deftli Privacy Notice

(including GDPR Privacy Provisions)

Effective Date

13th September, 2018

deftli Ltd (“we”, “us”, and “ours”) is committed to protecting your privacy. This Privacy Notice describes how deftli processes Personal Data in its capacity as a controller (i.e. deftli decides what Personal Data is collected and what it is used for) or processor (i.e. deftli only processes the data as per the controller’s instructions), as the case may be. It also describes your choices regarding use, access and correction of your Personal Data.

Definitions

The capitalised terms used in this Privacy Notice but not defined here shall have the same meaning as defined in the Terms of Service.

Who does the Privacy Notice apply to?

This Privacy Notice applies to (i) entities or individuals, excluding End-Users and Users, who have subscribed to our Service(s) and have agreed to the Terms (hereinafter referred to as the “Customer”) and (ii) individuals (“Individuals”) from whom deftli collects data as a controller as specified below.

Any questions?

If you have questions or complaints regarding our Privacy Notice or practices, please contact us at support@deftli.com.

What personal data does deftli collect and why?

Personal Data we collect and process for our own purposes: Collected Data

When you visit our Websites or participate in deftli’s events, deftli may collect information, which may include Personal Data, from individuals, as set out below (collectively referred to as “Collected Data”). For the purposes of General Data Protection Regulation (GDPR), deftli shall be the controller for the Collected Data – this means that deftli decides what Collected Data is processed and why.

When does deftli process Collected Data?

1. Sign-up, billing and Account information.

When you subscribe and sign-up to our Service, we may collect your:

  1. contact information such as name, e-mail address, mailing address, IP address, geographic location, or phone number;
  2. billing information, such as credit card number and billing address;
  3. name and email address when you provide feedback from within the Service; and
  4. unique identifiers, such as username, account number or password.

Subject to this Privacy Notice and the Terms, we will use such data, including without limitation, to:

  1. provide you with the Service;
  2. send you communications from the Service;
  3. assess the needs of your business to determine or suggest suitable Service;
  4. send you requested information about the Service;
  5. respond to customer service requests, questions and concerns;
  6. administer your Account;
  7. send you promotional and marketing communications (where you have requested us to do so); and
  8. facilitate your transactions with other users when you use our Service.
2. deftli recruitment

When you apply for an open position we may collect your:

  1. contact information, such as name, email address, mailing address, phone number, links to your social networking profiles; and
  2. any other information contained in the resume that you submit to us.

Subject to this Privacy Notice, we will use such data to evaluate you for the position that you have applied for or any position that we consider you suitable for at the time of your application or at any later date. Unless you notify us otherwise by emailing  support@deftli.com, we will retain such data for a period of 1 year for archival purposes. If you wish to update the data you provided to us, you may do so by contacting us at support@deftli.com.

We may collect your data from the following sources:

  1. when you apply for a job via our website
  2. When you register your CV on a job board and it matches the skills we are looking for
  3. When you apply for one of our jobs via a job board
  4. When you are referred by a friend / colleague.
3. Events

When you attend an event conducted by deftli, including webinars or seminars, we may collect your contact information such as name, e-mail address, designation and company name.

Subject to this Privacy Notice, we will use such data, including without limitation, to:

  1. assess needs of your business to determine or suggest suitable Service;
  2. send you requested information about the Service;
  3. send you promotional and marketing communications (where you have requested us to do so); and
  4. respond to your questions and concerns.
4. Public forums and Newsletters

When you visit our publicly accessible community forums and blogs, you should be aware that any information you provide in these areas may be read, collected, and used by others who access them. Further, we may collect your:

  1. contact information such as name, e-mail address, mailing address, or phone number;
  2. information about your business, such as company name, company size, business type; and
  3. a short bio about you to identify you as the author of the post. When you actively subscribe to our newsletters, we collect your email address to share our newsletters with you.

Subject to this Privacy Notice, we will use such data, including without limitation, to:

  1. assess needs of your business to determine or suggest suitable Service;
  2. send you requested information about the Service;
  3. send you promotional and marketing communications (where you have requested us to do so); and
  4. respond to your questions and concerns.
5. Clear Gifs and Log Files

We and our third-party advertising partners use technologies such as web beacons in analyzing trends, administering the website, tracking users’ movements around the site, and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.

As is true of most websites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We link this automatically-collected data to other data we collect about you.

Please see our Cookie Policy for further information about our use of cookies and similar technologies.

6. Analytics

Apart from the aforementioned information collected by us, we automatically receive and record certain Personal Data of yours when you visit our websites. This includes device model, IP address, the type of browser being used, usage pattern through cookies and browser settings, query logs and product usage logs. We also collect clicks, scrolls, conversion and drop-off on our websites and Service to render the user journey in real-time. Subject to this Privacy Notice, we will use such data, including without limitation, to:

  1. assess needs of your business to determine or suggest suitable Service;
  2. send you requested information about the Service; and
  3. respond to customer service requests, questions and concerns; and (iv) for analytical purposes.

