We at SourceChain care about your privacy and we respect your privacy rights. SourceChain has created this Privacy Policy to demonstrate our firm commitment to your privacy.

The following outlines this commitment to users of our SourceChain Service as we want to be able to provide everyone with an experience that is safe and secure. SourceChain endeavours to ensure that any personal data you give us remains private and is used only for the purposes outlined in this Privacy Policy.

By using the SourceChain Service, you acknowledge the collection and use of your personal data as outlined below. This version of our Privacy Policy was last updated on 12/11/2019.

1 ABOUT OUR PRIVACY POLICY

1.1 The SourceChain Services (for a more complete description of the Services see our Terms of Service)  together with our website https://www.sourcechain.com/ which includes any webpage containing this domain name, including any page that is enabled for use by a mobile device or any webpage redirected from another domain name provided on the Website are operated by SourceChain Marketplace Limited trading as SourceChain, 74 Pembroke Road, Dublin 4, Ireland (“SourceChain”, “we”, “us” and “our”).

1.2 The SourceChain Service helps Registered Users (“Users”, “Candidates”, “you” and “your”) find employment, by way of a marketplace, where their Talent Profile is available to be matched, by way of a proprietary algorithm, against the Talent requirements, of SourceChain Customers (i.e. direct employers and recruitment agencies who are Registered Customers of the SourceChain Service) (“Customers”). SourceChain is the Data Controller (as defined under data protection law) and responsible for your personal data. Your Talent Profile will be available to match and, subsequent to a match, viewable on the SourceChain Service by SourceChain Customers. SourceChain will control the personal data you submit to us when using the SourceChain Service. In certain circumstances, SourceChain Customers who receive your messages, Talent Profile information, job applications or other personal data you have provided as part of your use of the SourceChain Service will also be a Data Controller of some of your personal data. 

1.3 This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us and your rights in relation to your personal data. If you are a Customer, this Privacy Policy supplements any data protection provisions contained in our contract with you and is not intended to override them. Please read the following carefully to understand our views and practices regarding your personal data, how we will treat it and your data protection rights. The SourceChain Services are not intended for children and we do not knowingly collect personal data relating to children.

2 PERSONAL DATA WE COLLECT AND PROCESS

2.1 When registering for a Candidate account, using any SourceChain Service, we will collect and gather the following categories of personal data:

2.1.1 Identity Data such as first name, surname, gender, date of birth.

2.1.2 Contact Data such as address, e-mail address, telephone number.

2.1.3 Profile Data such as your username and password, personal data contained in resumes/CVs and cover letters, photographic and video images, employment details, education history, eligibility to work, salary expectations, job applications made by you, your interests, preferences, feedback, company ratings and survey responses.

2.1.4 Placement Data such as location of current workplace, salary, annual leave, pensions and benefits entitlement; start date, leaving date and pay rate.

2.1.5 Financial Data such as, for Customers only, your payment card details, bank details, VAT number, information about payments to and from you and other details of services you have purchased from us.

2.1.6 Technical Data such as internet protocol (IP) address, your login data, browser type and version, 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 SourceChain Service.

2.1.7 Usage Data such as information about how you use the SourceChain Services.

2.1.8 Marketing and Communications Data such as your preferences in receiving marketing communications from us and third parties and your communication preferences.

2.2 The type of personal data collected and used by us varies depending upon whether you are; just browsing the Website; a registered Candidate; or if you are a Customer the SourceChain Services.

2.3 We collect, use and share aggregated data such as statistical or demographic data. Aggregated data may be derived from your personal data but is not considered personal data under applicable data protection law as this data does not directly or indirectly reveal your identity.

3 HOW WE COLLECT PERSONAL DATA ON THE WEBSITE

3.1 In order to use the SourceChain Service, you will need to register an account with SourceChain, which will involve you giving us your Identity, Contact and Profile Data. We will inform you at the time of collecting personal data from you whether you must provide the personal data to use the SourceChain Service, or whether the provision of personal data requested by us is optional.

