SeaPark Consultancy, Inc. (“SeaPark Consultancy”) is a cloud software company that provides recruiting products and services (the “Services”) to employers that have entered into a written agreement with SeaPark Consultancy (each a “Client” and collectively “Clients”).
At SeaPark Consultancy, we take data privacy seriously. This Policy describes our privacy practices for the activities set out in this Policy, including with respect to users of our Website, suppliers, and job applicants. Please read this Policy carefully, as it outlines how we collect, use, share, and otherwise process personal information from which an individual (and in some jurisdictions, a household) can be identified (“Personal Data”). Additionally, this Policy outlines your choices and rights with respect to our processing of your Personal Data.
This Policy does not apply to the information we process on behalf of our Clients, which is governed by the agreements we have in place with them. If you are a potential candidate, job applicant, or employee, who has submitted data to a Client, the use of your data is governed by the policies of that Client. For detailed privacy information regarding the use of your data by a Client, or to exercise your rights regarding such Personal Data, please reach out to that organization directly. Our Clients control the use of data we process on their behalf and determine their own privacy practices and security settings. SeaPark Consultancy may only access, share, distribute, or otherwise process personal data submitted to us by or on behalf of a Client as provided in the agreement between SeaPark Consultancy and that Client, as instructed by the Client, or as required by law.
We are not responsible for the privacy or data security practices of our Clients, which may differ from those set forth in this Policy.
This Policy does not apply to employees of SeaPark Consultancy.
The Website (as defined below) and Services may contain links to other websites, applications and services maintained by third parties. The privacy and data protection practices of such third parties are governed by the privacy policies of those organizations. Please review the privacy policies of those organizations to better understand their privacy practices.
3. PROCESSING ACTIVITIES
SeaPark Consultancy may process your Personal Data in a number of online and offline circumstances, including, without limitation, when you: (i) visit our websites that display or link to this Policy (the “Website”); (ii) visit our offices; (iii) communicate with SeaPark Consultancy via email, phone, or fax; (iv) interact with SeaPark Consultancy as a representative of a company that provides SeaPark Consultancy with goods or services (e.g. you are a SeaPark Consultancy supplier); (v) fill out a form at a conference or event; (vi) register to attend an event or webinar; (vii) access or download certain content (such as a whitepaper); or (viii) apply for a job at SeaPark Consultancy.
4. COLLECTION OF PERSONAL DATA
4.1 PERSONAL DATA THAT YOU PROVIDE
The type of Personal Data that we may collect from you directly depends on how you interact with SeaPark Consultancy, including, without limitation, via phone, in person, or via the Website, and for what purposes, including as a:
Potential Client: As a potential Client, the types of Personal Data you may choose to provide to SeaPark Consultancy include, without limitation: full name, your email address, job title, company information, mailing address, IP address, general location, telephone number, professional information, device and usage information, unique identifiers and cookie data (as described below in this Section 4), or any other Personal Data that SeaPark Consultancy requests or you elect to provide.
Potential Job Applicant: As a potential applicant for employment, the types of Personal Data you may choose to provide to SeaPark Consultancy include, without limitation: your full name, email address, job title, company information, mailing address, IP address, general location, telephone number, professional and educational information, background information included in a CV/resume, device and usage information, unique identifiers, and cookie data (as described below in this Section 4), or any other Personal Data that SeaPark Consultancy requests or you provide.
SeaPark Consultancy Supplier: As a SeaPark Consultancy supplier the types of Personal Data you may choose to provide includes, without limitation: full name, your email address, job title, company information, mailing address, general location, telephone number, professional information, or any other Personal Data that SeaPark Consultancy requests or you elect to provide.
4.2 PERSONAL DATA WE COLLECT FROM OTHER SOURCES
We also collect Personal Data about you from other sources including third parties from whom we have purchased business contact information and from publicly accessible websites, such as LinkedIn or your company’s website, professional network services, or press releases, which we may combine with Personal Data that you have provided to SeaPark Consultancy. Such Personal Data may include, without limitation, company information, phone numbers, job titles, mailing addresses, email addresses, employment history, and Personal Data available at public facing websites and/or social media profiles. Please note that publicly available information is not considered Personal Data in some jurisdictions.
