Privacy Policy

CooperHire collects some personal data from its Users.

Data Controller of the website https://cooperhire.io and https://cooperhire.de pursuant to Art. 4 (7) of the EU General Data Protection Regulation (GDPR):

CooperHire GmbH
Rheinsberger Straße 76/77
10115 Berlin, Germany
c/o Factory Works GmbH
Managing Director: Sohraab Joshi, Amar Ahlers
Commercial Register: Amtsgericht Charlottenburg, HRB 214774 B
email: [email protected]
Phone: (+49) 176 87799534

This Privacy Policy governs the extent to which CooperHire collects, processes and uses personal data about you. We, therefore, ask you to read the following explanations carefully. This Privacy Policy is only valid for this website. The website might contain cross-references ("links") to other websites of third-party providers. Our Privacy Policy does not apply to websites of third parties. For this reason, users should carefully read the privacy policies of third party websites collecting your personal data.

Types of Data collected

CooperHire is an application allowing Clients to manage, organise and filter applications submitted by Recruiters for a specific vacancy. Furthermore, Recruiters can apply for specific jobs through the apply form on the website of CooperHire. Unless otherwise specified, all provisions of this Privacy Policy apply without distinction to Clients, Recruiters and other users (jointly referred to as “User” or “Users”).

Each time a User accesses a page of our website and every retrieval of a file access data about that process is stored in a log file on the server. In particular, this applies to the following information:

  • Date and time of the request
  • Time zone difference to Greenwich Mean Time (GMT)
  • Content of the request (concrete page)
  • Access status/ HTTP status code
  • Transferred amount of data
  • Website from which the request was initiated
  • Browser
  • Operating system and its interface
  • Language and version of the browser software
  • IP address

The IP address is stored for the period of use only and will be deleted or anonymized afterwards immediately. This data will neither be used to identify users nor be combined with other data, but serves to provide this website only. CooperHire collects the aforementioned data as this is technically necessary for us to be able to display our website and to ensure the stability and security of the website. The legal basis of this processing is Art. 6 (1) sentence 1 lit. f) GDPR. If you use our website not only for information purposes, you will generally need to provide further personal data, such as name, date of birth, email address, address or telephone number, which we use to provide the respective services. We will collect the relevant personal data only if this is permitted by law (for example, for the performance of a contract or for legitimate interests) or if you consent to the processing of personal data. In case of your consent the legal basis of the processing is Art. 6 (1) sentence 1 lit. a) GDPR. With respect to the performance of a contract the legal basis is Art. 6 (1) sentence 1 lit. b) GDPR. The legal basis concerning processing of your data with respect to legitimate interests is Art. 6 (1) sentence 1 lit. f) GDPR. You may withdraw your consent to the processing of personal data at any time. A revocation has direct influence on the admissibility of the processing of your personal data as soon as directed to us. If the processing of your personal data is based on legitimate interests, you have the right to object to processing the personal data. If you exercise your right of objection, we kindly ask you to explain the reasons why we should not process your personal data. If your objection is justified, we will review the facts and adjust or modify the processing of data or inform you about imperative legitimate reasons for the processing. Among the types of personal data that CooperHire collects, by itself or through third parties, there are: - name, last name and email address of Clients using CooperHire and/or the natural person using CooperHire on the Client's behalf - personal data contained in each Candidate's application documents provided by the Recruiter. The personal data collected of Candidates submitted by Recruiters, who use CooperHire autonomously and for their own scopes in particular to apply for a specific job, are all those included in their personal professional profiles and/or application documents, including: name, surname, place of domicile, e-mail address, date of birth, gender and photograph, previous academic and professional experiences and background, personal skills (such as languages spoken), personal interests, hobbies, social media accounts, certificates, diplomas and other qualifications, preferences in terms of working hours and working places, a presentation video or a video interview and further documents (such as motivation letters, CVs etc.).

