Last updated: 31 January 2024
Thank you for choosing CVGenius, operated by Sonaga Tech Limited, Hamilton, Zweigniederlassung Luzern (“Company”, “Service Provider”, “we”, “us” or “our”), to craft your CV and cover letter. We are dedicated to safeguarding your information and your right to privacy. Your data controller is Sonaga Tech Limited, Hamilton, Zweigniederlassung Luzern. Should you have any queries or concerns about our policy or our practices regarding your personal information, kindly contact us at email@example.com.
Table of Contents
- What information do we collect?
- How do we use your information?
- Will your information be shared with anyone?
- Do we utilise cookies and other tracking technologies?
- How do we manage your social account logins?
- How long do we keep your information?
- How do we keep your information safe and secure?
- Do we collect information from minors?
- What are your privacy rights?
- Settings for do-not-track options
- Do California residents possess particular privacy rights?
- Do we make updates to this policy?
- How can you get in touch with us regarding this policy?
1. What information do we gather?
Personal information you disclose to us
We collect the information you provide us with when opening an account or registering at the Site and 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 aware that in certain instances, supplying some personal information may be necessary to use our service. Otherwise, we may not be in a position to provide our Services. This relates specifically to your email address (if you choose to register the account) and the information you provide whilst using our Services.
The information that we gather 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 gather may comprise, though is not confined to, the following:
Information provided by you: We gather data provided by you when using our Services, that may be, for instance, first name, last name, email address, telephone number, address, the information you input into our tools (professional experience, details about your education, skills), but also collected from surveys, CVs and other job application data and other similar data.
Credentials: We collect passwords, password hints, and similar security information used for authentication and account access.
Social media login data: We offer you the option to register using social media account details, such as your Facebook or another social media account. If you choose to register in this manner, we will gather 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 comprise device and usage information, such as your IP address, browser and device features, 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 chiefly required 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 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 register with us. Examples of the data collected from this service are your email, first name, surname, and login information from those third parties.
2. HOW DO WE USE YOUR INFORMATION?
We use personal information gathered through our Services for a variety of purposes as detailed below. We process your information for these purposes based on our legitimate business interests, to enter into or carry out a contract with you, with your consent, and/or to comply 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 for the following purposes:
- 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 account creation and login 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 at any time (see ” WHAT ARE YOUR PRIVACY RIGHTS” below). Marketing emails from our partners will only be sent to you if you give your permission.
- To provide you with our Services: to respond to your questions and enquiries; (ii) provide customer support, (e.g. to fulfil product and service orders made by you, give you information about your account to resolve disputes, issues with your account/profile or the Site, administer a contest, sweepstake or promotion. We may use your details to send you information on a product, service, and new feature and/or information about changes to our terms, conditions, and policies,(iii) request feedback and contact you about your use of our Services.
- To post testimonials We publish testimonials on our Services that might include user information. Before posting a testimonial, we will ask your permission to use your name and testimonial. If you would like to update or remove your testimonial, kindly get in touch with us at firstname.lastname@example.org, and make sure you provide your name, testimonial location, and contact details.
- Administer prize draws and competitions: We may use your information to administer prize draws and competitions when you choose to take part.
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).
- 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 utilise and store this information in aggregated and anonymised 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 share information with:
- Suppliers, consultants, and other third-party service providers. We may share your data with third-party vendors, service providers, contractors, or agents who carry out services for us or on our behalf and require access to such information to do that work. Examples include payment processing, data analysis, email delivery, hosting services, customer support, and marketing efforts. We may permit chosen third parties to use tracking technology on the Services, which will enable them to gather data about how you engage with the Services over time. This information may be used to, amongst other things, analyse and track data, determine the popularity of specific content, and better understand online activity. We may also share your information with third parties if the activity is recognised to be unlawful, fraudulent, or poses a potential risk to security. Unless stated in this Policy, we do not share any of your information with third parties for their marketing purposes. We have contracts in place with our data processors and have instructed them to hold your data securely and use it only for the purpose set out in the contract.
If you are an EU resident, please note that we are cooperating with suppliers all over the world. That is why your data may be transferred outside European Economic Area (“EEA”). We take every precaution to ensure your data is secure. This 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 email@example.com
- 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. This may only occur in accordance with applicable laws, for instance, when, after the assessment carried out by the parties to the transaction, such legitimate interest is not overridden by your interest or fundamental rights and freedoms.
Business partners We may share your information with our business partners to offer you certain products, services, or promotions.
5. HOW DO WE HANDLE YOUR SOCIAL ACCOUNT LOGINS?
Our Services offer you the ability to register and log in 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, 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), then 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 want to withdraw your consent, please contact us.
