information about you if they contacted us regarding yourself.
• Other partners – We may receive information about you from our partners. For instance where we have placed an advert on a partner’s website, they may pass along details in reference to a campaigns success.

Disclosure of personal information

The information held within our system concerning yourself is stored in a secure database and kept private. Access to that information stored under your account is protected by your username and password. It does not form part of our jobseekers / candidate database and cannot be searched or accessed by anyone else.

Since our main objective is to link job seekers and employers or those offering employment, the main sharing of users’ information is, of course, with these employers or individuals offering employment. We also share some users’ information with service providers and partners who assist us in operating our Products and, in some cases, legal authorities.

Provided you maintain the security of your username and password, no one other than those listed below will be able to access your information.

We will not disclose your personal information to third parties except:

• Employers in the context of the provision of our services to them in connection with the Infinitely People Products and/or assessments and/or human capital Platforms in which you have participated in and to which they are signed up to. When you set up an account with us, you share information with employers or those offering employment when you voluntarily disclose information on our Products (such as but not exclusively creating a profile). Please be careful with your information and make sure that the content you share is information that you are comfortable being publically viewable since neither you nor us can control what others do with your information once you have shared it.
• any of our employees, officers, subcontractors, professional advisers, agents, and suppliers insofar as reasonably necessary for the purposes set out in this policy, each of which is subject to GDPR act, as applicable;
• Any third parties which assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing, security operations and any parties necessary to fulfil your orders for our Products;
• to suppliers and licensors that process data on our behalf;
• where an individual completes one of our instruments under the direction of our qualified customers and we perform a service of scoring that instrument for the client/customer, we will send the individual’s results to that client/customer in order for them to provide appropriate feedback to the individual who completed the instrument;
• for anonymous research purposes using the information provided for statistical analysis of large groups of individuals. From this research you will not be identified or identifiable and we will not contact you in connection with this;
• where we believe, in good faith, that it is necessary to comply with any applicable law, or to protect our safety, that of our customers, their clients or the public;
• in connection with any ongoing or prospective legal proceedings or to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention or credit risk reduction); and
• if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control we may transfer your data

We follow a strict vetting process prior to engaging any service provider or working with any partner. All of our service providers and partners are required to agree to strict confidentiality obligations.

PLEASE NOTE: Your current employer may be a customer/client of Infinitely People, or a client of one of our customers/clients. Infinitely People cannot guarantee to restrict the customers or employers who access profiles on our Products or databases and cannot be held responsible for any eventuality.

Length of storage of information

In accordance with the Act, no personal data should be kept for any longer than is necessary for the purpose for which it is collected. This means that information is destroyed/erased from our systems when it is no longer required. Generally we keep information and personal data for no longer than is necessary to provide our service or until you ask us to delete your personal details. We may however, delete, destroy or anonymise information about you as we consider appropriate from time to time. To protect the safety and security of our users on and off our Products we implement a safety retention window of 3 months following account deletion. During this period the account will be retained but not visible on the Products

In relation to personal and sensitive personal information collected as a consequence of the use of our Products, which contain assessment type questionnaires or other user / participant information, this information is generally retained for a period of 12 months after which it is needed and then deleted. After that period you will be unable to access candidate/user/participant information or previous reports and consequently should a candidate report be required, the candidate will be required to complete a new questionnaire / assessment from which a new report may be generated.

Any information retained on our system after 12 months is for research or technical purposes (i.e. statistics, validities or compilation of norm groups) and no longer constitutes personal data. The data is anonymised and aggregated on our system at which point no individual is identified or identifiable from such data and the data no longer falls within the scope of the Act. Consequently after the expiry of the 12 month retention period it will not be possible to order new reports or order reprints of previously ordered reports as the personal data of a user would have been deleted.

In practice, we delete or anonymize your information upon deletion of your account (following the safety retention window) or after one year of continuous inactivity, unless:

1. we must keep it to comply with applicable law or regulation (for instance, some “traffic data” is kept for one year to comply with statutory data retention obligations);
2. we must keep it to evidence our compliance with applicable law (for instance, records of consents to our Terms, Privacy Policy and other similar consents are kept for five years);
3. there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
4. the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behaviour or security incidents from opening a new account.

We may also store the information on our equipment or the equipment of third parties that Infinitely People has a relationship with. Such storage services will be governed by appropriate protections, as required by applicable rules.

Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific timeframe due to technical constraints.

Security of Data and International Transfers

We implement appropriate security policies, rules and technical measures to protect against loss, misuse and alteration of information under our control.