The detailed personal data collected will be described in the relevant sections of this Privacy Policy or in a dedicated explanatory text contextually with the data collection. The personal data may be freely provided by the User, or collected automatically when using CooperHire. In case Users set up an account storage of data can be revoked at any time. The specified data and your entire user account can always be deleted in the customer area. You agree to treat personal access data confidentially and not to make such data available to unauthorized third parties. We do not assume liability for misused passwords unless we are responsible for the abuse. You should notify us immediately if you are concerned about a third party having knowledge of your password, if the password is used unauthorized or this seems to be likely. You are responsible for ensuring that your information is accurate and complete and that you notify us of any changes to the information provided. After completing communication with CooperHire you should log out and close the browser window, especially if you share the computer with other people. Any use of Cookies - or of other tracking tools - by CooperHire or by the owners of third party services used by CooperHire, unless stated otherwise, serves to identify Users and remember their preferences, for the sole purpose of providing the service required by the User. Failure to provide certain personal data may make it impossible for CooperHire to provide its services.

Users are responsible for any personal data of third parties obtained, published or shared through CooperHire and confirm that they have the third party's consent or another legal basis to provide the Data to the CooperHire.

Mode and place of processing the Data

Methods of processing

The Data Controller processes the Data of Users in a proper manner and shall take all appropriate technical and organizational security measures to protect the data against manipulation, loss, destruction or unauthorized access by third parties. Our systems are secured against unauthorized access. In particular, your personal data is encrypted by us. We use the coding system SSL (Secure Socket Layer). We expressly point out that despite all technical precautions, the Internet does not allow absolute data security. We are not liable for acts of third parties.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by CooperHire. We transmit your personal data to third parties only if you have consented to the transfer, the transfer is necessary for the performance of the contract, or we are enforced to do so by law. In case we use external service providers to process your personal data (e.g. for IT services, storage of data or optimization of processes) they are carefully chosen and instructed by us. They are bound by our instructions and are regularly inspected. The data provided to our service providers may be used by them to fulfill their tasks only. If we transfer personal data to service providers outside the European Economic Area (EEA), we will do so only if the EU Commission has confirmed that the third country ensures an adequate level of data protection or other appropriate safeguards exist (e.g. EU standard contractual clauses or binding corporate rules).In case Recruiter submits Candidates data for a specific job at CooperHire, respective personal data such as name, contact details and CV are stored at the platform of CooperHire. Furthermore, the data are transferred to the Client offering the respective job. The legal basis of this processing is Art. 6 (1) sentence 1 lit. b) and f) GDPR. By sending an application Recruiters agree that they have obtained the consent of the Candidate to the processing of their personal data by CooperHire and Clients. Personal data will be processed by CooperHire only for the purposes mentioned in this Privacy Policy. Please note, that CooperHire has no influence on the processing of personal data by the Clients. Recruiter holds all responsibility of passing on the data to CooperHire.

Retention time

The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that the Data Controller suspend or remove the data. CooperHire will delete the personal data of Users as soon as the data is no longer necessary for the respective purpose. It may occur that personal data is kept for the time during which possible claims may be asserted against CooperHire (for example statutory limitation period of three or thirty years). Furthermore, CooperHire is required by law to store certain data due to the duties of proof and retention, inter alia with respect to the German Commercial Code, the German Tax Code or the Money Laundering Act. The storage periods can be up to ten years. As personal data are submitted by Recruiters through the website of CooperHire the Client offering the job is responsible for the timely erasure of personal data on the platform according to legal deletion periods. CooperHire will erase or make anonymous these personal data on the platform submitted by Recruiters upon instructions of the Client or, at the latest, twelve month after application of the Candidate.

The use of the collected Data

The Data concerning the User is collected to allow CooperHire to provide its services, as well as for the following purposes: Registration and authentication, Analytics, User database management, Tag Management, Managing contacts and sending messages, Contacting the User and Remarketing and behavioral targeting. The personal Data used for each purpose is outlined in the specific sections of this document.

