Privacy Policy
Effective Date: June 21, 2019
Your privacy is
important to us and maintaining your trust is our priority.
Mftstaffing, Inc. ("Mftstaffing,"
"we," or "us"), respects your privacy and is committed
to protecting it through our compliance with this Privacy Policy.
This Privacy Policy
describes the types of information we may collect from you or that you may
provide when you visit one of the websites listed below, and our practices for
collecting, using, maintaining, protecting, and disclosing that information.
This Privacy Policy
applies to data we collect:
·
On this Website.
·
In email, text, and other electronic messages between you and this
Website.
·
Through mobile and desktop applications you download from this Website,
which provide dedicated non-browser-based interaction between you and this
Website.
·
When you interact with our advertising and applications on third-party
websites and services, if those applications or advertising include links to
this Privacy Policy.
Capitalized terms
that are not defined in this Privacy Policy have the meaning given to them in
our Terms of Use or in any
other contractual document between you and us.
This Privacy Policy
is provided in a layered format so you can click through to the specific areas
set out below. Alternatively, you can download a pdf version of the
policy here.
The Website is
owned and operated by Mftstaffing, Inc. (“Mftstaffing”), which provides an online job
board that connects employers to job seekers.
It would be helpful
to start by explaining some key terms used in this Privacy Policy:
Non-Personal Data |
“Non-Personal
Data” means data that is not considered Personal Data under applicable law.
We reserve the right to treat data as Personal Data or Non-Personal Data
based on the law applicable to the data and the data subject. |
Personal Data |
“Personal data”
means any information or pieces of information that could identify you either
directly (e.g., your name) or, where required by applicable law indirectly
(e.g., through pseudonymised data, such as a unique ID number). This means
that Personal Data includes things like email/home addresses, usernames, user
generated content, financial information, and health information. It could
also include certain Technical Data (defined below) such as unique numerical
identifiers like your computer’s IP address or your mobile device’s MAC address,
as well as cookies (“Device IDs”), where required by applicable law |
Special
Categories of Personal Data |
This refers to
sensitive Personal Data that reveals racial or ethnic origin, political
opinions, religious beliefs, philosophical beliefs or trade union membership;
Genetic and biometric data; and Data concerning health, sex life or sexual
orientation. |
3) DATA WE COLLECT
ABOUT YOU
Personal Data
As permitted by applicable
law in the country from which you access our Website and use our services, we
may collect, use, store and transfer different kinds of Personal Data about
you. We have grouped these into the following categories of Personal Data:
·
“Identity Data” such as first
name, maiden name, last name, resume/CV, Social Media profile, username or
similar identifier.
·
“Contact Data” such as
billing addresses, email addresses and telephone numbers.
·
“Financial Data” such as
payment card details. However, please note that payment methods (e.g., credit
card number and/or PayPal and/or bank account details) are not collected by us
directly, but by secure payment service providers.
·
“Transaction Data” such as
details about payments to and from you, and details regarding the services that
you have subscribed to in relation to this Website.
·
“Technical Data” such as
Device IDs, your login data, access dates and times, browser type and version,
device information, cookie data, time zone setting and location, browser
plug-in types and versions, operating system and platform and other technology
on the devices you use to access the Website.
·
“Profile Data” such as your
username and password, orders made by you, preferences, user-generated content,
job searches, candidate searches, job applications, feedback and survey
responses.
·
“Usage Data” such as
information about how you use our Website, products and services.
·
“Marketing and Communications Data” such as your
preferences in receiving marketing from us and our third-parties and your
communication preferences.
Non-Personal Data
We also collect,
use and share Aggregated Data such as statistical or
demographic data for any purpose. Aggregated Data may be derived from your
Personal Data but is not considered Personal Data since it does not directly or
indirectly reveal your identity. For example, we may aggregate your Usage Data
to calculate the percentage of users accessing a specific website feature.
