Privacy Policy

WHO IS RESPONSIBLE?

The person responsible in the sense of the UK’s Data Protection Act (“DPA”) and the EU’s General Data Protection Regulation (“GDPR”) is CVFY Recruit LTD of Kemp House, 160 City Road, London, EC1V 2NZ, UK (“CVCollage”, “we”, “us”, “our”). If you have any questions about this policy or our data protection practices, please contact us using contact@cvcollage.com.

PRINCIPLES OF DATA PROCESSING

Personal Data: Personal Data is any information relating to an identified or identifiable natural person. This includes, for example, information such as your name, age, address, telephone number, date of birth, email address, IP address or user behaviour.
Special Category Data: Special Category Data is Personal Data that needs more protection because it is sensitive. This includes Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data. As well as, data concerning health, a person’s sex life; and a person’s sexual orientation. In order to lawfully process Special Category Data, it is necessary to consent to the processing.
Processing: The processing of Personal Data (e.g. collection, retrieval, use, storage or transmission) always requires a legal basis.
Legal basis: In accordance with the DPA and the GDPR, we have to have at least one of the following legal bases to process your Personal Data: i) you have given your consent, ii) the data is necessary for the fulfilment of a contract / pre-contractual measures, iii) the data is necessary for the fulfilment of a legal obligation, or iv) the data is necessary to protect our legitimate interests, provided that your interests are not overridden.
Retention: Processed Personal Data will be deleted as soon as the purpose of the processing has been achieved and there are no longer any legally required retention obligations.

DATA WE COLLECT AUTOMATICALLY

Provision and use of the website: When you visit our website, we collect the Personal Data that your browser automatically transmits to our server. This is technically necessary for us to display our website and to ensure its stability and security. In this sense, we collect the following data: i) IP address of the requesting computer, ii) Date and time of access, iii) name and URL of the file accessed, iv) website from which the access was made (referrer URL), v) browser used and, if applicable, the operating system of your computer as well as the name of your access provider. The legal basis is our legitimate interest.
Hosting: We use the Amazon Cloudfront hosting services of Amazon Web Services, Inc (AWS) for the purpose of hosting and displaying our website. AWS does so on the basis of processing on our behalf, and that also means that all data collected on our website is processed on AWS's servers. The legal basis for processing is our legitimate interest.
Fonts: We use Google Fonts by Google LLC on our website to display external fonts. To enable the display of certain fonts on our website, a connection to a Google server is established when our website is accessed. The connection to Google established when you call up our website enables Google to determine which website sent your request and to which IP address the display of the font is to be transmitted. This represents a legitimate interest.
Cookies: We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. There are different types of cookies: i) Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and ii) Non-essential Cookies. Non-essential Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyse your behaviour on a website (“analytical” cookies) or cookies used to display advertisements to you (“advertising” cookies).
As set out in the UK`s Privacy and Electronic Communications Regulations (“PECR”) and the EU`s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of non-essential Cookies. For further information on the cookies we use, please refer to our Cookie Policy. The legal basis for processing is our legitimate interest and your consent.
Cookie consent: Our website uses a cookie consent tool to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following Personal Data is transferred to us: i) Your consent(s) or revocation of your consent(s); ii) Your IP address; iii) Information about your browser; iv) Information about your device; v) Time of your visit to our website. The basis for processing is our legitimate interest.
Economic analyses and market research: For business reasons, we analyse the data we have on business transactions, contracts, enquiries, browsing behaviour etc. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarised and or anonymised values. For this purpose we use Google Analytics from Google and Hotjar from Hotjar Ltd and you can find more information about Google Analytics in our Cookie Policy. The legal basis is our legitimate interest and your consent.

DATA WE COLLECT DIRECTLY

Contacting Us: We offer you the opportunity to contact us using various methods. We collect the data you submit such as your name, email address, telephone number and your message in order to process your enquiry and respond to you. The legal basis is both your consent and contract.
We also offer to contact us via the messaging services of WhatsApp. If you contact us via WhatsApp we store and use the mobile phone number, you use and - if provided - your first and last name in accordance with the provision of a contractual or pre-contractual measure to process and respond to your request. The legal basis is both your consent and contract.
Live Chat: For the Chat, we use the services of Brevo (formerly Sendinblue). Brevo determines the length of a visitor’s stay on the site and for the live chat length and helps to facilitate the routing of messages via our Chat. We have no knowledge of the storage period of the personal data you submit through the chat and no possibility to influence it. The legal basis for the processing is also your consent.
Registration: If you register, we will request mandatory and, where applicable, non-mandatory data in accordance with our registration form including your full name and email address. The entry of your data is encrypted so that third parties cannot read your data when it is entered. Your data will remain stored for as long as the registration lasts, in particular if the storage is necessary for the fulfilment/execution of the contract, to enforce our rights or for our other legitimate interests or we are required by law to retain your data (e.g., within the framework of tax retention periods).
Contractual Services: We process the Personal Data involved when you enter into a contract with us in order to be able to provide our contractual services. This includes in particular our support, correspondence with you, invoicing, fulfilment of our contractual, accounting and tax obligations. Accordingly, the data is processed on the basis of fulfilling our contractual obligations and our legal obligations.
Our Resume Builder Services: As mentioned above, we process the data involved in your use of our Resume Builder Services (“Service Data”) in order to be able to provide our services. Your Service Data can, depending on your use of our Resume Builder Services, include both Personal Data and Special Category Data such as your contact details, information about your education, qualifications, work experience and skills.
In accordance with the DPA and GDPR, we process your Service Data as Data Processor or in other words on your behalf and in accordance with your instructions. As such we also provide you the ability to (i) access your Service Data, (ii) share your Service Data through supported third-party integrations, and (iii) request export or deletion of your Service Data. For the purpose of providing our Services all Service Data processed will be stored only in your browser.
When you go ahead and download your CV, your IP address is requested and logged for documentation purposes by AWS. This is a mere technical process and required to make your CV available for download to your device or depending on your browser available for viewing. The basis for this storage is the provision of a contract and our legitimate interest.
The legal basis for processing data during the resume builder process is contract and, if you have given your consent, for example by inserting Special Category Data into our resume builder, is consent.
Finally, please also note that you can use our free data cleanup tool to delete CVs and cover letters you have created from your browser's cache.
Support ticket: If you create a support ticket, we will request Personal Data and, where applicable, non-Personal Data in accordance with your request, this may include your name, email address and other order related data you voluntarily provide. The data provided is not shared with third parties and cannot read your data when it is entered. If you submit a support ticket, we process the data for the purpose of processing and handling your ticket.
Our employees will also have access to data that you knowingly share with us for technical support or to import data into our services. We communicate our privacy and security guidelines to our employees and enforce privacy safeguards strictly. The legal basis of the data processing is our obligation to fulfil the contract and/or our legitimate interest in processing your support ticket.
Administration, financial accounting, office organisation, contact management: We process data in the context of administrative tasks as well as organisation of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.
Payment Data: If you make a purchase your payment will be processed via our payment service provider Stripe. Payment data will solely be processed through Stripe and we have no access to any Payment Data you may submit. The legal basis for the provision of a payment system is the establishment and implementation of the contract.
Promotional use of your data: We use your data within the legally permissible scope for marketing purposes, e.g., to draw your attention to special promotions and discount offers. In addition, we may draw your attention to comparable offers by email, e.g., we may inform you about exclusive sales, promotions, or special events. The legal basis for processing is our legitimate interest.
Aggregated Data: We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose including improving our website and services. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