4.3 DEVICE AND USAGE DATA
When you visit the Website, our servers automatically record information that may include Personal Data. Personal Data we collect may include, without limitation: the web address you came from or are going to, your device model, your operating system, the type of web browser you are using, your internet service provider/mobile carrier, unique identifiers, your IP address, general location your mobile network carrier, the duration of your visit, your time zone, and additional information provided by your web browser or device. Whether we collect some or all of this information depends on the type of device you are using and your device settings. To learn more about what information your browser or device makes available to us, please check the policies of your device manufacturer or software provider. You may be able to control the Personal Data you provide to us through your settings and/or as described below.
4.4 COOKIES, AND OTHER TRACKING MECHANISMS
Cross-Device Use: We and our third party providers, including Google, may use the Personal Data collected about you (whether directly from the Website, through your device(s), or from a third party) to help us and our third party providers identify other devices that you use (e.g., a mobile phone, tablet, other computer, etc.). We and our third party providers also may use cross-device and other information we learn about you to serve targeted advertising on your devices and to send you e-mails.
Third-Party Ad Networks: We also use the Personal Data that we learn about you to assist us in advertising our Services on third-party websites and social media and to assist us in evaluating the success of our advertising campaigns on various platforms. You can control these settings as described below in Section 7.
5. HOW WE USE YOUR PERSONAL DATA
We collect and process Personal Data for the following purposes, such as:
Providing the Website or Services: To provide the Website to you, to communicate with you about your use of the Website, to respond to your inquiries, and for other customer service purposes.
Tailoring Content: To tailor the content and information that we may send or display to you and to personalize your experiences while using the Website.
Recruiting, Hiring, and Evaluating Applicants: to review, assess, recruit, consider or otherwise manage Applicants, candidates and job applications, including:
scheduling and conducting interviews;
identifying candidates, including by working with external recruiters;
reviewing, assessing and verifying information provided, and otherwise screening or evaluating applicants’ qualifications, suitability and relevant characteristics;
extending offers, negotiating the terms of offers, and assessing salary and compensation matters;
satisfying legal and regulatory obligations;
communicating with applicants regarding their applications and about other similar position(s) for which they may be interested;
maintaining applicant Personal Data for future consideration; and
in support of our equal opportunity employment policy and practices.
Contacting you about Potential Positions: to identify other positions for which an applicant may be suited or interested, and to contact applicants about such positions. (If you do not wish to be contacted about potential positions, please let us know using the contact information in Section 11 or as otherwise described in this Policy.)
Marketing and Communications: For marketing, advertising and promotional purposes, for example, we may use your Personal Data, such as your email address, to send you news and newsletters, special offers, events, surveys, and promotions, or to otherwise contact you about services or information we think may interest you. We also use the Personal Data that we learn about you to assist us in advertising ourServices on third-party websites and social media and to assist us in evaluating the success of our advertising campaigns on various platforms.
Improving the Website, Services and Security: To improve the Website and/or Services and for other internal business purposes, such as detecting security incidents, debugging to identify and repair errors.
Research and Analytics: To better understand how users access and use the Website and/or Services in order to improve the Website and/or Services and respond to user preferences, to administer surveys, programs and questionnaires, and for other research and analytical purposes.
Legal Compliance: To comply with legal obligations, as part of our general business operations, and for other business, compliance and administration purposes.
Protecting Rights and Interests: Where we believe necessary to investigate, to prevent or take action regarding suspicious, harmful or illegal activities, suspected fraud, situations involving potential threats to the safety of any person or us or violations of our agreements or this Policy.
Health and Safety: For health and safety purposes, such as contact tracing or including conducting appropriate screenings of applicants and visitors prior to entering or accessing certain locations or premises.
Managing Potential Supplier and Supplier Relationships: SeaPark Consultancy may collect and maintain Personal Data when vetting and reviewing potential vendors, purchasing products or services, or managing its relationships with its suppliers or potential suppliers.