You authorise deftli and its service providers to perform analytics on such Collected Data, to:

  1. improve, enhance, support and operate the Websites; and
  2. compile statistical reports and record insights into usage patterns.

You acknowledge that deftli uses Collected Data, as the case may be, for the aforementioned purposes.

7. Testimonials

We may post your testimonials/comments/reviews on our websites which may contain your Personal Data. Before to posting the testimonial, we will obtain your consent to post your name along with the testimonial. If you want your testimonial removed, please contact us at support@deftli.com.

8. Marketing communications

We may use your e-mail address, collected as part of Collected Data, to send our newsletters and/or marketing communications about our products and services. Where you have so requested, we will also send you marketing communications about our third-party partners. If you no longer wish to receive these communications, you can opt out by following the instructions contained in the emails you receive or by contacting us at support@deftli.com.

What is our legal basis for processing Personal Data?

Our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it.

However, we will normally collect Personal Data from you only where we need the Personal Data to perform a contract with you, or where the processing is in our legitimate interests or rely upon your consent where we are legally required to do so and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Data from you or may otherwise need the Personal Data to protect your vital interests or those of another person.

If we ask you to provide Personal Data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data).

Similarly, if we collect and use your Personal Data in reliance on our legitimate interests (or those of any third-party), we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, please contact us using the contact details provided below.

Data we process on your behalf: User Data

We only process User Data as per our Customer’s instructions. For purposes of the GDPR, we are the processor and not the controller of the User Data. User Data, as defined in the Terms of Service, means all electronic data, text, messages or other materials, including Personal Data of Users, submitted to the Service by our Customers through their Account in connection with a Customer’s use of the Service, including data collected under “Other Information” and “Mobile Applications” below. Our EEA or Swiss Customers are the “controllers” of that data and are responsible for compliance with the applicable data protection law. We work with our Customers to help them provide notice to their customers concerning the purpose for which Personal Data is processed by deftli.

If you are our Customer from the EEA or Switzerland, then in your role as a controller, you are authorizing, on behalf of you and your authorised agents and End-Users, and representing that you have the authority to provide such authorisation to the processing and transfer of Personal Data in and to other countries which may have different privacy laws from your or their country of residence. We will take all steps reasonably necessary to ensure that the User Data is treated securely and in accordance with this Privacy Notice.

We do not own, control or direct the use of User Data, and in fact we are largely unaware of what information is being stored on our platform and only access such information as reasonably necessary to provide the Service (including to respond to support requests), as otherwise authorised by Customers or as required by law. Unless we explicitly agree otherwise in writing, you will not process sensitive personal data (such as health data) on our platform.

As the controller, it shall be your responsibility to inform the End-Users about the processing, and, where required, obtain necessary consent or authorisation for any Personal Data that is collected as part of the User Data through your use of the Service. As the processors of Personal Data on behalf of our Customers, we follow Customer’s instructions with respect to the User Data to the extent consistent with the functionality of our Service. In doing so, we implement technical, physical and administrative measures against unauthorised processing of such information and against loss, destruction of, or damage to, Personal Data.

Other Information

Where a User uses the Service, we automatically receive and record certain information of such user. This information includes device model, IP address, the type of browser being used, usage pattern through cookies and browser settings, query logs and product usage logs (collectively referred to as “Other Information”).

Mobile Applications

When you download, install and use our Mobile Applications, we automatically collect information on the type of device you use, operating system version, and the device identifier.

Subject to this Privacy Notice, we will use such data to

  1. provide and manage Mobile Application; and
  2. notify you of events relating to your Account activity.
Improving and enhancing our Service

You expressly authorise us and the service providers we use to process the User Data in our systems to:

  1. provide, improve, enhance, support and operate the Service(s) and its availability;
  2. develop new products and services; and
  3. compile statistical reports and record insights into usage patterns.

Social media features

Our web site may include social media features. Where you interact with these features, they may collect your IP address, which page you are visiting on our websites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third-party or hosted directly on our websites. Your interactions with these features are governed by the privacy notice of the company providing them. Please see our Cookie Policy for further information.

Sharing Personal Data

Except as outlined in this Privacy Notice and the Terms of Service, Personal Data contained in Collected Data and User Data will never be sold to or shared with other companies or organisations for commercial purposes.

We process Personal Data in the United States and the European Economic Area (“EEA”) and in other countries through third parties that we may use. You may refer to the Terms of Service for more information on our Sub-Processors. Third parties with whom Collected Data is shared may include third-party payment processors who process your credit card and other payment information for deftli but are otherwise not permitted to store, retain or use such information. Third parties that we utilise to assist in providing the Service with whom User Data may be shared are listed in the Terms of Service (“Sub-Processors”).