3.2 It is not necessary to register a Candidate or Customer account in order to browse the publicly accessible elements of the Website. However, we will receive Technical Data and Usage Data when you browse the Website. This is further explained below.

3.3 Where we need to collect personal data by law, or under the terms of a contract we have with you (e.g. Terms and Conditions) and you don’t 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 the SourceChain Service). In this case, we may not be able to provide all or part of the relevant service.

4 METHODS USED TO COLLECT PERSONAL DATA FROM AND ABOUT YOU

4.1 Direct interactions: You may give us your Identity, Contact, Profile, Financial (Customers only), Marketing and Communications Data by populating your online Profile, changing details in Your Account, filling in online forms or by communicating with us. If you are a registered Candidate who expresses an interest in a matched role via the SourceChain Service, we and the relevant Customer will receive your relevant personal data associated with it. The personal data we receive from direct interactions with you includes personal data you provide when you:

4.1.1 apply or subscribe to the SourceChain Service;

4.1.2 create a Candidate account on our SourceChain Service and when you add to and manage your personal Profile;

4.1.3 contact or communicate with us and/or Customers via the SourceChain Service;

4.1.4 submit responses to Talent Matches (defined below);

4.1.5 submit responses to surveys or polls, provide feedback, rate companies or make available any other content on the SourceChain Service;

4.1.6 request marketing communications to be sent to you;

4.1.7 make your resumes or CVs available on the SourceChain Service for third parties to browse in connection with employment, consultant or contractor positions;

4.1.8 as a Customer, where you save or download a resume or other personal data from the Service.

4.2 Automated technologies or interactions: As you interact with the SourceChain Service, we collect Technical Data and Usage Data including details of your device, browsing actions and patterns, searches, job advertisements viewed, traffic data, web logs and other communication data and the resources that you access. We collect this personal data by using cookies, tracking codes, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookies policy for further details.

4.3 Third parties: We may receive personal data about you from various third parties as set out below:

  • 4.3.1 Identity, Contact and Profile Data from other sources such as LinkedIn, job board websites, online CV libraries, personnel recommendations and referrals, hiring platforms and using business development tools.;
  • 4.3.2 Technical Data from providers such as Google Analytics, HubSpot, and Albacross;

5 HOW WE USE YOUR PERSONAL DATA

5.1 Registered SourceChain Customers (whether on their own behalf or, if a recruitment agency or consultancy, on behalf of third parties) develop a Profile of the Talent that they are looking to match against as part of a Talent search. This Profile is matched, by way of our proprietary algorithm, against the Talent Profiles of our Candidates and the matching Candidate Profiles are made available to the Registered SourceChain Customers. The Registered SourceChain Customer may then initiate communication with the matched users to elicit interest in the role being searched for and to pursue further discussions. 

5.2 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

5.2.1 Where we need to perform the contract (e.g. the Terms of Service) we are about to enter into or have entered into with you.

5.2.2 Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

5.2.3 Where we need to comply with a legal or regulatory obligation.

5.3 Generally we do not rely on consent as a legal basis for processing your personal data. If we do rely on your consent to process your personal data this will be made clear to you at the time, and you have the right to decline to provide us with your consent and to withdraw your consent at any time by contacting us.

5.4 SPECIAL CATEGORY PERSONAL INFORMATION

We may also collect, store and use the following “special categories” of more sensitive personal information regarding you where you include it in the Profile information you make available on the SourceChain Service:

  • information about your race or ethnicity, religious beliefs, sexual orientation and political opinions;
  • information about any trade union membership; and
  • information about your health, including any medical condition;
  • We may also collect, store and use information about any criminal convictions and offences where we have been instructed to obtain this information from a client in order to determine your eligibility to undertake particular types of work.