Notice: For other purposes we may notify you of or that you consent to from time to time.
For UK and EU residents, further detail regarding these purposes and the associated lawful bases are set out in the European Addendum available at the following location:
6. DISCLOSING OF PERSONAL DATA
6.1 DISCLOSURE OF PERSONAL DATA
SeaPark Consultancy may disclose Personal Data and other information as follows:
Affiliates: We may disclose the Personal Data to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your Personal Data will be subject to this Policy.
Service Providers: We may disclose Personal Data to third-party service providers who use this information to perform services for us, such as hosting providers, cloud services providers, customer service providers, event planners advisors, consultants, and/or support providers.
Advertising, Social Media and Analytics Providers: We share your Personal Data with advertising, social media and analytics providers as described above.
Webinars, Events, and Other Activities Related to SeaPark Consultancy Offerings: We may offer the following solely or jointly with third parties or partners: webinars, events, whitepaper downloads, or other resources related to SeaPark Consultancy Services. We may share your contact information and interests in these offerings or services with third parties to communicate with you about such resources and SeaPark Consultancy’s offerings.
Credit, Finance, and Background Check Providers: We may share your information with credit, background checking or credit reporting agencies during the recruiting process as described in the notice/consent provided at that time
Additional Disclosures: SeaPark Consultancy may also disclose your Personal Data when you direct us to, or otherwise give your specific consent, or with others for any legitimate business purpose that does not conflict with the statements made in this Policy or applicable law.
6.3 DISCLOSURE OF PERSONAL DATA AS REQUIRED BY LAW, ACQUISITION OR MERGER
We may disclose your Personal Data if we are required to do so by law or we, in good faith, believe that such action is necessary to: (i) comply with the law or with legal processes; (ii) protect and defend our rights and property; (iii) protect against misuse or unauthorized use of the Websites and/or Services; or (iv) protect the safety or property of our users or the public (among other things, this means that if you provide false information or attempt to pose as someone else, information about you may be disclosed as part of any investigation into your actions).
If SeaPark Consultancy goes through a business transition, such as a merger, acquisition, or sale of all or a portion of its assets, your Personal Data may be among the assets transferred.
6.4 AGGREGATE OR DE-IDENTIFIED INFORMATION
We may disclose aggregate, or de-identified information about users for marketing, advertising, research, compliance, or other purposes.
6.5 CROSS-BORDER TRANSFERS
We may transfer your Personal Data across borders to fulfil any of the purposes described in this Policy, which may make that Personal Data subject to applicable laws in those jurisdictions. You may contact us (as set out in Section 7, below) to obtain more information about our policies and practices regarding our transfer of Personal Data across borders, or to ask questions about the collection, use, disclosure or storage of Personal Data by us or our providers. Please visit Section 9 for additional information on how we transfer data in accordance with EU/UK requirements.
7. YOUR PRIVACY CHOICES; ACCESSING AND MANAGING YOUR PERSONAL DATA
You may have the right to change your preferences or exercise certain control over your Personal Data. Where you have consented to our processing of your Personal Data, you may withdraw that consent at any time and prevent further processing by contacting us as described below subject to certain exceptions as described to you and/or allowed by law.
As described above, if you do not wish to receive promotional e-mails from us, you may change your preferences by following the unsubscribe link contained in the e-mail itself or contacting us as described below. Please also note that if you opt out of receiving promotional communications from us, we may continue to communicate with you regarding service-related issues. We maintain and process requests for telephone “do-not-call”, “do-not-mail”and do-not-contact lists as required by law
If you do not wish to continue receiving SMS messages, you may opt-out of receiving mobile message services by replying STOP, STOP ALL, UNSUBSCRIBE, CANCEL, END or QUIT to any mobile message that you have received from SeaPark Consultancy. After sending such message, you may receive an additional mobile message confirming your decision to opt-out.
