As the operators of the Workable website, Workable Software Limited registered in England and Wales with Company Registration Number 08125469 and having its registered office address at 5 Golden Square, 5th Floor, London, W1F 9BS, United Kingdom ("We", "Us", “Workable”), is committed to protecting and respecting your privacy. This Privacy and Cookies Policy ("Policy") relates to services provided through our website and application (“Services”) and sets out the basis on which the Personal Data collected from you, or that you provide to Us will be processed by Us. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations (collectively the “Data Protection Laws”). This Policy does not cover the practices of companies We don’t own or control or people We don’t manage. For clarity, this policy applies when Workable acts as a “Controller” (as defined in the General Data Protection Regulation (the “GDPR”) or “Business” as defined under the California Consumer Privacy Act of 2018 (the “CCPA”)). Note that we may also process Personal Data of our customers’ job applicants in connection with our provision of services to customers, in which case we are the processor of Personal Data. If we are the processor or service provider for your Personal Data (i.e., not the controller or business), please contact the controller/business party in the first instance to address your rights with respect to such data. Please read the following carefully to understand our views and practices regarding your Personal Data and how We will treat it.
For the purpose of the GDPR and the CCPA:
We collect Personal Data about you from:
We collect and process some or all of the following types of information from you:
The provision of your full name and e-mail address, your employer and/or your place of work and the url of the business that you work for is required from you when you register to use our Services. We will inform you at the point of collecting information from you, whether you are required to provide the information to Us.
|Personal Data Collected (including Categories)||Purposes of Use||What is the source of this Personal Data?||Categories of third parties to whom we disclose the information for business purposes|
|A. Personal identifiers|
Real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social profile URL
B. Customer records identified by state law (including the California Customer Records statute (Cal. Civ. Code § 1798.80(e)))
Name, signature, address, telephone number, employment.
C. Commercial information
History of services purchased through Workable
D. Internet or other similar network activity information
Browsing history, search history, information interaction with the website or application.
E. Geolocation data
Physical location (calculated from IP address)
F. Professional or employment-related information
Current job title and employer
The following section provides additional information about how we collect your Personal Data.
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration, customer support and to collect aggregate information for internal reporting purposes.
The cookies we use are "analytical" cookies. Some of the common uses for our cookies are as follows:
You can also decide whether or not to accept cookies through your internet browser’s settings. Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new cookie in a variety of ways. You can also delete all cookies that are already on your computer. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some of the Services and functionalities may not work.
To explore what cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about cookies, including information about how to manage and delete cookies, please visit https://ico.org.uk/for-the-public/online/cookies/ or http://www.allaboutcookies.org/.
You may connect your Google account to your Workable account in order to make use of certain Workable features such as Gmail Import and Syncing and scheduling with Google Calendar. This is done through OAuth authentication, a secure mechanism which gives Workable access to your Google account data without letting Workable know your password.
In that case, Workable will require access to your Google account and user data for the following purposes:
If you request assistance by a representative of Workable, the Workable representative may obtain access to your Workable account for the purposes of resolving your inquiry. Under those circumstances, the Workable representative will assume your role in Workable and view your account as you would when you log in.
Workable reserves the right to assume the role of a user in your account without prior notice in certain situations, for example when it is necessary for security purposes (such as investigating a bug or abuse) or when it is necessary to comply with applicable law.
Where you are using our Services on behalf of our Customer, we rely on legitimate interests in performing our contract with our Customer as the lawful basis on which We collect and use your Personal Data.
We use information held about you in the following ways:
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable). Where any such member of our group is outside the EU this transfer will be on the basis of a contract including the Model Contractual Clauses in accordance with the Data Protection Laws.
We may disclose your personal information to third parties:
We disclose your Personal Data to service providers and other parties for the following business purposes:
We disclose your Personal Data to the following categories of service providers and other parties:
Over the past twelve months, we have disclosed the following categories of your Personal Data to service providers or other parties for the business purposes listed above:
We haven’t sold your Personal Data over the last twelve months.
We take appropriate measures to ensure that all Personal Data is kept secure including security measures to prevent Personal Data from being accidentally lost, or used or accessed in an unauthorised way, for the duration of your use of our Services. We limit access to your Personal Data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to the Website, therefore any transmission remains at your own risk. Once we have received your information, we will use strict procedures and security features in order to prevent unauthorised access.Keeping your Personal Data up to date
If your personal details change you may update them by accessing the relevant page of the Website, or by contacting Us at [email protected].
We will endeavour to update your Personal Data within thirty (30) days of any new or updated Personal Data being provided to Us, in order to ensure that the Personal Data We hold about you is as accurate and up to date as possible.Where we store your Personal Data
The data that We collect from you and process as a result of your use of the Services may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for Us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services. By submitting your Personal Data, you agree to this transfer, storing or processing.
In particular, your data may be accessible to i) Workable’s staff in the USA or ii) may be stored by Workable’s hosting service provider on servers in the USA as well as in the EU. The USA does not have the same data protection laws as the United Kingdom and EEA. A Data Processing Agreement has been signed between Workable Software Limited and Workable Technology Limited and their overseas group companies, and between Workable and each of its data processors. These Data Processor Agreements that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your Personal Data. A full list of Workable's sub-processors can be found here.
If you would like further information please contact Us (see ‘Contact’ below). We will not otherwise transfer your Personal Data outside of the United Kingdom OR EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.How long we keep your Personal Data
We will hold all the data for so long as we have an obligation to the Customer to provide the Services, and thereafter until such time as we delete the Customer’s account in accordance with our Customer Terms and Conditions.
Your personal information will be deleted on one of the following occurrences:
We do not knowingly collect or solicit Personal Data from children under 16; if you are a child under 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Data, please contact us at [email protected].
If you are a California resident, you have the rights outlined in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. If there are any conflicts between this section and any other provision of this Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at [email protected].Access
You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. We will provide you with the following information:
If we have disclosed your Personal Data for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient.Deletion
You have the right to request that we delete the Personal Data that we have collected from you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.Exercising Your Rights
To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify you and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may submit a Valid Request using the following methods:
Emailing us at: [email protected]
We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA.
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at [email protected].
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.European Union Data Subject Rights
If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
The Services are hosted and operated in the United States (“U.S.”) through Workable, Inc. and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Workable, Inc. in the U.S. and will be hosted on U.S. servers, and you authorize Workable to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby acknowledge and agree to the transfer of your data to the U.S. pursuant to the EU-U.S. or Swiss-U.S. Privacy Shield Frameworks, respectively, the details of which are further set forth below.
With respect to Personal Data received or transferred pursuant to the Privacy Shield Frameworks, Workable Inc. is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.
Pursuant to the Privacy Shield Frameworks, EU individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to [email protected]. If requested to remove data, we will respond within a reasonable timeframe.
We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to [email protected].
In certain situations, we may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Workable’s accountability for Personal Data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Workable remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process Personal Data on its behalf do so in a manner inconsistent with the Principles, unless Workable proves that it is not responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, Workable commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. Please contact us at [email protected] with any questions, concerns or complaints relating to our Privacy Shield Certification.
We are also further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU and Switzerland and you may have the possibility to engage in binding arbitration through the Privacy Shield Panel.
We hope that We can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.