“Special categories” of particularly sensitive personal information require differing levels of protection. We need to have different justifications for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

  • with your explicit written consent;
  • where it is needed to establish, bring or defend legal claims;
  • where we need to carry out our legal obligations relating to employment law, social security law or social protection law; and
  • where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.

Less commonly, we may process this type of information where it is needed to protect your vital interests (or someone else’s vital interests) and you are not capable of giving your consent, or where you have already made the information public.

The situations in which we will process your personal information are listed below. 

  • storage of records relating to you and also records relating to our business;
  • assessing suitability for particular roles based on health grounds;
  • we will use information about criminal convictions to comply with law and in order to determine your eligibility to undertake particular types of work;

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

5.5 We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your personal data. Please contact us using [email protected] if you need details, in addition to those set out below, about the specific legal ground we are relying on to process your personal data.

5.6 We use your personal data in the following ways:

5.6.1 We will collect and use your Identity; Contact; Profile and Financial Data (Customers only) to register you as a new Candidate of the SourceChain Service or to register Customers. This is necessary in order to perform our contract (e.g. Terms of Service) with you.

5.6.2 We will collect and use your Identity, Contact and Profile Data to provide Customers with the information that you submit to the SourceChain Service in response to Talent matching requests. This is necessary in order to perform our contract (e.g. Terms of Service) with you. Details of your application for, or engagement involving, a specific Talent Match / Talent Profile will only ever be shared with the Customer matching the role. It will never be shared with any other Customer.

5.6.3 We will process your Identity, Contact and Profile Data to:

(a) maintain this personal data in our database of searchable and viewable Candidate Profiles, CVs and resumes (“Talent Profile”);

(b) display your CV or resume and associated personal data for our Customers, so that our Customers and their customers can evaluate whether you are a suitable candidate for a vacant position (whether or not a Talent Match);

(c) identify and create a Profile of the key information you disclosed in your CV or resume, which we will use for our internal administration purposes to manage the Talent Profile, to enhance your personal Profile and to match your CV or resume to relevant Job Specifications and Talent Matches. This processing involves profiling, the consequence of which is that the key personal data we identify from your CV or resume will be used to enhance the likelihood of a Customer considering you for a Talent Match and

(d) identify from your CV or resume key skills based on your current role and job title contained in your CV or resume, which we will use to match your CV or resume to relevant Talent Matches. This processing involves automated decision making, including profiling, of the kind referred to in Article 22 GDPR. The logic of this processing involves assumptions based on information you submit with your  Profile, CV or resume, but which you can change at any time by accessing the SourceChain Service.[email protected]

The processing described in this section 5.6.3 is necessary in order for us to perform our contract (e.g. Terms of Service) with you, and in respect of sub-sections (a), (b) and (c) is necessary for our legitimate interest to increase the possibility of registered users gaining employment which in turn improves the SourceChain Service. 

5.6.4 We may promote your Talent Profile to a Customer where we believe your CV is a good match to a vacant position or Talent Match they are seeking. This matching will be based on your Talent Profile and a Profile of the Talent Matches you have interacted with recently. This processing is necessary in order for us to perform our contract (e.g. Terms of Service) with you. 

5.6.5 We will collect and use Profile, Technical and Usage Data for data analytics purposes to improve the SourceChain Service, products/services, marketing, user/Customer relationships and experience. This involves building a Profile of your interests based on the companies, jobs, and Talent Matches you have interacted with in the past 45 days. This is necessary for our legitimate interest to ensure that the SourceChain Service content is presented in an effective manner for you and for your computer/device.