7.3 COOKIES AND INDUSTRY PROGRAMS
You may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences or by visiting the “Your Privacy Choices” link in the footer of the Website. Please note that blocking or deleting non-essential cookies may affect the Websites’ functionality and that any choice with regards to cookie-based advertising only applies to the web browser and device through which you exercise that choice. If you delete your cookies, you may need to reapply your choices. Additionally, you will still continue to see certain advertising, including potentially from SeaPark Consultancy, even if you opt-out of personalized advertising.
You can also control how participating third-party ad companies use the Personal Data that they collect about your visits to our Websites, and those of third parties, in order to display more relevant targeted advertising to you. If you are in the U.S., you can obtain more information and opt out of receiving targeted ads from participating third-party ad networks at aboutads.info/choices (Digital Advertising Alliance). You may also download the DAA AppChoices (https://youradchoices.com/appchoices) tool in order to help control interest-based advertising on apps on your mobile device). In addition, users in other countries may obtain more information at the following links:
8. GLOBAL PRIVACY
Personal Data collected by SeaPark Consultancy may be stored and processed in the United States or in any other country where SeaPark Consultancy or its affiliates, subsidiaries, or third party service providers maintain facilities. When you provide Personal Data to SeaPark Consultancy, you consent to the processing and transfer of your information within the United States and around the world. We follow data protection laws applicable to us when transferring Personal Data.
8.1 EUROPEAN PRIVACY RIGHTS
A summary of applicable European privacy rights is set out below. You can find a detailed description of such rights as well as more detail regarding how SeaPark Consultancy processes Personal Data in compliance with European laws at the following location: https://www.seaparkconsultancy.com/contact-us.
Lawful Bases for Processing: SeaPark Consultancy will process your Personal Data for the legitimate interests of SeaPark Consultancy, or, when needed, with your explicit consent. If you have provided consent for the processing of your Personal Data, you have the right to withdraw consent at any time, which will not affect the lawfulness of the processing before your consent was withdrawn. SeaPark Consultancy may also process your Personal Data for other legal basis, for example, we may have a legal obligation to process your Personal Data, such as in response to a court or regulator order. We also may need to process your Personal Data to protect vital interests, or to exercise, establish, or defend legal claims.
Data Subject Rights: You have the right to request access to and rectification or erasure of your Personal Data, as well as the right to restrict processing, object to processing, and, under certain circumstances, exercise the right to data portability. You have the right to lodge a complaint as described under Section 9.2 and with a data protection supervisory authority if you believe that we have not complied with the requirements of the EU General Data Protection Regulation or UK law with regard to your Personal Data.
Contacting SeaPark Consultancy: EU and UK individuals with GDPR complaints are encouraged to contact our Data Protection Officer, whose contact information is listed under Section 11.2. Those individuals also have the right to file a grievance directly with their local Data Protection Administrator (“DPA”). To find out more about the relevant DPA’s:
8.2 TRANSFERS OF EU OR UK PERSONAL DATA
SeaPark Consultancy may process your Personal Data outside of your jurisdiction, and in countries that are not subject to an adequacy decision by the European Commission or your local legislature or regulator, and that may not provide for the same level of data protection as your jurisdiction, such as the EEA. SeaPark Consultancy ensures that the recipient of your Personal Data offers an adequate level of protection and security, for instance by entering into the appropriate back-to-back agreements and, if required, standard contractual clauses for the transfer of data, such as those approved by the European Commission (Art. 46 GDPR).
8.3 PRIVACY RIGHTS IN CANADA
The following apply to individuals in Canada:
Consent: We will obtain your consent to collect, use or disclose Personal Data except where we are authorized or permitted by law to do so without consent. For example, we may collect, use or disclose Personal Data without your knowledge or consent where:
the information is publicly available, as defined by statute or regulation;
we are obtaining legal advice; or
we reasonably expect that obtaining consent would compromise an investigation or proceeding.
Other exceptions may apply. Your consent can be express, implied or given through an authorized representative such as a lawyer, agent or broker. Consent may be provided orally, in writing, electronically, through inaction (such as when you fail to notify us that you do not wish your Personal Data collected/used/disclosed for various purposes after you have received notice of those purposes) or otherwise. You may withdraw consent at any time, subject to legal, contractual and other restrictions, provided that you give reasonable notice of withdrawal of consent to us. On receipt of notice of withdrawal of consent, we will inform you of the likely consequences of the withdrawal of consent, which may include the inability of us to provide portions of the Website or other services for which that information is necessary.