All such transfers are covered by the service agreements with the relevant recipients and we have taken appropriate safeguards to ensure that your Personal Data will remain protected in accordance with this Privacy Notice. Further details can be provided upon request.

Subject to the Terms of Service and this Privacy Notice, we have the right to access Customer’s Accounts and to process User Data solely to the extent necessary to provide, enhance and improve the Service, including, without limitation, in response to Customer’s support requests.

Our Sub-Processors will only be given access to Customer’s Account and User Data as is reasonably necessary to provide the Service and will be subject to confidentiality obligations in their service agreements.

How does deftli keep Personal data secure?

We use appropriate technical and organizational measures to protect the Personal Data that we collect and process. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Data.

European Residents Specific Rights

Collected Data

If you are an individual resident in EEA or Switzerland, you have the following data protection rights regarding Collected Data:

  • If you wish to access, correct, update or request deletion of your Personal Data, you can do so at any time by contacting us.
  • You can object to the processing of your Personal Data, ask us to restrict the processing of your Personal Data or request portability of your Personal Data. Again, you can exercise these rights by contacting us.
  • You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), please contact us.
  • Similarly, if we have collected and processed your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority.

If you seek access to, or wish to correct, update, modify or delete Personal Data (hereinafter referred to as a “Request”) which forms a part of Collected Data, please contact us at support@deftli.com. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

User Data

If you seek access to, or wish to correct, update, modify or delete Personal Data (hereinafter referred to as a “Request”) which is part of the User Data and processed by us on behalf of our Customer, you should direct your query to our Customer i.e, the controller. If you are a Customer of our Service and wish to raise a Request on behalf of your Users in connection with User Data, you may email support@deftli.com.   

Other Communications

If you are our Customer, we will send you announcements related to the Service on occasions when it is necessary to do so. For instance, if our Service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of communications which are not promotional in nature. If you do not wish to receive them, you may deactivate your Account.

Retention of Personal Data

If you wish to request that we no longer use your Collected Data, please contact us at support@deftli.com.  

Except as otherwise set out below, Personal Data contained in the User Data is retained and deleted in accordance with the Terms of Service.

Users should contact the relevant Organisation Owner regarding retention or removal of their Personal Data (or any other matter concerning their Personal Data).  If you are unsure how to contact your Organisation Owner please email support@deftli.com for assistance.

Organisation Owners should contact support@deftli.com for assistance regarding the retention or removal of Personal Data (or any other matter concerning the Personal Data) contained in User Data associated with their Organisation Account.

deftli will, in any event, retain Collected Data and User Data as necessary to comply with our legal obligations, for litigation / defence purposes, maintain accurate financial and other records, resolve disputes, and enforce our agreements.

Links to third-party websites

Our website may contain links to other websites that are not owned or controlled by deftli. Please be aware that we are not responsible for the privacy practices of these other websites or third parties. We encourage you to be aware when you leave our websites and to read the privacy policies of each and every website that collects Personal Data.

Children's Personal Data

deftli does not knowingly collect any Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through our websites or Service. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Privacy Notice by instructing their children never to provide Personal Data through our Service or websites without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to us through our Websites or Service, please contact us and we will endeavour to delete that information and terminate the child’s account from our databases.

Amendments

Amendments to this Privacy Notice will be posted to this URL and will be effective when posted. If we make any material changes, we will notify you by means of a notice on this Website prior to the change becoming effective and if you are our Customer, via email (specified in your Account).

Please be aware we will not be notifying you if we amend the Cookie Policy to make addition, deletions or modifications to the list of cookies from time to time to keep the list of cookies current and accurate.

You should frequently visit this Privacy Notice to check for amendments. Your continued use of our websites or the Service following the posting of any amendment, modification, or change to this Privacy Notice shall constitute your acceptance of the amendments to this Privacy Notice.

You can choose to discontinue use of the websites or Service if you do not accept the terms of this Privacy Notice, or any modified version of this Privacy Notice.

 

Legal Disclosure

We reserve the right to disclose your Personal Data contained in Collected Data and User Data as required by applicable law, in response to lawful requests by public authorities, including meeting national security or law enforcement requirements and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or other legal process served on us.

In the event deftli goes through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, Customer Accounts, Collected Data and User Data will likely be among the assets transferred. Deftli will notify Organisation Owners of any such change in ownership or control.

Contacting deftli

If you have any questions about this privacy notice or your dealings with the deftli, you can contact us via email: support@deftli.com, or post: deftli Ltd, Chantry House, Hill Green, Leckhampstead, Newbury, Berkshire, RG20 8RA, United Kingdom.