5.6.6 We collect and use Identity, Contact, Technical, Usage and Profile Data and Marketing and Communications Data to send registered users of the SourceChain Service Alerts by email to help with your job search. This involves building a Profile of your interests based on the companies and Talent Matches you have interacted with in the past 45 days. This is necessary (i) in order for us to perform our contract (e.g. Terms of Service) with you; and (ii) for our legitimate interest to ensure registered users are informed of roles relevant to them which in turn improves our service. To facilitate your ease of use of the SourceChain Service across multiple devices, Alerts by email include a personalised link which will recognise you when you visit the SourceChain Service by clicking on a link in the email. This makes it easy for you to engage with the Service as your name, email address, and link to your last used CV will automatically be available. As Job Alert emails are personalised to you, it is important that you do not share these email links with other people or post them on social media. You are responsible for maintaining the security of these personal Job Alert email links. Sharing personalised Job Alerts could result in somebody inadvertently applying for a job in your name.

5.6.7 We collect and use Technical, Usage and Profile Data for data analytics purposes to build an understanding of the sort of Talent Profiles registered users of the SourceChain Service are most interested in by learning from the Profiles you engage with to tailor the jobs we present to you. Our understanding of the jobs you might like will adapt and change as it is based on the job content you interact with over a rolling 45-day period. This will involve profiling. This is necessary for our legitimate interest to ensure registered users are informed of roles relevant to them which in turn improves our service;

5.6.8 We will collect and use Identity, Contact, Technical, Usage, Profile Data and Marketing and Communications Data to communicate to registered users of the SourceChain Service via email about similar products or services from SourceChain that will assist with your job search. This is necessary in order for us to perform our contract (e.g. Terms of Service) with you.

5.6.9 We will collect and use Identity, Contact, Technical, Usage, Profile Data and Marketing and Communications Data to send you career support and advice emails from SourceChain and job and training opportunities from trusted third party partners that you request from us or which we feel may interest you, but only where you have consented to be contacted for such purposes. This processing of your personal data is based on your consent and our legitimate interests to direct market, develop our products/services and grow our business.

5.6.10 We or a registered Customer may use your Identity and Contact Data to contact you where you are a registered Candidate or if you have responded to a Talent Match. This is necessary for us to perform our contract (e.g. Terms of Service) with you and our legitimate interest to perform services for Customers.

5.6.11 We will collect and use Identity, Contact, Profile, Technical and Usage Data to allow you to participate in interactive features of the SourceChain Service, when you choose to do so. This is necessary for us to perform our contract (e.g. Terms of Service) with you.

5.6.12 We will collect and use Identity, Contact, Profile, Marketing and Communications Data to manage our relationship with you which will include notifying you about changes to our SourceChain Service, terms and/or Privacy Policy. This is necessary for us (i) to perform our contract (e.g. Terms of Service) with you; and (ii) to comply with a legal obligation.

5.6.13 We will collect and use Identity; Contact and Technical Data to administer and protect our business and the SourceChain Service (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) which is necessary (i) for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) and (ii) to comply with a legal obligation;

6 MARKETING

6.1 We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

6.2 You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

6.3 You can opt out of any marketing communications from us at any time by updating your notification settings or by using the “Unsubscribe” function at the bottom of the marketing email we send you.

7 CHANGE OF PURPOSE

7.1 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

7.2 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

8 DISCLOSURE OF PERSONAL DATA TO OTHERS

8.1 Except as set out in this Privacy Policy, we do not disclose to any third party personal data that we collect or you provide to us. We may disclose your personal data to third parties expressly mentioned in this Privacy Policy and the following third parties:

8.1.1 Customers to whom you submit an expression of interest in their talent match via the SourceChain Service;

8.1.2 if you have indicated at registration, or at any time during your time as a Registered Candidate of the SourceChain Service, that you are happy to receive information or promotions from selected third parties about goods and services which may be of interest to you, we will send you such offers or information. See Marketing above on how to change your preferences;

8.1.3 any member of our group of companies, which means our subsidiaries, our ultimate holding company and its subsidiaries, where it is necessary to do so for the provision and administration of the services we provide to you;

