In this case, we are the data controller.
Please remind : when You apply to one of our Customers’ jobs, 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 and is responsible for the process of Your Personal Data and SmartRecruiters is the data processor processing the data on behalf of the Customer.
SmartRecruiters is not a headhunting company. We only provide a talent acquisition technology to our customers and the services to You as mentioned above.
Because SmartRecruiters and its affiliates (“SmartRecruiters”) offer 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.
SmartRecruiters, Inc. adheres to the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. You can find more details here.
- Help You manage Your job opportunities within the Candidate Portal: when You apply to one of our Customers, You have access to a Candidate Portal, where You can find Your profile information and applications information.
- Receive jobs suggestions available from and through SmartRecruiters.
- Conduct surveys: SmartRecruiters may also contact You via surveys to conduct research about Your opinion of current or future SmartRecruiters functionalities and user experience.
- Improve and develop services and products: SmartRecruiters may use the Personal Data to improve and develop its services and products to the extent this is necessary.
In this case, we are the data controller.
Please remind : when You apply to one of our Customers’ jobs, 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 and is responsible for the process of Your Personal Data and SmartRecruiters is the data processor processing the data on behalf of the Customer.
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 click here.
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 www.smartrecruiters.com, 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
SmartRecruiters will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy.
EU-U.S. Privacy Shield Framework & Swiss-U.S. Privacy Shield Framework
SmartRecruiters, Inc. adheres to the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data from European Union member countries, the United Kingdom and Switzerland (https://www.privacyshield.gov/welcome) to the United States. If there is any conflict between the terms of this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.
SmartRecruiters, Inc. is committed to subjecting all Personal Data received from European Union (EU) member countries, United Kingdom and Switzerland in compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (https://www.privacyshield.gov).
SmartRecruiters, Inc. shall ensure that (i) Personal Data is handled, processed, transferred and stored in accordance with relevant Privacy Shield Principles and EU data protection laws, and (ii) adequate safeguards and procedures providing protection to personal data are in place.
Inquiries – Contact under Privacy Shield
The Federal Trade Commission has jurisdiction over SmartRecruiters, Inc. compliance with the Privacy Shield.
SmartRecruiters, Inc. may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
In compliance with the Privacy Shield Principles, SmartRecruiters, Inc. commits to resolve complaints about our collection or use of your Personal Information.
Individuals with inquiries or complaints regarding our Privacy Shield policy should first contact SmartRecruiters at: . SmartRecruiters will respond within 45 days.
In case of unresolved privacy or data use concern, SmartRecruiters, Inc. commits to cooperate with the panel established by the EU data protection authorities (DPAs) and/or the Swiss Federal Data Protection and Information Commissioner, as applicable and comply with the advice given by the panel and/or Commissioner, as applicable with regard to data transferred from the EU and/or Switzerland, as applicable. Such resolution process is at no cost to the complaining individual.
Under certain conditions explained at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, a binding arbitration option before a Privacy Shield Panel may be available to you.
Onward Transfer
SmartRecruiters adheres to the Privacy Shield Principles for all onward transfers of Personal Data from the EU, the United Kingdom or Switzerland and complies with applicable data protection laws.
SmartRecruiters uses a limited number of third-party providers in the 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 (SPOLKA AKCYJNA) Oddzial w Polsce (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.
- Jitterbit, Inc. (US, service optional) is the cloud connector hosted in our hosting location in Germany and used to host and maintain any custom integrations between Customer’s system and SmartRecruiters platform.
- ClickBoarding, LLC (US, service optional) is used by our Customers subscribing to the onboarding add-on.
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, the United Kingdom 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 (http://ec.europa.eu/justice/data-protection/international-transfers/index_en.htm) 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 https://aws.amazon.com/compliance/.
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 smartrecruiters.com. 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.
If You have any queries related to one of Your applications 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 our Data Protection Officer 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.