1. Introduction

Welcome to Attributilize, an Applicant Tracking System designed to streamline the recruitment process. This Privacy Policy explains how we collect, use, and protect your personal information when you use our services.

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2. Information We Collect

Attributilize is committed to transparency in our data processing practices. We collect personal information, including name, email address, phone number, resume/CV, cover letter, application materials, portfolio samples, writing samples, references, transcripts, certifications, work samples, and additional documents as specified during the application process. We also collect technical information such as IP address, browser type, device type, operating system, referring website, pages visited on our site, and date and time of visit. We use this information to process job applications, communicate with applicants, improve our services, comply with legal obligations, and protect our rights and property.

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Cookies and Tracking Technologies

In addition to the information listed above, Attributilize uses cookies and other tracking technologies to enhance your experience on our website and to collect data that helps us improve our services. Cookies are small text files that are placed on your device by websites that you visit. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

The types of cookies and tracking technologies we use include:

• Essential Cookies: These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in, or filling in forms.
• Performance Cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site.
• Functionality Cookies: These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have added to our pages.
• Targeting Cookies: These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites.

You can control and manage cookies in various ways. Please refer to your browser settings for more information on how to do this. Please note that blocking cookies may affect the functionality of the website.

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The legal bases for processing this data include the performance of a contract, our legitimate interests, and your consent where applicable. Retention periods vary depending on the type of data and your preferences.

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3. How We Use Your Information

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We use the information we collect for the following purposes:

• To process your job application
• To communicate with you about your application
• To improve our services
• To personalize your experiences
• To comply with legal obligations
• To protect our rights and property

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We use the information we collect for the following specific purposes:

Application Data: We process your application data and, in some cases, store it on behalf of the Employer. This data is used to facilitate your application to a Job Listing and to help Employers find relevant candidates. It also aids in improving our services. The legal basis for processing this data is the performance of a contract and our legitimate interests. The retention period for this data is until the relevant Employer deletes your application or at your request.

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Application Screening Data: We pass your screening data to the relevant Employer and may listen to and analyze the recording. This data is used to improve our services and as part of your application process to a Job Listing. The legal basis for processing this data is the performance of a contract and our legitimate interest. The retention period for this data is until the relevant Employer deletes your application or at your request.

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Demographic Data: We analyze this data for specific purposes in line with applicable data protection regulations. This data is used for evaluating our algorithmic fairness, improving products that address employment barriers, helping employers hire more inclusively, and streamlining applying to jobs by pre-filling future applications. The legal basis for processing demographic data is the applicant's consent. The retention period for this data is until the applicant decides to remove it, where applicable.

• Evaluating Algorithmic Fairness:  This helps ensure that the ATS does not discriminate against any group of applicants.
• Improving Products that Address Employment Barriers: Making the recruitment process more inclusive and accessible for all applicants.
• Helping Employers Hire More Inclusively: Providing insights into the diversity of their applicant pool and helping them make more informed hiring decisions.
• Streamlining Applying to Jobs by Pre-filling Future Applications: The data is used to streamline the job application process by pre-filling future applications with demographic information, saving applicants time and effort.

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Disposition Data: We collect, store, process, and analyze this information. This data is used to further understand the effectiveness of our Sites and their features, and to automatically update job application statuses . The legal basis for processing this data is our legitimate interest. The retention period for this data is the application's duration.

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Mock Interviews Data: We collect, analyze, and process, including via automated means, your Mock Interviews data. This data is used to provide an automated score and feedback based on practice interviews. The legal basis for processing this data is your consent. The retention period for this data is 2 years.

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Application Data ("Contact for Future Positions"): We collect, store, process, and analyze your application data. This data is used to help you find the relevant Employer Job Listings that fit your application in the future. This enables Employers to invite you to apply to their jobs, send you invitations to apply to certain jobs, offer suggestions to you when you apply for jobs on third-party websites in our mobile software, show when you are recently active on Attributilize, and improve our Sites services. The legal basis for processing this data is the performance of a contract and our legitimate interest. The retention period for this until you remove application data.

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Application Data ("Do Not Contact for Future Positions"): We collect, store, process, profile, and analyze your not Do Not Contact application data. We only share your Do Not Contact application data with employers at your direction, when you apply to jobs. This data is used to help you find more relevant Position Listings in the future. The legal basis for processing this data is the performance of a contract. The retention period for this data is until you remove profile data.

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Attributilize collects and processes personal information to personalize the user experience. This includes:

• Personal Identifiers and Contact Information: Used to open and maintain applicant records, communicate with applicants, and manage job applications.
• Device Identifiers: Used to better understand user behavior on the website, enable sign-in functionality, combat fraud, and for other purposes as outlined on the website.
• Personal Information for Service Provision: Used to help companies post and manage jobs, source candidates, manage applicants, communicate with users, analyze recruiting activities, onboard new hires, detect and prevent fraud, provide recording and transcription services, offer customer support, and personalize the user experience.
• Contact Information: Used to send marketing and transactional emails, create accounts, verify identities, conduct interviews, provide campaign-related services, establish a complaint handling system, and list employers' contact persons.
• IT Information: Used to analyze user interaction with services, maintain and improve service content and functionality, develop new programs, prevent fraud, ensure compliance with sanctions regulations, and protect rights and property.