8.1.4 we contract with other entities that perform certain tasks on our behalf and who are under our control (“Service Providers”). This is required in order to provide and manage the SourceChain Service. Such Service Providers include IT systems suppliers and support, data storage, IT developers, insurance, credit card companies, payment processors, analytics companies, website hosting providers, payroll, email marketing specialists, business development tool providers and IT services (including CRM, website, video- and teleconference services) and other service providers;

8.1.5 professional advisors such as accountants, auditors, lawyers, bankers, insurers, and other outside professional advisors;

8.1.6 third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy;

8.1.7 entities that regulate or have jurisdiction over SourceChain. We will disclose your personal data in order to comply with any legal obligation, if we are ordered to do so by a court of competent jurisdiction, law enforcement, regulatory or administrative authorities or in order to enforce or apply our Terms of Service and other agreements, or to protect the rights, property, or safety of SourceChain, our Customers, registered users or others. This includes exchanging personal data with third parties for the purposes of fraud protection and credit risk reduction.

8.2 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 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. Unless prevented by applicable law, we will notify you when your personal data may be provided to third parties in ways other than explained above, and you may have the option to prevent such sharing at the time that we notify you.

9 TALENT PROFILE SERVICE

9.1 All registered users create their Talent Profile and may upload their CVs and resumes to build their personal Profile which remain private and will not be searchable by other users.  Registered Customers will be made aware of your Talent Profile should your Profile match the criteria of a role they are searching for.

10 CUSTOMER CONTROL OF YOUR PERSONAL DATA

10.1 If you respond to a Talent Match communication from a Registered Customer, or otherwise communicate with Customers via the SourceChain Service the relevant Customer will control the personal data you disclose. This will typically relate to your Identity, Contact and Profile Data. Customers can access this personal data in their SourceChain Service Customer account, and so can SourceChain. Both SourceChain and the Customer will jointly control this personal data, and we have arrangements in place intended to ensure your personal data is only used by Customers in accordance with this Privacy Policy. [email protected]

10.2 If a Customer to whom you or we have disclosed any of your personal data downloads or copies the personal data to a medium other than our Service, SourceChain will no longer jointly control this personal data. Such data will be subject to the Customer’s own data protection and privacy practices. If you wish to understand the Customer’s data protection and privacy practices please contact the Customer directly. You will be able to exercise your Data Protection Rights directly with the Customer.

11 INTERNATIONAL DATA TRANSFERS

11.1 Your personal data may be transferred, stored and accessed within the European Economic Area (“EEA”) or transferred to, stored in, and accessed from countries outside the EEA in order to fulfil the purposes described in this Privacy Policy. For transfers to countries outside the EEA, the data protection regime may be different than in the country in which you are located and will therefore be based on a legally adequate transfer method. Whenever SourceChain transfers your personal data out of the EEA, we ensure a similar degree of protection is given to it by ensuring at least one of the following safeguards is implemented:

11.1.1 Where the country has been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

11.1.2 We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

11.1.3 Where service providers are based in the US, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

11.2 We will provide you on request a list of the countries located outside the EEA to which personal data may be transferred, and an indication of whether they have been determined by the European Commission to grant adequate protection to personal data. Where applicable, you are entitled, upon request to receive a copy of the relevant safeguard (for example, EC model contractual clauses) that has been taken to protect personal data during such transfer.

12 DATA SECURITY

12.1 SourceChain is committed to protecting the personal data you provide us. To prevent unauthorised access or disclosure of personal data under our control, SourceChain has appropriate security management systems in place to safeguard the personal data we collect. Firewalls, intrusion detection and virus scanners are used on all parts of the SourceChain Service. Encryption during transmission is also used on sections of the SourceChain Service where security is particularly important.

12.2 While SourceChain makes reasonable efforts to protect all personal data, no data transmission over the Internet can be guaranteed to be 100% secure. As a result SourceChain cannot ensure or warrant the security of any personal data you transmit to us, you do so at your own risk. You acknowledge that we are not responsible for any intercepted information sent via the Internet, and you hereby waive, release and discharge us from any and all claims arising out of or related to the use of intercepted information in any unauthorised manner.