Rights of Users

You have the right of access, rectification or erasure, restriction of processing, objection to the processing, and data portability with respect to your personal data. We are available for corresponding requests or messages at the specified address below. Please note that the deletion of data is only possible if there are no precluding legal regulations. Information concerning your requests or messages is transmitted in electronic form (by email). Should you use this option of providing information via email, the specified email address (both sender and recipient) will not be used for any purpose other than the provision of information and its documentation. You also have the right to lodge a complaint concerning the processing of your personal data by us with a supervisory authority. If we are legally required to disclose data to local, state, national or international authorities, we will comply with this obligation. We will also disclose information to third parties when required by applicable laws and regulations. In addition, we may disclose information to investigate, prevent, or initiate countermeasures against illegal activities or suspected fraud, or to apply or enforce any of our contracts and licensing rights.

Detailed information on the processing of Personal Data

In addition, personal data is collected for the following purposes and using the following services:

  • Analytics

The services contained in this section enable CooperHire to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics with anonymized IP (Google Inc.)

This website uses Google Analytics, a web analytics service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Google Analytics uses so-called "cookies", text files that are saved on your computer and that allow an analysis of your use of the website. The information generated by cookies about your use of this website is usually transmitted to and stored on a Google server in the USA. However, in the event of activation of IP anonymization on this website, your IP address will be truncated previously by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases, the full IP address will be sent to a Google server in the US and truncated there. On behalf of the operator of this website, Google will use this information to evaluate your use of our website, to compile reports on website activity, and to provide other services related to website activity and internet usage. The IP address transmitted by your browser as part of Google Analytics will not be combined with other Google data. You can prevent the storage of cookies by an appropriate setting of your browser software; however, please note that in this case, you may not be able to use the full range of all functions of this website. You may also prevent the collection of the data generated by cookies and relating to your use of the website (including your IP address) as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de. This website uses Google Analytics with the extension "_anonymizeIp ()". Accordingly, IP addresses are truncated and, thus, a reference to persons can be ruled out. If the data collected about you have a personal reference, this reference is immediately excluded and the personal data is deleted immediately. We use Google Analytics to analyze and regularly improve the use of our website. With the statistics we can improve our offer and make it more interesting for you as a user. For exceptional cases in which personal data is transferred to the US, Google is part of the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. The legal basis of this processing is Art. 6 (1) sentence 1 lit. f) GDPR. Information of third-party provider: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. User conditions: http://www.google.com/analytics/terms/de.html, Overview of data protection: http://www.google.com/intl/de/analytics/learn/privacy.html, and privacy policy: http://www.google.de/intl/de/policies/privacy. This website also uses Google Analytics for cross-device analysis of visitor traffic conducted through a user ID. Personal Data collected: Cookies and Usage Data. Place of processing: US – Privacy Policy – Opt Out.

MixPanel (MixPanel)

MixPanel is an analytics service provided by Mixpanel Inc., San Francisco CA94105, 405 Howard Street, 2nd Floor.
For this purpose, cookies can be used. Mixpanel collects and stores usage data in pseudonymous profiles. The pseudonymous usage profiles, as required by § 15 (3) Telemediengesetz (TMG), are not merged with personal data about the bearer of the pseudonym.
You can object to the collection and storage of data for the purpose of web analysis at any time with effect for the future by deactivating the service by clicking the button "Opt out" below.
In this case, please note that a cookie is set on your device, which ensures that no further data is collected and evaluated by you. Therefore, you should not delete this cookie.
In addition, we use Mixpanel to send targeted push notifications if you have consented to this. In case you no longer want notifications, you can deactivate them at any time.
MixPanel is part of the EU-US-Privacy-Shield, https://www.privacyshield.gov/EU-US-Framework.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy – Opt Out.