If You Fail to
Provide Personal Data Where Required to Provide Services to You
Where we need to
collect Personal Data by law, or under the terms of a contract we have with
you, or a prospective contract, and you fail to provide that Personal Data when
requested, we may not be able to perform the contract we have or are trying to
enter into with you (for example, to provide you with our services). If so, we
may have to cancel the service you have with us (or have requested from us),
and you accept that as a condition of service.
Data That You
Should Not Provide to Us
We do not require any Special
Categories of Personal Data about you. Accordingly, please do not
provide this type of personal data to us.
Mftstaffing as a Data
Processor
Mftstaffing acknowledges
that you have the right to access your personal information. With respect to
Personal Information provided by a client of Mftstaffing to Mftstaffing, we collect such
information under the direction of that client and have no direct relationship
with the individuals whose Personal Information we process. If you are a
customer of such a Mftstaffing client and would no longer like to be serviced by such
client, please contact the client directly. If you seek access or want to
correct, amend, or delete inaccurate data, you must direct such request to that
client (the data controller). If requested to remove data, we will respond
within a reasonable timeframe. We may transfer personal information to
companies that help us provide our service. Transfers to subsequent third
parties are covered by our service agreements with our clients.
We will retain
Personal Data that we process on behalf of our clients for as long as needed to
provide services to our client. Mftstaffing will retain this Personal Data as
necessary to comply with our legal obligations, resolve disputes, enforce our
agreements, and in accordance with our internal record keeping policies.
4) HOW DATA IS
COLLECTED
We use different
methods to collect Personal Data from and about you including, for example:
Direct Interaction
You may give us
your identity, contact, billing and other information by filling in forms or by
corresponding with us by post, phone, e-mail or otherwise. This includes
Personal Data you provide when you:
·
create an account on our Website
·
request information to be sent to you
·
submit your CV/resume to our resume database
·
give us some feedback
·
apply to a job posted on our Website
·
authorize Mftstaffing to connect your account to the account of a "Connected
Site" (e.g., LinkedIn, Monster, Facebook or Twitter), we may be
able to access information you have provided to the Connected Site, such as
content information, timeline feeds, contact and follow lists, network
statistics and updates regarding your Connected Site account
Automated Technologies or Interactions. As you
interact with our Website, we may automatically collect Technical Data and
Usage Data about your equipment, browsing actions and patterns. We collect this
Personal Data and Non-Personal Data by using cookies, server logs and other
similar technologies. We may also receive Technical Data and Usage Data about
you if you visit other websites employing our cookies and other Tracking
Technologies (defined below). For more information regarding our use of
Tracking Technologies, please refer to “Cookies and Similar Technologies”
below.
Third Parties. We may receive Personal Data in the form of
Technical Data and Usage Data about you from various third-parties such as
analytics providers or advertising networks.
Non-Personal Data
Where permitted by
applicable law, we may use your Non-Personal Data for any purpose not
prohibited by applicable law or inconsistent with this Privacy Policy or any
written representation we have made to you at the point and time of the data
collection.
Personal Data
We will only use
your Personal Data where permitted by law. Most commonly, we will use your
personal data in the following circumstances:
·
Where we need to perform the contract, we are about to enter into or
have entered into with you
·
Where it is necessary for our legitimate interests (or those of a third
party) and your interests and fundamental rights do not override those interest
·
Where we need to comply with a legal obligation
·
Where you have given us your consent
Purposes for Which
We Use Your Personal Data
In the table below,
we have described (i) in what context your personal
data was collected, i.e., what activity you were involved in when we collected
or used your personal data; (ii) the types of personal data that we hold about
you; (iii) how and why we use your personal data; and (iv) what our legal basis
is for using your personal data. We will amend the table as required. We have
also identified what our legitimate interests are where appropriate. We have
also provided you with an explanation of some of the terms we use in this
table:
a. ‘Legitimate
Interest’ means our interest in conducting and managing our business, to
enable us to give you the best experience when using the Website, products, and
services. We make sure we consider and balance any potential impact on you
(both positive and negative) and your rights before we process your personal
data for our legitimate interests. We do not use your personal data for
activities where our interests are overridden by the impact on you (unless we
have your consent or are otherwise required or permitted to by law).
b. ‘Performance of
Contract’ means processing your Personal Data where it is necessary for the
performance of a contract to which you are a party or to take steps at your
request before entering into such a contract.
c. ‘Comply with a
legal or regulatory obligation’ means processing your Personal Data
where it is necessary for compliance with a legal or regulatory obligation to
which we are subject.
d. ‘Consent’ means that
you consent to our use of your personal data for one or more specific purposes.
