Last updated: 26 December 2022
Thank you for choosing CV Genius, owned by Sonaga Tech Limited, Hamilton, Zweigniederlassung Luzern, Switzerland (“Company”, “Service Provider”, “we”, “us” or “our”), to create your CV and cover letter. We are committed to protecting your information and your right to privacy. Your data controller is Sonaga Tech Limited, Hamilton, Zweigniederlassung Luzern, Switzerland. If you have any questions or concerns about our policy or our practices with regard to your personal information, please contact us at firstname.lastname@example.org.
Table of Contents
- What information do we collect?
- How do we use your information?
- Will your information be shared with anyone?
- How do we handle your social account logins?
- How long do we keep your information?
- How do we keep your information safe?
- Do we collect information from minors?
- What are your privacy rights?
- Controls for do-not-track features
- Do California residents have specific privacy rights?
- Do we make updates to this policy?
- How can you contact us about this policy?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
We collect information that you voluntarily provide us when opening an account, or when registering at the Site expressing an interest in obtaining information about us or our products and services, when participating in activities on the Services or otherwise contacting us. Please be informed that, in some cases, providing some personal information will be required to use our service. Otherwise, we may not be in a position to render services. This relates in particular to your email address (if you decide to register the account) and information you provide while using our services.
The information that we collect depends on the context of your interactions with the Site and the Services, the choices you make and the products and features you use. The personal information we collect can include, but is not limited to, the following:
Information provided by you. We collect data provided by you when using our services that may be, for example, your name, surname, email address, phone number, address and/or information you introduced to our tools (professional experience, information about your education, skills), but also collected from surveys, CVs and other job application or similar data.
Credentials. We collect passwords, password hints and similar security information used for authentication and account access.
Social media login data. We provide you with the option to register using social media account details, like your Facebook or another social media account. If you choose to register in this way, we will collect the information described in the section called ‘HOW DO WE HANDLE YOUR SOCIAL LOGINS’ below. All information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Information automatically collected. We may collect certain information when you visit, use or navigate the Site and the Services. This information may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Online identifiers. We collect devices, tools and protocols, such as IP (Internet Protocol) addresses, cookie identifiers, or others such as the ones used for analytics and marketing, device’s geolocation and other similar data.
Information collected from other sources. We may collect information about you from third parties when you use your social media account to sign up with us. Examples of the data collected from these services are your email, first name, last name and login information from those third parties.
2. HOW DO WE USE YOUR INFORMATION?
We use personal information collected via our Services for a variety of purposes as described below. We process your information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on for the reasons described next to each purpose listed below.
We use the information we collect or receive:
- To facilitate account creation and login process. If you choose to link your third-party social media account to your account with us (such as your Google or Facebook account), we may use the information you allowed us to collect from those third parties to facilitate the account creation and log-in process for the performance of the contract. See the section below headed ‘HOW DO WE HANDLE YOUR SOCIAL LOGINS’ for further information;
- To send you marketing and promotional communications. We may use the information you send to us for marketing purposes as this is our legitimate interest. You can opt-out of our marketing emails from us at any time (see the ‘WHAT ARE YOUR PRIVACY RIGHTS’ below). Marketing emails from our partners will only be sent to you if you grant your consent;
- To provide you with our Services: to (i) respond to your questions and requests; (ii) provide customer service, (e.g. to fulfill product and service orders made by you; to give you information about your account to resolve disputes, problems with your account/profile or the Site; to administer a contest, sweepstakes or promotions). We may use your information to send you product, service and new feature information and/or information about changes to our terms, conditions and policies; (iii) to request feedback and to contact you about your use of our Services;
- To post testimonials. We post testimonials on our Services that may contain user information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update or delete your testimonial, please contact us at email@example.com and be sure to include your name, testimonial location and contact information;
- Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in competitions;
- Request feedback. We may use your information to request feedback and to contact you about your use of our Services;
- To protect our Services. We may use your information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention);
- To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond. This is our legitimate interest;
- For location-based services. When you access our Site through your mobile device we may access your location to provide you with location-based services and other personalised content. This is our legitimate interest;
- For other business purposes. We may use your information for other business purposes (this is our legitimate interest), such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
We may process or share data based on the following legal basis:
- Consent. By using the Services, you are contracting with us and agree that we may process your data;
- Legitimate interests. We may process your data when it is reasonably necessary to achieve our legitimate business interests;
- Performance of a contract. Where we have entered into a contract with you, we may process your information to fulfil the terms of our contract;
- Legal obligations. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements);
- Vital interests. We may disclose your information where we believe it is necessary to investigate, prevent or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
If you are an EU resident, please note that we are cooperating with vendors all over the world. That is why your data may be transferred outside the European Economic Area (“EEA”). We are making the best effort to ensure your data is safe. That is why transfer will only take place in accordance with the applicable regulations. To obtain a copy of the relevant transfer mechanism or additional information on the transfers, please address these requests to firstname.lastname@example.org.
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.
4. WHO WILL YOUR INFORMATION BE SHARED WITH?
We share and disclose your information with third parties for the following purposes: advertising, direct marketing and lead generation, allow users to connect to their third-party accounts, cloud computing services, communicate and chat with users, invoice and billing, social media sharing and advertising, user account registration and authentication, web and mobile analytics, website hosting, customer satisfaction, job alerts and provision of services. We may also share your information with third parties if the activity is understood to be illegal, fraudulent or posts a potential threat to security. If we have processed your data based on your consent and you wish to revoke your consent, please Contact Us.