Contacting the User

Mailing list or newsletter (CooperHire)

With our newsletter service we inform you by email about our services. This requires your consent.If you wish to subscribe to our newsletter service we ask you to provide your email address. However, before we send you the newsletter you will receive an email notification with a link. By clicking the link you confirm to receiving the newsletter and, hence, you will be included in our distribution list. This ensures that nobody other than you used your email address for subscription to or newsletter (so-called double opt in procedure). If you do not confirm the registration within 96 hours we block your information immediately and delete them automatically after one month. In addition, we only store your IP address as well as the time of registration and confirmation in order to be able to prove your registration and to have the possibility to disclose the misuse of your data. To receive our newsletter you only need to enter your email address, name and surname. Providing further data is voluntary. We store your email address for the purpose of sending our newsletter only. The legal basis is Art. 6 (1) sentence 1 lit. a) GDPR. You may withdraw your consent to receive the newsletter at any time by sending a message to us or simply by clicking the link provided at the bottom of each newsletter. A message in text form to contact details provided below (email, letter) will be sufficient.

Personal Data collected: email address.

Contact

If you contact us via the contact form on our website or by email or fax, the information provided will be stored and processed in order to process the request as well as follow-up questions. We will delete the relevant data after the storage is no longer required or restrict the processing if statutory retention periods exist. The legal basis of this processing is Art. 6 (1) sentence 1 lit. f) GDPR. Our legitimate interest is to answer your request.

Social-Media-Plug-ins

We currently use the following social media plug-ins on our website: Facebook, Twitter, LinkedIn, GitHub. We use the so-called two-click solution. This means that, by visiting our website, no personal data is initially passed on to providers of such plug-ins. The provider of the plug-in can be identified on our website by the corresponding logo. Via the respective button we provide the opportunity to communicate directly with the provider of the plug-in. The plug-in provider only receives the information that you have accessed its website through our online service, if you click on the designated field and activate it. According to the information of the respective provider when using the Facebook plug-in, in Germany the IP address will be anonymized immediately after collection . Please note that by activating of the plug-in personal data about you will be transferred to and stored by the respective plug-in provider (in case of US providers in the USA). Data collection is mainly done by plug-in providers via cookies. So we recommend to delete all cookies on the security settings of your browser before clicking on the button. We have no influence on the collected data and the data processing operations. We are also not aware of the full scope of the data collection, the purpose of the processing and the storage periods. In addition, we have no information on the deletion of the data collected by the plug-in provider. The respective plug-in provider stores the data collected about you in profiles and uses them for marketing, market research and/or tailored design of its website. Such an evaluation is carried out in particular (also for non-logged-in users) for the presentation of tailor-made advertising and to inform other users of the social network about your activities on our website. You have a right to object against the creation of such usage profiles. To exercise, you need to contact the respective plug-in provider. The plug-ins allow us to interact with social networks and other users so that we can improve our offer and make it more interesting for you. The legal basis for the use of the plug-ins is Art. 6 (1) sentence 1 lit. f) GDPR. A transfer of data takes place regardless of whether you have an account with the plug-in provider and are logged-in. However, if you are logged in to the plug-in provider, your data collected from us will be assigned directly to your user account. If you activate the social media button and, for example, link the page, the plug-in provider also stores this information in your user account and shares it publicly with your contacts. For this reason, we recommend to log out regularly after using a social network, but especially before activating a button, as this will prevent you from being assigned to your profile with the plug-in provider. For more information on the purpose and scope of the data collection and its processing by the plug-in provider, please refer to the privacy statements of the relevant provider, which are provided below. You will also get further information about your rights and settings options to protect your privacy. Addresses of respective plug-in providers und URL with privacy policies: Facebook Inc., 1601 S California Ave, Palo Alto, California 94304, USA; http://www.facebook.com/policy.php; further information to the collection of data: http://www.facebook.com/help/186325668085084, http://www.facebook.com/about/privacy/your-info-on-other#applications and http://www.facebook.com/about/privacy/your-info#everyoneinfo. Facebook is part of the EU-US-Privacy-Shield, https://www.privacyshield.gov/EU-US-Framework. Twitter, Inc., 1355 Market St, Suite 900, San Francisco, California 94103, USA; https://twitter.com/privacy. Twitter is part of EU-US-Privacy-Shield, https://www.privacyshield.gov/EU-US-Framework. LinkedIn Corporation, 2029 Stierlin Court, Mountain View, California 94043, USA; http://www.linkedin.com/legal/privacy-policy. LinkedIn is part of the EU-US-Privacy-Shield, https://www.privacyshield.gov/EU-US-Framework. GitHub, 88 Colin P Kelly Jr St, San Francisco, CA 94107, United States; https://help.github.com/articles/github-privacy-statement/. GitHub is part of the EU-US-Privacy-Shield, https://www.privacyshield.gov/EU-US-Framework.