Limits on Collection of Personal Data: We will not collect Personal Data indiscriminately but will limit collection of personal information to that which is reasonable and necessary. We will also collect Personal Data as authorized by law.
Limits for Using, Disclosing and Retaining Personal Data: Your Personal Data will only be used or disclosed for the purposes set out herein and as authorized by law.
We will keep Personal Data used to make a decision affecting you for at least one year after using it to make the decision, except to the extent that you delete or remove that information yourself. We will destroy, erase or make anonymous documents or other records containing Personal Data as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the information and retention is no longer necessary for a legal or business purpose. We will take due care when destroying Personal Data so as to prevent unauthorized access to the information.
Access: Upon written request to our Privacy Officer and authentication of identity, we will provide you your Personal Data under our control. We will also give you information about the ways in which that information is being used and a description of the individuals and organizations to whom that information has been disclosed. We may charge you a reasonable fee for doing so.
We will make the information available within 30 days of receiving a written request or provide written notice where additional time is required to fulfil the request. In some situations, we may not be able to provide access to certain Personal Data (e.g., if disclosure would reveal Personal Data about another individual, the Personal Data is protected by solicitor/client privilege, the information was collected for the purposes of an investigation or where disclosure of the information would reveal confidential commercial information that could harm the competitive position of us). We may also be prevented bylaw from providing access to certain Personal Data. Where an access request is refused, we will notify you in writing, document the reasons for refusal and outline further steps which are available to you.
Accuracy: We will make a reasonable effort to ensure that Personal Data we are using or disclosing is accurate and complete. If you demonstrate the inaccuracy or incompleteness of Personal Data, we will amend the information as required. If appropriate, we will send the amended information to third parties to whom the information has been disclosed. When a challenge regarding the accuracy of Personal Data is not resolved to your satisfaction, we will annotate the Personal Data under our control with a note that the correction was requested but not made.
9. ADDITIONAL PRIVACY INFO
SeaPark Consultancy employs reasonable and appropriate physical and logical security measures designed to protect Personal Data. Please be aware that despite these measures, no data security measures can guarantee 100% security.
You should take steps to protect against unauthorized access to your password, mobile device, and computer by, among other things, signing off after using a shared computer, choosing a robust and unique password for each account that nobody else knows or can easily guess, and keeping your log-in and password private. You are responsible for maintaining the security of your password or other form of authentication involved in accessing password-protected or secured resources. In order to protect you and your information, SeaPark Consultancy may suspend your use of the Website and/or services without notice, pending an investigation, if any suspicious activity or security breach is suspected. We are not responsible for any lost, stolen, or compromised passwords or for any unauthorized account activity that may result.
9.2 DATA RETENTION
We will retain your Personal Data as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements, subject to certain exceptions as described to you and/or allowed by law. Our Clients and other third parties may have different practices, and you should refer to their privacy policies.
We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation or other lawful basis.
To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, compliance or other requirements.
9.3 CHILDREN’S PERSONAL DATA
SeaPark Consultancy does not direct any of its communications to, or knowingly collect Personal Data from, children. If we discover that a child has provided us with Personal Data, we will promptly delete such Personal Data from our systems
9.4 CHANGES TO THIS PRIVACY STATEMENT
We reserve the right to change or update this Policy at any time. Changes to the Policy will be posted at this URL. We encourage you to periodically review this Policy for any changes.
10. CONTACT SEAPARK CONSULTANCY
10.1 UPDATING YOUR CHOICES
If you have any questions regarding our Policy, or if at any time after providing your Personal Data to SeaPark Consultancy, you want to change your Personal Data, or if you would like to assert any of the rights listed above, please direct your request to firstname.lastname@example.org, call us at +353 1 8457876, or contact us via postal mail at the contact information listed below