5. HOW DO WE HANDLE YOUR SOCIAL ACCOUNT LOGINS?
Our Services offer you the ability to register and login using your third-party social media account details. Where you choose to do this, we may receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list and profile picture, as well as other information you choose to make public.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
When we have no ongoing legitimate business need to process your information, we will either delete or anonymise it, or, if this is not possible (for example, because your personal information has been stored in backup archives), we will securely store your information and isolate it from any further processing until deletion is possible.
If data is processed based on your consent, we will process it until you withdraw your consent. If you wish to revoke your consent, please Contact Us.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
We have implemented appropriate technical and organisational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the Internet itself is 100% secure. Although we will do our best to protect your information, transmission of information to and from our Services is at your own risk. You should only access the services within a secure environment. Our Data Protection Officer may be contacted by sending an email to email@example.com.
8. DO WE COLLECT INFORMATION FROM MINORS?
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18. If we learn that information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at firstname.lastname@example.org.
9. WHAT ARE YOUR PRIVACY RIGHTS?
Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information or delete it in some circumstances. To request to access, update or delete your personal information, please submit a request by clicking here. You can also make your request by sending an email to email@example.com or contacting one of our representatives through the phone number provided here. We will respond to your request within 30 days.
In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information; (ii) to request data rectification or erasure; (iii) to restrict the processing of your personal information; (iv) right to withdraw consent; (v) right to object and (vi) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please click here, send us an email to firstname.lastname@example.org or use the contact details provided in Section 18 below. You also have a right afforded by Article 77 of GDPR to file a complaint with the competent data protection authority. This complaint may be filed where the data protection breach occurred, at your place of work or your residence.
Please know that some minimal information will be requested for identification purposes and as a safeguard to your privacy before providing access to your personal data. If you do not provide this information, it will affect our ability to provide the information requested in a timely manner. GDPR provides us the right to refuse and/or charge a fee for requests that are found to be manifestly unfounded or excessive. We will consider and act upon any request in accordance with applicable data protection laws. For the purposes of this section, your data controller is Sonaga Tech Limited, Hamilton, Zweigniederlassung Luzern, Switzerland.
If we are relying on your consent to process your information, you have the right to withdraw your consent at any time. Please note, however, that this will not affect the lawfulness of the processing before its withdrawal.
If you have questions or comments about your privacy rights, you may email us at email@example.com.
If you would at any time like to review or change the information in your account or terminate your account, you can:
■ Log into your account settings and update your user account
■ Contact us using the contact information provided
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the ‘Unsubscribe’ link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list. However, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt out, you may:
■ Note your preferences when you register an account with the site
■ Access your account settings and update your preferences
■ Contact us using the contact information below
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
This section exclusively and only applies to users that are California residents in compliance with the California Consumer Privacy Act (“CCPA”). ‘Personal information’, according to the CCPA is ‘information that identifies, relates to, describes, is capable of being associated with or could reasonably be linked, directly or indirectly, with a particular consumer or household.’ California residents have the right to opt out of the sale of their personal information. We do not sell personal information. Under the CCPA we are prohibited from discriminating against California residents for exercising their rights. There are also certain requirements we must meet if any financial incentives are offered to California residents in connection with our handling of their personal information (we improve our offering when the difference in pricing, rates or quality of goods is reasonably related to the value of the California resident’s personal information).
If you are a California resident, you have the following rights (subject to some exceptions):
- The right to request deletion of personal information that we have collected about you.
- The right to request a copy of the specific pieces of personal information that we have collected about you in the last 12 months.
- The right to request that we disclose certain information on how we have handled your personal information in the prior 12 months, which include the categories of personal information collected and sources of personal information, the business purposes for collecting and selling personal information, the categories of third parties with whom we have shared your personal information, the categories of personal information that we have disclosed with a third party for a business purpose, the categories of personal information collected and the categories of third parties to whom your personal information has been sold, and the specific categories of personal information sold to each category of third parties.
- Do not sell. California consumers have the right to opt out of the sale of their personal information.
We may collect and share for a business purpose the following personal information from California residents:
- Name, contact information and identifiers – real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name or other similar identifiers.
- Customer records – electronic customer records containing personal information, such as name, signature, physical characteristics or description, address, telephone number, education or employment history.
- Protected classifications – characteristics of protected classifications under California or federal law such as race, colour, sex, age, religion, national origin, disability, citizenship status and genetic information.
- Purchase history and tendencies – commercial information including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Usage data – Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a California consumer’s interaction with an Internet website, application or advertisement.
- Geolocation data – precise geographic location information about a particular individual or device.
- Employment history – professional or employment-related information.
- Education information – information about education history or background.
- AudioVisual – audio, electronic, visual, thermal, olfactory or similar information.
- Inferences drawn from any of the information identified above to create a profile about a California consumer reflecting the California consumer’s preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities and aptitudes.
The categories above do not address our handling of personal information that is subject to an exemption under Section 1798.145(c) – (f) of the CCPA.
You may submit a deletion, copy and right-to-know request online by emailing us at firstname.lastname@example.org or contacting us at the toll-free number in the contact us section below. CCPA prohibits businesses from any type of discrimination against California residents that exercise their CCPA rights.
12. DO WE MAKE UPDATES TO THIS POLICY?
13. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have questions or comments about this policy, you may contact us by calling us on Phone: 0800 196 2674 (Monday to Friday, 8 AM – 12 AM and Saturdays and Sundays, 10 AM – 6 PM), by sending an email to email@example.com, or by post to Sonaga Tech Limited, Hamilton, Zweigniederlassung Luzern, Hertensteinstrasse 51, 6004 Luzern, Switzerland.