Managing contacts and sending messages

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.

These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

MailChimp (The Rocket Science Group, LLC.)

MailChimp is an email address management and message sending service provided by The Rocket Science Group, LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA. With MailChimp the dispatch of newsletters can be organized and analyzed. If you enter personal information for the purpose of subscribing to newsletters (e.g., email address), the information will be stored on MailChimp's US servers. MailChimp is part of the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. The legal basis of this processing is Art. 6 (1) sentence 1 lit. f) GDPR. There is a possibility that MailChimp may use the pseudonymous data of the recipients of newsletters to improve their own services, e.g. for technical optimization of shipping or statistical purposes. An assignment to a user does not take place. In addition, the data of MailChimp are not used to contact recipients of newsletters. Also, no data will be disclosed to third parties.

If you do not wish to be analyzed by MailChimp, you may unsubscribe from the newsletter using the link provided in the newsletter or by sending a text message to the contact details provided (e.g. email, letter).

We save the data provided by you for the purpose of receiving the newsletter until your cancellation of the newsletter. Thereafter, the data will be deleted both from our servers and from the servers of MailChimp.

Personal Data collected: email address.

Place of processing: US – Privacy Policy.

Registration and authentication

By registering or authenticating, Users allow CooperHire to identify them and give them access to dedicated services. Depending on what is described below, third parties may provide registration and authentication services. In this case, CooperHire will be able to access some Data, stored by these third party services, for registration or identification purposes.

Linkedin OAuth (LinkedIn Corporation)

· Linkedin Oauth is a registration and authentication service provided by Linkedin Corporation and is connected to the Linkedin social network. Candidates can apply for jobs of Clients with their LinkedIn profile without using a CV. For more information please see provision about Social-Media-Plug-ins also.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: US – Privacy Policy.

· Remarketing and behavioral targeting

This type of service allows CooperHire and its partners to inform, optimize and serve advertising based on past use of CooperHire by the User. This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.

In addition to any opt out offered by any of the services below, the User may opt out of a third-party service's use of cookies by visiting the Network Advertising Initiative opt-out page.

Facebook Remarketing (Facebook, Inc.)

Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc., 1601 South California Avenue, Palo Alto, CA 94304, USA, that connects the activity of CooperHire with the Facebook advertising network.

This allows us to display individually tailored and interest-based advertising on Facebook for certain groups of pseudonymised visitors to our website who also use Facebook. For this purpose, a Facebook custom audience pixel is integrated on our website, which stores non-personal data about the use of the website, e.g. IP address, browser as well as source and destination pages. The corresponding information is transmitted to Facebook servers in the USA. Here we can compare whether you have saved a Facebook cookie and belong to the relevant target group. In this case, we will display appropriate ads on Facebook. You will not be personally identified by us or Facebook. The legal basis for the use of the plug-ins is Art. 6 (1) sentence 1 lit. f) GDPR.

Personal Data collected: Cookies and Usage Data. Place of processing: US – Privacy Policy – Opt Out.

Twitter Remarketing (Twitter, Inc.)