Due to the international nature of our Products we may from time to time appoint third parties to process data containing information about you on our behalf as a data processor, or store such information in, or transfer it to persons, located in countries outside of the European Economic Area ("EEA"). Information that you submit or we collect may consequently be transferred, processed and/or stored on third party data processors located anywhere in the world and outside of your jurisdiction, which may not have data laws equivalent to those in the EEA. Where personal information is transferred outside the EEA, we take all reasonably necessary steps to ensure it is treated securely and that the third parties outside of the EEA provide sufficient guarantees in respect of the technical and organisational security measures and take reasonable steps to ensure their compliance with those measures and in accordance with this Privacy Policy in ensuring our data is adequately protected. However transmission of information via the internet is never completely secure and therefore we cannot guarantee the security of the data submitted on our Products or via other electronic means. By submitting your information you agree to the transfer, storing and processing of your information in accordance with the above.

Cookie usage

If you have a Infinitely People account or use any of the Infinitely People Products, including our website and applications, or visit other websites and applications that use the Infinitely People Products, please be aware we use cookies. The Cookies Policy explains what cookies are, why we use them, what types of cookies are placed on your device when you use our Products and how we use them. By continuing to visit our websites or use our Products, you are agreeing to the use of cookies for the purposes described in the Cookies Policy.

Marketing

We do not send marketing communications to people who are registered as users or participants on our Products. However, if you are a customer or prospective customer who has provided us with your details we may contact you in relation to services/products you may be interested in. You may also receive advertising relevant to you on our online advertising network, in line with our Cookies Policy.

If you do not wish for us to use your personal data for marketing communications, we may send you from time to time, of our Products and/or services please let us know by emailing us at support@infinitelypeople.com. Whilst you are able to opt out of marketing communications, it is not possible to opt out of communications for administrative or operational reasons.

Access to data held about you

We seek at all opportunities to enable you to be take charge of your information and consequently provide for the following:

• Access / Update tools in our Products. Tools and account settings that help you to access, edit, rectify or delete information that you provided to us and that is associated with your account directly within the Products.
• Device permissions. Mobile platforms have permission systems for specific types of device data and notifications, such as phone book and location services as well as push notifications. You can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Doing this may result in you not receiving the full functionality of our Products.
• Deletion. You can delete your account at any point in time by using the corresponding functionality directly on our Products.

You may, subject to applicable law, also have the right to contact us and establish what information we hold concerning you, or access, cancel or correct any information held. If you wish to see a copy of the personal information we hold pertaining to you, you may request this by emailing our Data Protection Officer at support@infinitelypeople.com.

If you wish to see information we hold about you, you will need to complete a Subject Access Request Form, the purpose of which is to ensure that you give us all the necessary information to enable us to comply with your request. You are not required to use this form but if you elect not to we encourage you to ensure that all required information on the form is provided.

In accordance with the act, we may charge you a fee of £10.00 for our costs in providing you with a copy of any personal information we hold about you

Links to other sites

This Privacy Policy applies only to information collected by us. Our Products includes hyperlinks to and details of third party websites and apps. Links within our Products to those of other organisations are not covered by this Privacy Policy. It is advised that if you link to other websites or apps, you read their privacy policies before submitting personal information to those sites. We accept no responsibility or liability for the policies of other websites or apps.

Applicable jurisdiction

This Privacy Policy shall be governed by English Law and you agree that the place of performance of obligations will be England and Wales. Any disputes relating to the policy shall be subject to the exclusive jurisdiction of the courts of England and Wales, except if you are a resident of Northern Ireland you may also bring proceedings in Northern Ireland, and if you are resident of Scotland, you may also bring proceedings in Scotland.

If any provision in this Privacy Policy is for any reason, held by any court or other competent authority to be invalid, unenforceable, illegal in any way either in whole or part, the validity of the remainder of the provision and the other provisions of the policy shall not be affected and will remain in full effect. No delay or neglect by us to enforce this Privacy Policy will be deemed to or will be a waiver or in any way prejudice any of our rights.

Changes to our Privacy Policy

We reserve the right to modify or update this Privacy Policy from time to time to comply with applicable law or to meet changing business requirements without notice to you. Any updates or amendments will be posted on our Products. By continuing to use the Products you agree to be bound by the terms of the updates and amendments and it is your responsibility to ensure you keep yourself up to date with regard to the way we process your personal information.

Contacting us

Any questions you have about our Privacy Policy can be submitted by sending us an email to support@infinitelypeople.com.