12.3 Where we have given you (or where you have chosen) a password which enables you to access certain parts of the SourceChain Service, you are responsible for keeping this password confidential. You must not to share your SourceChain Service password with anyone.

12.4 When you disclose personal data, or request us to make your personal data available, to Customers on the SourceChain Service (e.g. by submitting a CV to a Customer) that personal data will be used by the Customer for its own purposes (e.g. to contact you, arrange an interview, review your suitability for a particular position) and such third party purposes and activities are beyond our control.

13 UPDATING YOUR PERSONAL DATA

13.1 It is important that the personal data we hold is accurate and current. Please keep us informed, and let us know by using the Contact Us information below if any of your personal data changes during your relationship with us. It is your responsibility to keep your personal data up to date at all times.

14 LINKS TO THIRD PARTY WEBSITES

14.1 SourceChain Customers are given the option to have a Profile page on the SourceChain Service. This includes information related to their company such as: company logo, contact details, company Profile, web address and related links. This information is disclosed for your convenience and information, however if you access some of the links and web addresses disclosed on these pages, you will leave our Website.

14.2 The SourceChain Service contains links to and from the websites of our partner networks, Customers, advertisers and affiliates as well as third party websites to which we have no affiliation. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their policies.

14.3 We also use third party partners to support the SourceChain Service. Some of these partners may use technology such as cookies and web beacons when they interwork with our SourceChain Service, which will also send these parnters (such as Google through the Google Analytics program) information including your IP address, your ISP, the browser you used to visit the Website, and in some cases, whether you have Flash installed. This is generally used for marketing optimisation, geotargeting purposes or showing certain information based on specific cross-linked information.

15 IP ADDRESSES AND COOKIES

15.1 We may collect information about your computer, including (where available) your IP address, operating system and browser type, for system administration and statistical purposes.

15.2 For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. On revisiting the SourceChain Service our computer server will recognise the cookie, giving us information about your last visit. They help us to improve the SourceChain Service and to deliver a better and more personalised service. They enable us:

15.2.1 to estimate our audience size and usage pattern;

15.2.2 to store information about your preferences, and so allow us to customise the SourceChain Service according to your individual interests and make your usage of the SourceChain Service more enjoyable; and

15.2.3 to speed up your searches.

For more information about how our cookies work view our cookies policy.

For information on how to control your cookies go to allaboutcookies.

16 DATA RETENTION

16.1 We retain personal data for no longer than is allowed under data protection law and, in any case, no longer than such personal data is necessary for the purpose for which it was processed. 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 unauthorised use or disclosure, the purposes for which we process personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

16.2 As a registered Candidate of the SourceChain Service we will retain your Identity, Contact, Profile, Technical, Usage, Marketing and Communications Data for as long as your Candidate account is live. We retain the personal data you provide while your account is in existence or as needed to provide you access to the SourceChain Service and any SourceChain Service you have used. Even if you only use the SourceChain Service or any other SourceChain Service occasionally, we will retain your Identity, Contact, Profile, Technical, Usage, Marketing and Communications Data until you decide to close your Candidate account. In some cases, we retain certain Usage Data (e.g. visitor and application statistics in a depersonalized or aggregated form). Also, we retain personal data for longer if required by applicable law or regulation or justified under applicable statutory limitation periods.

16.3 If you respond to a Talent Match or otherwise communicate with Customers via the SourceChain Service a copy of your job application, CV or resume and a record of the communication will be held on the Customer’s account. The copy of your job application CV or resume and record of communication will remain on the Customer’s account for no more than 18 months after the Talent Match has been archived. We will delete that copy of your application, CV or resume and record of communication from the Customer’s account 18 months from the date the Talent Match is archived, unless you have exercised Your Legal Rights of erasure of that personal data before this. Details of all the job applications you make through the SourceChain Service can be viewed by you in Your Account.