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4. Sharing Your Information

Attributilize processes personal information to respond to user inquiries and provide customer service based on the following legal grounds:

• Legitimate Interest: Processing is necessary for the purposes of the legitimate interests pursued by Attributilize, such as improving services, providing customer support, and personalizing user experience.
• Consent: Users may provide consent for the processing of their personal information for specific purposes, such as receiving marketing communications.
• Contractual Necessity: Processing is necessary for the performance of a contract with the user, such as facilitating application creation and sign-in processes.
• Legal Obligation: Processing is necessary to comply with legal obligations, such as responding to legal requests and preventing harm.

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We may share your information with the following parties: Employers and recruiters using Attributilize, Service providers who assist us in operating our services, Law enforcement or government agencies, if required by law.

Purpose of sharing: To provide relevant features, services, and preferences through user engagement on the sites. To prevent or investigate possible fraud or other security and safety violations.

Explanation of sharing: To provide services. To prevent fraud and security violations.

Legal basis: Legitimate interest to provide services. Legitimate interest in preventing fraud and security violations.

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Employers and recruiters using Attributilize

We share your information with employers and recruiters using Attributilize to help connect you with job opportunities that match your skills and preferences. This includes sharing your applicant data, such as your resume, job search history, and application progress. For example, if your application is set to Contact for Future Positions, we display your profile and recommend it to the employer's recruiters. This helps employers access more job seekers and provides you with more job opportunities.

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Service providers who assist us in operating our services

We share your information with service providers who assist us in operating our services. This includes companies that provide us with services such as job boards, recruiters, interviewing and testing, pre-employment screening, and interview travel booking.

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Law enforcement or government agencies, if required by law

We may share your information with law enforcement or government agencies if required by law. This includes complying with legal and other requirements, such as reporting and equal opportunities monitoring requirements, where applicable.

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5. Data Security

Attributilize is committed to protecting the privacy and security of your personal data.

We take the security of your personal information very seriously and have implemented various security measures to protect it from unauthorized access, disclosure, destruction, or accidental loss. These measures include encryption of sensitive data, access controls to limit who can access personal information, regular security audits to identify and address vulnerabilities, and employee training on data protection best practices. We continuously monitor and update our security measures to ensure they remain effective against evolving threats. Users are responsible for maintaining the security of their data and systems.

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Encryption

We use industry-standard encryption technologies to protect your data both in transit and at rest. This ensures that your data remains secure whether it is being transmitted over public networks or stored within our systems.

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Access Controls

Access to your personal data is strictly controlled through logical access controls, including role-based access, unique IDs, and strong password policies. Multi-factor authentication is used where available to enhance security.

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Data Retention and Deletion

We retain your personal data only for as long as necessary for the purposes for which it was collected. Upon deletion, your data is removed from our systems and subject to a 30-day backup retention period.

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Incident Management

We have incident management procedures in place to quickly respond to and mitigate security incidents. These procedures include investigation, notification, and recovery processes to ensure the timely restoration of data availability.

Our process includes:

• Immediate assessment of the breach to determine its scope and severity.
• Containment of the breach to prevent further unauthorized access or disclosure.
• Notification of relevant authorities within 72 hours of becoming aware of the breach, as required by applicable laws.
• Notification of affected individuals, if necessary, to provide them with information and guidance on protecting their personal information.
• Investigation of the breach to identify the cause and implement measures to prevent future occurrences.
• Review and update of our incident management process to incorporate lessons learned and improve our response to future breaches.

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Regular Testing and Assessment

We regularly test, assess, and evaluate the effectiveness of our security measures through audit and risk assessment procedures. This ensures ongoing compliance with security standards and identifies areas for improvement.

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6. Your Rights

You have the following rights regarding your personal information:

• The right to access your personal information. To exercise this right, please contact us at info@attributilize.com with your request.
• The right to correct inaccuracies in your personal information. To exercise this right, please contact us at info@attributilize.com with your request and the necessary corrections.
• The right to delete your personal information. To exercise this right, please contact us at info@attributilize.com with your request. Note that we may still retain your personal data in accordance with applicable laws.
• The right to object to the processing of your personal information. To exercise this right, please contact us at info@attributilize.com with your request and the specific grounds for your objection.
• The right to data portability. To exercise this right, please contact us at info@attributilize.com with your request and the details of the new service provider.
• The right to restrict the processing of your personal information. To exercise this right, please contact us at info@attributilize.com with your request and the specific circumstances.
• The right to withdraw consent. For any consent-based processing of your personal information, you have the right to withdraw your consent. A withdrawal of consent will not affect the lawfulness of our processing or the processing of any third parties based on consent before your withdrawal. To exercise this right, please contact us at info@attributilize.com.

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7. Changes to This Policy

We may update this Privacy Policy from time to time to ensure that it continues to clearly explain how we collect and use personal and non-personal data. When we make updates, we will notify you of any changes by posting the new Privacy Policy on our site. Additionally, if we make material changes to the Privacy Policy, we may notify you either by prominently posting a notice of such changes on our site or by directly sending you a notification. You are advised to review this Privacy Policy periodically for any changes.

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If we make material changes to the Privacy Policy, we will provide you with notice as follows:

• By posting a notice on our site for a reasonable period before the changes take effect.
• By sending you an email notification if we have your email address on file.

By continuing to use our services or providing us with personal information after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.

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Types of Changes

The types of changes we may make to the Privacy Policy include, but are not limited to:

• Adding more detail about the information we collect, how we use personal data, and the legal bases we rely upon to use personal data.
• Updating our Region-Specific information section to include more information regarding relevant privacy laws.
• Reflecting changes in our group structure or business operations.

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8. Contact Information

If you have any questions about our Privacy Policy or information practices, please contact our legal team at info@attributilize.com

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