Candidate Privacy Policy

Last reviewed: May 9, 2018

What Personal Data (“Your Personal Data”) are we Collecting?

  • Data that you (“You”, “Your”) input during the application process or job alert creation (contact information, experience and education, attachments, screening questions answers).
  • Your IP Address.
  • Your login information (email address and encrypted password) for your Candidate Portal.
  • Cookies, which allow us to know how our services are accessed and used (i.e. the pages of our website that You visit, which career sites and job boards You visit, which application processes You have started).

What is the Purpose of Collecting Your Personal Data?

  • Help You manage Your job opportunities : when You apply, You have access to a Candidate Portal, where You can find Your profile information and applications information and receive jobs suggestions. In this case, we are the data controller.
  • Help our customers (“Customer”) find their next hires : when You apply, our Customer (the recruiter or hiring manager) can consider You for any job opportunities they have and can use any SmartRecruiters tools to track, manage and make a decision. In this case, the Customer is the data controller.

Because SmartRecruiters offers You real choice and control over how You use Your Personal Data, and wants to build trust and engagement with You, consent is the legitimate basis for processing Your Personal Data.

You can withdraw Your consent at any time by either withdrawing Your application or deleting Your profile.

SmartRecruiters is not a headhunting company. We only provide a talent acquisition technology to our customers and the services to You as mentioned above.

How Your Personal Data will be used?

  • You can set up a personal account (“Candidate Portal”) which allows  You to manage Your job opportunities and track your different applications of several Customers.
  • In Your Candidate Portal, which is accessible on, You may register through the email you received after applying, or if your consent was requested. This is operated by SmartRecruiters under  its own responsibility. The registration requires your email address and a password.
  • Your profile will be made available and visible to the Customer to which you applied.
  • In order to provide world-class services to You and the Customer, SmartRecruiters uses third-party providers to help perform statistical analysis, technical support and data hosting.
  • Your Personal Data might be transferred to a third-party vendor with whom the Customer has a relationship with (for example, in the case of an assessment, video interviewing, onboarding, etc.). The responsibility to comply to the Data Protection laws falls on the Customer, not SmartRecruiters.
  • Your application information will be collected by SmartRecruiters and be made available to You through the Candidate Portal.
  • You can find more details in Use of Your Personal Data. SmartRecruiters will never sell, rent, or lease the collected Personal Data.

How can You self-manage Your Personal Data?

  • Candidate Portal: You can see all Your profile and applications You’ve made
    • Right to rectification: You can modify Your profile by going to the “My SmartProfile” section.
      Terms - Modify Profile
    • Right to be forgotten: You can withdraw and delete Your profile at each company You applied for.
      Terms - Right to be Forgotten Footer
      Terms - Right to be Forgotten
    • Right to data portability: You can export Your profile in a machine readable format.
      Terms - Export your Profile
    • Right to object to processing: You can decide to not apply via SmartRecruiters
    • Right to restriction of processing: Your Personal Data will be used solely for the purpose of recruiting and You can decide whether or not You create a candidate portal account to help You manage Your applications.
  • If You have any questions on how Your Personal Data is used or how You can self-manage Your Personal Data, feel free to contact

Use of Your Personal Data

SmartRecruiters collects and processes Your Personal Data as follows:

  • Help You manage Your job opportunities : when You apply, You have access to a Candidate Portal, where You can find Your profile information and applications information and receive jobs suggestions. In this case, we are the data controller.
  • Help our customers (“Customer”) find their next hires : when You apply, our Customer (the recruiter or hiring manager) can consider You for any job opportunities they have and can use any SmartRecruiters tools to track, manage and make a decision. In this case, the Customer is the data controller.<

SmartRecruiters may also contact You via surveys to conduct research about Your opinion of current or future SmartRecruiters functionalities and user experience.

SmartRecruiters does not sell, rent or lease the collected Personal Data to third parties.

SmartRecruiters may share Your Personal Data with trusted partners in order to perform usage statistical analysis, customer support, technical operations and provide data hosting services. Our trusted partners are prohibited from using Your Personal Data except to provide these services to SmartRecruiters, and they are required to maintain the confidentiality of Your Personal Data. For more information, please see Onward Transfer.

Our Customer may opt in to use features that assist them in the recruitment process through automated means. For You, this means that Your application is processed and analyzed to identify relevant aspects from Your work history such as previous positions and employers, education history, demonstrated skills, and duration of work. These aspects are then compared against the job published by our Customer to indicate how Your application corresponds with the requirements outlined in the job listing.

These findings help our Customer highlight existing information in Your application. The automated capabilities are used to facilitate the recruitment process, however, any conclusive hiring decisions are ultimately at the Customer’s discretion.