17 YOUR LEGAL RIGHTS

17.1 Under certain circumstances you have rights under applicable data protection law in relation to personal data, namely:

17.1.1 Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

17.1.2 Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

17.1.3 Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

17.1.4 Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

17.1.5 Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

17.1.6 Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

17.1.7 Withdraw consent at any time if and to the extent we are relying on consent as the legal basis to process your personal data. 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.

17.2 Regarding your right to have your personal data erased, you can delete your Candidate account with SourceChain at any time. Deleting your Candidate account deletes records of job applications sent, CVs and cover letters stored in your account, your Profile, saved jobs and job alerts. Once your Candidate account is deleted, it is gone forever and cannot be restored. Some personal data however may still be stored and visible in other places on the SourceChain Service. For example, if you have applied for a job, your application information including your name, email, CV and cover letter may still be visible to the Customer in their account on the SourceChain Service. We will endeavour to contact Customers we know who have accessed your personal data within the previous 18 months and inform them of your request to erase your personal data.

17.3 You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

17.4 In order to exercise one or more of your rights in respect of your personal data please contact us at [email protected]. We will respond to your request(s) as soon as reasonably practicable, but in any case, within the legally required period of time.

17.5 You have the right to make a complaint at any time to the Data Protection Commission, the Irish supervisory authority for data protection issues (https://www.dataprotection.ie). We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Commission so please contact us in the first instance at [email protected]

18 CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our Privacy Policy in the future will be posted on this page, you may also be notified by email. You should visit this page periodically to review any changes to the Privacy Policy.

CONTACT US

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the following details: The Data Protection Officer, SourceChain Marketplace Limited, 74 Pembroke Road, Dublin 4, Ireland, or alternatively address your query to the Data Protection Officer through [email protected]

What are cookies?

A cookie is a small text file that a website stores on your computer or mobile device when you visit the site.

First party cookies are cookies set by the website you’re visiting. Only that website can read them. In addition, a website might potentially use external services, which also set their own cookies, known as third-party cookies.
Persistent cookies are cookies saved on your computer and that are not deleted automatically when you quit your browser, unlike a session cookie, which is deleted when you quit your browser.

Every time you visit our websites, you will be prompted to accept or refuse cookies. The purpose is to enable the site to remember your preferences (such as user name, language, etc.) for a certain period of time. That way, you don’t have to re-enter them when browsing around the site during the same visit.

Cookies can also be used to establish anonymised statistics about the browsing experience on our sites.

HOW DO WE USE COOKIES?

Currently, there are four types of cookies that may be generated as you browse our site: session cookies, analytics cookies, lead generation cookies and third party cookies.

1. Session Cookies

Session Cookies are only stored temporarily in the browser’s memory, and are destroyed when it is closed down, although they will survive navigating away from the website they came from. As you move through the site, various pieces of information need to be stored in order for the site to function properly. We use a service provider called CloudFlare to ensure our site functions as performant as possible and is delivered to you as quickly as possible.

How do I control session cookies?

You can use your browser settings to control whether or not we set session cookies. More information on your browser settings is provided at the bottom of this page.

Please be aware that cookies are critical to the efficient working of the site. If you choose to disable cookies from this site, the functionality of the site may be greatly reduced.

2. Analytics Cookies

In order to monitor how our sites are performing, we collect data about page visits. This information is completely anonymous — we cannot determine who it came from. When we use this data, we look at numbers of visitors overall rather than individual visits.

Analytics information is used in reports and to improve our site. For example, we have used analytics data to add, remove or change features of the site based on how popular they are with users.

We track, for example:

the numbers of visitors to individual pages;
when pages were visited;
how long users stayed on the page;
the IP address of the user of the website;
the page they came from;
technical data about the device being used to browse the site (such as browser and operating system version, and display size) — we use this data to ensure that the technology our site uses is appropriate for the majority of our users, and how best to display the site for users who have less capable browsers.