Twitter Remarketing is a remarketing and behavioral targeting service provided by Twitter, Inc. that connects the activity of CooperHire with the Twitter advertising network.

This allows us to display individually tailored and interest-based advertising on Twitter for certain groups of pseudonymised visitors to our website who also use Twitter. For this purpose, a Twitter pixel is integrated on our website, which stores non-personal data about the use of the website, e.g. IP address, browser as well as source and destination pages. The corresponding information is transmitted to Twitter servers in the USA. Here we can compare whether you have saved a Twitter cookie and belong to the relevant target group. In this case, we will display appropriate ads on Twitter. You will not be personally identified by us or Twitter. The legal basis for the use of the plug-ins is Art. 6 (1) sentence 1 lit. f) GDPR.

Personal Data collected: Cookies and Usage Data. Place of processing: US – Privacy Policy – Opt Out.

· User database management This type of service allows CooperHire to build user profiles by starting from an email address, a personal name, or other information that the User provides to CooperHire, as well as to track User activities through analytics features. This personal data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that CooperHire can display and use for improving CooperHire. Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on CooperHire.

Intercom (Intercom Inc.)

Intercom Inc.,55 2nd Street, 4th Fl., San Francisco, CA 94105, USA, is a User database management service provided by Intercom Inc. Intercom can also be used as a medium for communications, either through email, or through messages within our product(s). The legal basis of this processing is Art. 6 (1) sentence 1 lit. f) GDPR. In particular, we transmit some of your information (such as your email address and the date of your registration) to Intercom and use Intercom when you visit our website or use our services. Intercom analyzes your use of our website and / or our services and tracks the evolution of our customer relationship so that we can improve our service to you. If you do not want this information to be collected by Intercom or transmitted to Intercom, please contact us. Intercom is part of the EU-US-Privacy-Shield, https://www.privacyshield.gov/EU-US-Framework.

Personal Data collected: email address and various types of Data as specified in the privacy policy of the service. Place of processing: US – Privacy Policy.

Further information about Personal Data

· Recruiters’ liability for Candidates' personal data In order to deliver its Services, CooperHire needs to have access to all personal data and information included in Candidates' application documents submitted to Recruiters. CooperHire shall only process such data as far as necessary to perform and deliver its Services to the Client and Recruiter and shall never retain, transfer, disseminate, make public or resell such data and information for own purposes or for any purpose not expressly authorized by the data subject. By accepting this Privacy Policy, Recruiter and Client expressly acknowledge that they bear the sole liability to inform Candidates about CooperHire's involvement in the application procedure and about the extent, modalities and scopes for which personal data and information relating to Candidates are collected and transferred to CooperHire. The Client and Recruiter further guarantees that all Candidates, whose applications are processed via CooperHire at the Client's request, have consented to such proceeding and commit to deliver evidence about such consent to CooperHire at demand.

· Candidates may withdraw their consent at all times with effect for the future sending a respective communication to the contact details specified above.

Consent can always be revoked through the relevant settings of the Service, or by notifying CooperHire via the contact details specified at the beginning of this document. When subjected to profiling, the Users, in addition to exercising their general rights (see section “Rights of Users”), may also:

  • request information on the profiling procedures adopted by CooperHire;
  • request not to be subjected to decisions based solely on automated processing, including profiling, which produce legal effects affecting the User, or which have a significant effect on him or her.