Where we rely on your consent to use your personal data, you have the right to
withdraw that consent at any time. You can do this by contacting us at support@mftstaffing.com. However, this will not affect the
lawfulness of any processing carried out before you withdraw your consent. If
you withdraw your consent, we may not be able to provide certain products or
services to you. We will advise you if this is the case at the time you
withdraw your consent.
6) WHO WE SHARE
YOUR DATA WITH
We require all
third-parties to respect the security of your personal data and to treat it in
accordance with the law. We do not allow our third-party service providers to
use your Personal Data for their own purposes and only permit them to process
your personal data for specified purposes and in accordance with our
instructions.
Personal Data
We may share
Personal Data with the following parties:
Internal Parties
·
Companies within our corporate family that comprise the Mftstaffing
Group. Access to your Personal Data will be controlled and only granted
where necessary to provide our services to you and/or to allow us to perform
any necessary or legitimate functions.
External Third-Parties
·
Service providers that we use to support our business and help provide
our services to you, including, but not limited to, third-parties that host our
Website, assist us to verify your identity, perform website and platform
maintenance, risk assessments, and security, perform data and web analytics,
provide databases, IT services, customer service, payment platforms and credit
card processing, communication services, and email services
·
Professional advisers such as lawyers, bankers, auditors and insurers
who provide consultancy, banking, legal, insurance, financial, auditing, and
accounting services to us so we can operate our business
·
Taxing authorities, such as the Internal Revenue Service and other
authorities acting as processors based in the United States, the United Kingdom
and other applicable countries, who require reporting of processing activities
in certain circumstances
·
Fraud prevention and identity verification services where we believe
that disclosure is necessary or appropriate to protect the rights, property, or
safety of Mftstaffing, our customers or others. This includes exchanging information
with third-parties for the purposes of fraud detection and prevention and
credit risk reduction
·
In connection with or during negotiations of any proposed or actual
financing, merger, purchase, sale, sale or transfer of some or all of our
assets or stock, joint venture, or any other type of financing, acquisition or
business combination of our company(ies), or all or
any portion of our assets, or transfer of all or a portion of our business to
another company, including without limitation in the event of a
divestiture, restructuring, reorganization, dissolution or other event, whether
as a going concern or as part of bankruptcy, liquidation or similar
proceeding. In the event of a merger, divestiture, restructuring,
reorganization, or other sale or transfer of some or all of our assets or
stock, Personal Data that we hold about our clients and users of our services
will be one of the assets that will be transferred. If a change happens
to our business, the new owners may use your personal data in the same way as
set out in this Privacy Policy
·
Third-parties where you have expressly consented to the disclosure of
your Personal Data
·
Law enforcement agencies, courts, supervisory authorities, regulatory
bodies and certain other third-parties, to the extent that we are permitted or
required to do so by law, or in order to comply with our legal and regulatory
obligations, or in the interests of national security, or to respond to
verified requests relating to a criminal investigation or alleged or suspected
illegal activity
·
To enforce our Terms of Use and other
agreements with you, to respond to, and defend ourselves against, claims
asserted against us, to protect the rights, property, or safety of Mftstaffing, our
services, customers or others, or to investigate, prevent, or take action
regarding suspected or actual illegal activities or for debt collection
·
If you are a job seeker, we will share your personal data with
prospective employers if you respond to a job advertisement or have opted-in to
our Resume Database. Note: to the extent that you have an
account with Mftstaffing, please ensure that the resume associated with your account
is up-to-date so when you apply for a job on a Mftstaffing website, the employer
receives your most recent resume. You will have an account with Mftstaffing if you
opened an account yourself, signed up for job alerts, submitted your resume to
the resume database, and/or applied for a job on the Mftstaffing website. You can
delete and upload new resumes by going to the ‘Profile’ settings in your
account.