DATA SECURITY

We undertake to protect your privacy and to treat your Personal Data and Service Data confidentiality. In order to prevent manipulation or loss or misuse of your data stored with us, we take extensive technical and organisational security precautions which are regularly reviewed and adapted to technological progress. These include, among other things, the use of recognised encryption procedures (SSL or TLS).

However, we would like to point out that, due to the structure of the Internet, it is possible that the rules of data protection and the above-mentioned security measures are not observed by other persons or institutions that are not in our area of responsibility. We have no technical influence on this. It is the user's responsibility to protect the data he or she provides against misuse by encrypting it or in any other way.

MARKETING

Insofar as you have also given us your consent to process your Personal Data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.

You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission, or sometimes your consent is implied from your interactions or contractual relationship. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.

Our Marketing generally takes the form of email but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent by us or on our behalf will include a means by which you may unsubscribe or opt out.

ADVERTISING

We would like to show you interesting advertising outside of our website and use various third-party tools and cookies for this purpose. These collect and process information about your activities on our website - for example, which products you are interested in or which pages you visit. By knowing what you are looking for and how you use our website, we can adapt our advertising to your needs. And thus increase the likelihood that you will also be shown suitable and interesting advertising outside our website.

We also analyse this data to evaluate the relevance of the advertisements and to optimise the advertisements for you. Through the tools, your browser regularly establishes a connection to the server of the tool provider when you visit our website. For some tools, we have no direct influence on what data is processed by the providers. The following Personal Data may be processed by third-party providers i) HTTP header information (e.g., IP address, web browser, website URL, date and time); ii) measuring pixel-specific data (e.g., pixel ID and cookie ID); and iii) additional information about visits to our website (e.g., orders placed, products clicked on). The legal bases for processing are our legitimate interest and your consent in case of cookies. For further information, please refer to our Cookie Policy.

INTERNATIONAL TRANSFERS

We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organisational measures to protect the Personal Data we transfer.

HOW WE MAY SHARE YOUR PERSONAL DATA

We may share your Personal Data with our business partners as necessary for the purposes described in this Privacy Policy and within CVCollage for the purposes described in this Privacy Policy, including (but not limited to) conducting the services you request, or customising our business to better meet your needs. We share your Personal Data only with business partners who agree to protect and use your Personal Data solely for the purposes specified by us.

We may also disclose your Personal Data for any purpose with your consent or for law enforcement, fraud prevention or other legal actions as required by law or regulation, or if we reasonably believe that we must protect us, our customers or other business interests. Except as described above of which you will be informed in advance, we will not disclose your Personal Data.

WHAT WE DO NOT DO

We do not request Personal Data from minors and children;
We do not use Automated decision-making including profiling; and
We do not sell your Personal Data.

PRIVACY RIGHTS

Under the DPA and the GDPR, you can exercise the following rights:

Right to information
Right to rectification
Right to deletion
Right to data portability
Right of objection
Right to withdraw consent
Right to complain to a supervisory authority
Right not to be subject to a decision based solely on automated processing.

If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us.

UPDATING YOUR INFORMATION AND WITHDRAWING YOUR CONSENT

If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing or want to withdraw any consents you have given us, please contact us.

ACCESS REQUEST

In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

COMPLAINT TO A SUPERVISORY AUTHORITY

You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in the UK is: The Information Commissioner's Office, (www.ico.org.uk). However, we would appreciate the opportunity to address your concerns before you contact any supervisory authority.

HOW DO WE MAKE CHANGES TO THIS POLICY?

We may change our Privacy Policy from time to time. When we change our Privacy Policy, we will publish the updated policy on our website. Please check this Privacy Policy regularly. Subject to applicable law, all changes will take effect as soon as we publish the new Privacy Policy, but where we have already collected information about you and/or where legally required to do so, we may take additional steps to inform you of any material changes to our Privacy Policy and may request that you agree to these changes.

EFFECTIVE DATE

Sunday, 30th of June, 2024