Cookie Policy CooperHire uses Cookies. To learn more and for a detailed cookie notice, the User may consult the Cookie Policy. Additional information about Data collection and processing Legal action The User's personal data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of CooperHire or the related services. The User declares to be aware that the Data Controller may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data In addition to the information contained in this Privacy Policy, CooperHire may provide the User with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request. System logs and maintenance For operation and maintenance purposes, CooperHire and any third-party services may collect files that record interaction with CooperHire (System logs) use other personal data (such as the IP Address) for this purpose. Information not contained in this policy More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document. The rights of Users CooperHire does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies. Changes to this privacy policy The Data Controller reserves the right to make changes to this Privacy Policy at any time by giving notice to its Users on this page. It is strongly recommended to check this page often. If a User objects to any of the changes to the Privacy Policy, the User must cease using CooperHire and can request that the Data Controller remove the personal data. Unless stated otherwise, the then-current Privacy Policy applies to all personal data the Data Controller has about Users. Information about this Privacy Policy The Data Controller is responsible for this Privacy Policy. Definitions and legal references

Client - A User benefitting of CooperHire's Services acting as potential employer or recruiter.

Candidate - A User benefitting of CooperHire's Services to get potential employment.

Recruiter - A User benefitting of CooperHire's Services acting as facilitator to provide a potential employee.

Data Subject - The legal or natural person to whom the personal data refers.

Data Processor (or Data Supervisor) The natural person, legal person, public administration or any other body, association or organization authorized by the Data Controller to process the personal data in compliance with this Privacy Policy. Data Controller (or Owner) The natural person, legal person, public administration or any other body, association or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of personal data and the means used, including the security measures concerning the operation and use of CooperHire. The Data Controller, unless otherwise specified, is the Owner of CooperHire. Cookies Small piece of data stored in the User's device. Legal information Notice to European Users: this Privacy Policy has been prepared in fulfillment of the obligations under Art. 10 of EC Directive n. 95/46/EC, and under the provisions of Directive 2002/58/EC, as revised by Directive 2009/136/EC, on the subject of Cookies. This Privacy Policy relates solely to CooperHire.

Cookie Policy CooperHire uses Cookies. To learn more and for a detailed cookie notice, the User may consult the Cookie Policy. Additional information about Data collection and processing Legal action The User's Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of CooperHire or the related services. The User declares to be aware that the Data Controller may be required to reveal personal data upon request of public authorities. Additional information about User's Personal Data In addition to the information contained in this privacy policy, CooperHire may provide the User with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request. System logs and maintenance For operation and maintenance purposes, CooperHire and any third-party services may collect files that record interaction with CooperHire (System logs) use other Personal Data (such as the IP Address) for this purpose. Information not contained in this policy More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document. The rights of Users Users have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above. CooperHire does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies. Changes to this privacy policy The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User must cease using CooperHire and can request that the Data Controller remove the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Data Controller has about Users. Information about this privacy policy The Data Controller is responsible for this privacy policy, prepared starting from the modules provided by iubenda and hosted on iubenda's servers. Definitions and legal references Personal Data (or Data) Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number. Usage Data Information collected automatically through CooperHire (or third-party services employed in CooperHire), which can include: the IP addresses or domain names of the computers utilized by the Users who use CooperHire, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment. User The individual using CooperHire, which must coincide with or be authorized by the Data Subject, to whom the Personal Data refers.

Client - A User benefitting of CooperHire's Services acting as potential employer or recruiter.

Candidate - A User benefitting of CooperHire's Services acting as potential employee.

Data Subject - The legal or natural person to whom the Personal Data refers.

Recruiter - A User benefitting of CooperHire's Services acting as facilitator to provide a potential employee.

Data Processor (or Data Supervisor) - The natural person, legal person, public administration or any other body, association or organization authorized by the Data Controller to process the Personal Data in compliance with this privacy policy.

Data Controller (or Owner) - The natural person, legal person, public administration or any other body, association or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of CooperHire. The Data Controller, unless otherwise specified, is the Owner of CooperHire. CooperHire The means by which the Personal Data of the User is collected and processed. Cookies Small piece of data stored in the User's device.

Legal information Notice to European Users: this privacy statement has been prepared in fulfillment of the obligations under Art. 10 of EC Directive n. 95/46/EC, and under the provisions of Directive 2002/58/EC, as revised by Directive 2009/136/EC, on the subject of Cookies. This privacy policy relates solely to CooperHire.