·
You can opt-out of your information being available in our Resume
Database at any time by updating this preference on the My Profile tab of your
Job Seeker account
·
Upon your authorization, the Services may also post information directly
to the timeline of your Connected Site Account
·
With prospective employers and recruiters (and/or with their external
Applicant Tracking System or similar external system used by such companies to
manage responses to their job postings), if you respond to a job posting
·
From time to time, we may run contests, special offers, or other events
or activities ("Events") on our Services together with a
third-party partner. If you provide information to such third parties, you give
them permission to use it for the purpose of that Event and any other use that
you approve. We cannot control third parties' use of your information. If you
do not want your information to be collected by or shared with a third party,
you can choose not to participate in these Events
·
For any other purpose disclosed by us when you provide the information
or with your consent
Non-Personal Data
Where permitted by
applicable law, we may share your Non-Personal Data for any purpose not
prohibited by applicable law or inconsistent with this Privacy Policy or any
written representation we have made to you at the point and time of the data
collection.
7) HOW LONG YOUR
DATA WILL BE KEPT
We will not retain
your Personal Data for longer than necessary for the purposes set out in this
Privacy Policy. Different retention periods apply for different types of
Personal Data and in determining the appropriate retention period, we consider
several criteria, including, but not limited to, the purpose for which we hold
your Personal Data, our legal, accounting, reporting and/or regulatory
obligations in relation to that Personal Data, e.g., financial or tax reporting
obligations, whether our relationship with you is ongoing, e.g., where you use
more than one of our products and/or services, any specific request you may
have made in relation to the deletion of your Personal Data, or where we have a
legitimate interest in relation to the management of our own rights, e.g., the
defence of any claims. In some circumstances we may anonymize your Personal Data
so that it can no longer be associated with you, in which case we may use such
information without further notice to you. Once you no longer have a
relationship with us, we will retain and securely destroy your Personal Data
subject to the foregoing and in accordance with applicable laws and
regulations. If you request to receive no further contact from us, we will keep
some basic information about you on our suppression list in order to avoid
sending you unwanted materials in the future.
8) COOKIES & TRACKING
TECHNOLOGIES
Mftstaffing and third
parties may use cookies or similar tracking technologies (e.g., pixels,
beacons, scripts, etc.) (“Tracking Technologies”) to analyze
trends, administer the website, track users’ movements around the website, and
to gather demographic information about our user base as a whole. You can
control the use of cookies at the individual browser level, but if you choose
to disable cookies, it may limit your use of certain features or functions on
our website or service. For more information about the types of cookies and
Tracking Technologies that we, and certain third parties use, and why we use
them, and how you can control these, please review our policy regarding Cookie Policy.
We partner with a
third party to either display advertising on our websites or to manage our
advertising on other sites. Our third party partner
may use cookies or similar technologies in order to provide you advertising
based upon your browsing activities and interests. Please note that you will
continue to receive generic ads.
We use mobile
analytics software to allow us to better understand the functionality of our
Mobile Software on your phone. This software may record information such as how
often you use the application, the events that occur within the application,
aggregated usage, performance data and where the application was downloaded
from.
To the extent
permitted by applicable law, we may send you push notifications from
time-to-time in order to update you about any events or promotions that we may
be running. If you no longer wish to receive these types of communications, you
may turn them off at the device level. To ensure you receive proper
notifications, we will need to collect certain information about your device
such as operating system and user identification information.
We use appropriate
technical and organizational measures to protect Personal Data we process about
you.
However, no transmission
of information via the Internet or wireless network can be guaranteed to be
100% secure. As a result, while we strive to protect your Personal Data,
you acknowledge that there are security and privacy limitations of the Internet
which are beyond our control and accordingly, the security, integrity and
privacy of data exchanged between you and us through the Website cannot be
guaranteed.