7. HOW DO WE KEEP YOUR INFORMATION SECURE?
We have implemented suitable technical and organisational security measures designed to protect the security of any personal information we process. However, please also bear in mind that we cannot guarantee that the Internet itself is 100% secure. Whilst we will endeavour to safeguard your information, the 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 firstname.lastname@example.org.
8. DO WE GATHER INFORMATION FROM MINORS?
We do not knowingly solicit data from or market to children under 18 years of age. By utilising the Services, you represent that you are at least 18. If we discover that information from users under the age of 18 has been gathered, we will deactivate the account and take reasonable steps to promptly remove such data from our records. If you become aware of any data we have collected from children under the age of 18, please contact us at email@example.com.
9. WHAT ARE YOUR PRIVACY RIGHTS?
Based on the laws of certain 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 access, update, or remove your personal information, kindly submit a request by clicking here. You can also make your request by sending an email to firstname.lastname@example.org, or contacting one of our representatives through the telephone number provided here. We shall respond to your enquiry within the timeframe provided by law.
In some areas (such as the European Economic Area), you have specific rights under relevant data protection laws. These may include the right (i) to request access and obtain a copy of your personal data, (ii) to request data rectification or erasure; (iii) to restrict the processing of your personal data; and (iv) the right to withdraw consent; (v) right to object; and, if applicable, (vi) to data portability. In particular situations, you may also have the right to object to the processing of your personal data. To make such a request, please submit a request by clicking here or send us an email to email@example.com or use the contact details provided in Section 13, below. You also have a right granted by Article 77 of GDPR to lodge a complaint with the relevant data protection authority. This complaint may be lodged where the data protection breach occurred, at your place of work or 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 affords us the right to decline and/or levy a fee for requests deemed to be manifestly unfounded or excessive. We will consider and act upon any request in accordance with applicable data protection laws. For purposes of this section, your data controller is Sonaga Tech Limited, Hamilton, Zweigniederlassung Luzern.
We have appointed EDPO, Avenue Huart Hamoir 71 – 1030 Brussels, Belgium, as our EU representative for GDPR purposes. If you wish to exercise your rights regarding your personal data, you may do so by sending an email to firstname.lastname@example.org
We value the privacy of our customers and endeavour to comply with all applicable privacy laws, including UK GDPR. All rights referred to in Section 9 apply accordingly to UK inhabitants. We have appointed EDPO UK, 8 Northumberland Avenue – WC2N 5BY London, UK, as our UK privacy representative. You may contact us through our representative and exercise your rights by sending an email to email@example.com
If we are relying on your agreement to process your data, you have the right to revoke your consent at any time. Please note, however, that this will not affect the lawfulness of the processing prior to its withdrawal.
If you have any queries or remarks regarding your privacy rights, you may email us at firstname.lastname@example.org.
If you would at any time like to review or change the information in your account or terminate your account, you can:
■ Log in to your account settings and update your user account.
■ Contact us using the contact details 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 whilst registering an account with the site;
■ Access your account settings and update preferences; or
■ Contact us using the contact details below.
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO CALIFORNIA RESIDENTS HAVE PARTICULAR PRIVACY RIGHTS?
There are 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, subject to some exceptions, you have the following rights:
- The right to request the 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 about how we have handled your personal data in the prior 12 months which include the categories of personal data collected and sources of personal data, the business purposes for collecting and selling personal data, the categories of third parties with whom we have shared your personal data, the categories of personal data that we have disclosed with a third party for a business purpose, the categories of personal data collected, the categories of third parties to whom your personal data has been sold and the specific categories of personal data sold to each category of third parties.
We may collect and share for business purposes 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, employment, and employment history;
- Protected categories – characteristics of protected categories 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 bought, 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 – accurate geographical location information about a specific individual or device;
- Employment history – professional or employment-related information;
- Education information – information about educational history or background; and
- AudioVisual – audio, electronic, visual, thermal, olfactory, or similar information.
- Inferences drawn from any of the information identified above 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 data 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 email@example.com or contacting us at the freephone number in the Contact us section below. CCPA forbids a business from any form of discrimination against California residents who exercise their CCPA rights.
12. DO WE MAKE UPDATES TO THIS POLICY?
13. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have queries or remarks about this policy, you may contact us by ringing 0808 196 2674 (available Monday to Friday, 8am–12am (midnight)), by sending an email to firstname.lastname@example.org, or by post to Sonaga Tech Limited, Hamilton, Zweigniederlassung Luzern, Hertensteinstrasse 51, 6004 Luzern, Switzerland.