Tracking Cookies

SmartRecruiters may use “cookies” to help You personalize Your online experience. A cookie is a text file that is placed on Your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to Your computer. Cookies are uniquely assigned to You, and can only be read by a web server in the domain that issued the cookie to You.

One of the primary purposes of cookies is to provide a convenience feature to save You time. The purpose of a cookie is to tell the Web server that You have returned to a specific page. For example, if You personalize SmartRecruiters pages, or register with SmartRecruiters site or services, a cookie helps SmartRecruiters to recall Your specific information on subsequent visits. This simplifies the process of recording Your Personal Data, such as Login information. When You return to, the information You previously provided can be retrieved, so You can easily use the SmartRecruiters features that You customized.

You have the ability to accept or decline cookies.

Retention of Your Personal Data

A Customer may decide which data retention period they observe for each country to comply with its legal obligations (for example, if they are required to retain Your Personal Data to comply with applicable local laws) and resolve disputes .

SmartRecruiters will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy.

Onward Transfer

SmartRecruiters uses a limited number of third-party providers in US and in Europe to help to perform usage statistical analysis, customer support and technical operations and provide data hosting services.

Our Sub-processors are:

  • SmartRecruiters Sp. z o.o. (Poland): our branch in Poland is used for operation, maintenance, support and testing of our talent acquisition platform;
  • Amazon Web Services, Inc. is used for hosting of the data. Hosting location is the cluster AWS Germany.
  • SendGrid, Inc. (US) is used to power the sending and receiving of emails from our talent acquisition platform to You and our Customer.
  • Textkernel B.V. (The Netherlands) is used to parse the Candidate’s CV and documents and parse the data into the database field.

SmartRecruiters shall remain responsible in case of onward transfers to third parties. SmartRecruiters shares the Personal Data with these third-party providers to support SmartRecruiters’ Services only. Any other use of the Personal Data by third-party providers is prohibited.

All third-party providers receiving Personal Data from the European Union and/or Switzerland agree to (i) process the Personal Data only to the extent required by SmartRecruiters’ Services and in accordance with SmartRecruiters’ instructions and (ii) comply with the applicable data protection laws for transfer and processing of Personal Data and (iii) provide adequate technical and organization measures to protect the Personal Data.

To this end, we use the European Standard Contract clauses ( with our sub processors in order to guarantee the privacy and the security of Your Personal Data.

When You submit Your application, You agree to this Privacy Policy and, in particular, You expressly agree to the transfer of Your Personal Data for the purposes described in that Privacy Policy.

Security of Your Personal Data

SmartRecruiters is ISO 27001 certified.

SmartRecruiters uses industry-standard technologies when transferring and receiving consumer data exchanged between SmartRecruiters and third parties to help ensure its security. SmartRecruiters’ website has security measures in place to protect the loss, misuse and alteration of information.

Personal Data may be hosted on servers maintained by Amazon Web Services and subject to their security safeguards, which are continuously audited, with certifications from accreditation bodies across geographies and verticals. You can read more about Amazon Web Services’ security and compliance at

Children Under Thirteen

SmartRecruiters does not knowingly collect Personal Data from children under the age of thirteen. If You are under the age of thirteen, You must ask Your parent or guardian for permission to use If a child under 13 submits Personal Data to Company and we learn that the Personal Data is the information of a child under 13, we will attempt to delete the information as soon as possible. If You believe that we might have any Personal Data from a child under 13, please contact us at

Changes to our Privacy Policy

We reserve the right to change this Privacy Policy and our Terms of Use at any time. We will notify You of significant changes to our Privacy Policy by sending a notice to the primary email address specified in Your account or by placing a prominent notice on our site. Significant changes will go into effect following such notification. Non-material changes or clarifications will take effect immediately. We encourage You to check our site and this Privacy Policy for updates.

Disclosure of Your Personal Data

SmartRecruiters may disclose Your Personal Data, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on SmartRecruiters or the site; (b) protect and defend the rights or property of SmartRecruiters; and, (c) act under exigent circumstances to protect the personal safety of users of SmartRecruiters, or the public.

Inquiries – How to Contact Us?

If You have any queries related to one of Your application for our Customer, please contact them directly. You will find the Customer’s contact showed in the Candidate Portal.

If You have any further queries, please send an email to:  at: . SmartRecruiters will respond in a timely manner.

In case of unresolved privacy or data use concern, You have the right to lodge a complaint with Your data protection supervisory authority.


SmartRecruiters, Inc.
225 Bush Street
Suite #300
San Francisco CA 94104

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