We have put in
place procedures to deal with any suspected Personal Data breach and will
notify you and any applicable regulator of a breach where we are legally
required to do so.
The safety and
security of your Personal Data also depends on you. Where we have given you (or
where you have chosen) a password for access to certain parts of our Website,
you are responsible for keeping this password confidential. We ask you
not to share your login or account credentials with anyone and keep your
account information secure. We urge you to be careful about giving out
information in public areas of the Website like message boards, where
information will be available to other users of the Website. If you
believe that your access credentials or Personal Data have been compromised,
please contact us immediately.
10) LINKS TO THIRD
PARTY WEB SITES AND SOCIAL MEDIA FEATURES
Our Website may
from time to time, contain links to third-party services such as websites,
locations, platforms, applications or services operated by third parties. If
you follow a link to or otherwise access any of these third-party services,
these third-party services may use their own cookies, web beacons, and other
Tracking Technology to independently collect information about you and may
solicit Personal Data from you. Please note that these third-party
services have their own privacy policies and we do not accept any
responsibility or liability for these parties’ policies or practices.
Please check these policies before you share any Personal Data with these
third-party services.
We may offer you the opportunity to use your social media login when
interacting with our Website. If you do so, please be aware that you may be
sharing your profile information with us. The personal data that is
shared will depend on your social media platform settings. Please visit the
relevant social media platform and review its privacy policy to understand how
your personal data is shared and used in this context.
Social media
features may also collect your IP address, which page you are visiting on our
Website, and may set a cookie or other Tracking Technologies to enable the
applicable social media feature to function properly. Your interactions
with these features are governed by the privacy policy of the company providing
such features.
The Website may
include tools provided by us or third-party services that enable you to send a
message to another person. If you use any such tools, please ensure that
you only send messages to persons to whom you have permission to send
messages. Absent the recipient’s consent, we will only use their Personal
Data that you provide us to facilitate such messages.
You should be aware
that when you voluntarily disclose any Personal Data in a public forum on the
Website, this information, along with any information disclosed in your
communication, can be collected and used by third parties and may result in
unsolicited messages from third parties. Such activities are beyond our control
and this Privacy Policy does not apply to such information. You accept that
you, and not Mftstaffing, are responsible for providing such information in any
public forum. Any submissions to public areas on the Website are accepted by
you with the understanding that such forums are accessible to all third
parties. If you do not want your comments or any content to be viewed by third
parties, you are advised not to make any submissions. Please be careful and
responsible whenever you're online.
We may use your
Personal Data to send you information about the services provided by the Mftstaffing
Group; provided, however that we will obtain consent to do so where required by
applicable law. You may unsubscribe from our marketing e-mails by clicking
"Unsubscribe" in any promotional e-mail communications we send you.
As permitted by applicable law, you cannot opt-out of non-marketing,
services-related notices.
13) CHANGES TO THIS
PRIVACY POLICY
We reserve the
right to change this Privacy Policy at any time. If we propose to make any
material changes, we will notify you by posting notice on the Website or by
issuing an email to the email address listed by registered users prior to the
changes becoming effective. You acknowledge that it is your responsibility to
maintain a valid email address as a registered user, and to review the Website
and this Privacy Policy periodically in order to be aware of any modifications.
If you object to any changes to the revised Privacy Policy, you can stop using
our services and close your account with us. However, if you continue to use
our services (including the Website) after we publish a new or updated Privacy
Policy, you acknowledge that such continued use means that the treatment of
your Personal Data will be subject to the new or updated Privacy Policy.
Our Services and
the Website are not intended for use by persons under the age of 18
years. Mftstaffing does not knowingly collect or solicit Personal Data from
anyone under the age of 13 or knowingly allow such persons to register to use
our Website. In the event that we learn that we have collected Personal
Data of a child under the age of 13, we will delete that data to the extent
required by applicable law as quickly as possible. If you believe that we might
have any Personal Data from or about a child under 13, please contact us
at privacy@mftstaffing.com.