More information about analytics cookies

We use cookies from different partners including HubSpot and Google to provide our analytics data. You can read more about how Google Analytics treats your data on their web site. You can also read Google’s full privacy policy.

How do I control analytics cookies?

Google provides a tool to opt-out of Google Analytics. This is available for all modern browsers in the form of a browser plugin. Additionally, you can control how cookies are set using your browser settings. 

3. Lead Generation cookies

Information collected from cookies set in your device that qualify as personal data will be processed by Albacross, a company offering lead identification and ad targeting services with offices in Stockholm and Krakow. 

The purpose for the processing of the personal data is that it enables Albacross to improve a service rendered to us and our website (e.g. “Lead Generation” service), by adding data to their database about companies.

The data that is collected and used by Albacross to achieve this purpose is information about the IP-address from which you visited our website, and technical information that enables Albacross to tell apart different visitors from the same IP-address. Albacross stores the domain from form input in order to correlate the IP-address with your employer.

4. Third party cookies

The advertisements you see displayed on the site are generated by third parties. These services may use their own anonymous cookies to track how many times a particular ad has been displayed to you, and may track your visits to other sites where their ads are displayed. Please note that advertisers can only track visits to sites which display their ads or other content. This tracking is anonymous, meaning that they do not identify who is viewing which ads.

Tracking in this manner allows advertisers to show you ads that are more likely to be interesting to you, and also limit the number of times you see the same ad across a wide number of sites. As an example of how advertisers operate, if you recently researched holidays, adverts for holiday operators may subsequently appear on our sites.

We do not have access to, or control over, these third party cookies; nor can we view the data held by these advertisers. Online advertisers provide ways for you to opt-out of your browsing being tracked. More information about the advertisers we use, and how to opt-out, is provided below.

YouTube

We display clips from YouTube related to our Company Profiles. You can view YouTube’s privacy policy. This page also allows you to control what cookies YouTube saves on your computer.

LinkedIn

We work with LinkedIn to optimise how LinkedIn ads are displayed. You can discover how LinkedIn protects your privacy relating to ads at its privacy policy. 

Twitter

We display content clips from Twitter related to our Company Profiles. You can view Twitter’s privacy policy. This page also allows you to control what cookies Twitter saves on your computer.

Cookie Table of our cookies 

Cookie Name Expires Use
Google Analytics
_ga 2 years Used to distinguish users.
_gid 24 hours Used to distinguish users.
_gat 1 minute Used to throttle request rate. If Google Analytics is deployed via Google Tag Manager, this cookie will be named _dc_gtm_.
AMP_TOKEN 30 seconds to 1 year Contains a token that can be used to retrieve a Client ID from AMP Client ID service. Other possible values indicate opt-out, inflight request or an error retrieving a Client ID from AMP Client ID service.
_gac_ 90 days Contains campaign related information for the user. If you have linked your Google Analytics and Google Ads accounts, Google Ads website conversion tags will read this cookie unless you opt-out.
Hubspot
hubspotutk  13 months This cookie is used to keep track of a visitor’s identity. This cookie is passed to HubSpot on form submission and used when deduplicating contacts.
__hstc  13 months The main cookie for tracking visitors. It contains the domain, utk, initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session).
 __hssc 30 minutes This cookie keeps track of sessions. This is used to determine if HubSpot should increment the session number and timestamps in the __hstc cookie. It contains the domain, viewCount (increments each pageView in a session), and session start timestamp.
 __hssrc End of session Whenever HubSpot changes the session cookie, this cookie is also set to determine if the visitor has restarted their browser. If this cookie does not exist when HubSpot manages cookies, it is considered a new session.
Albacross
nQ_cookieId 2 years Tracking for business IP address lock-up provided by 3rd-party called Albacross for lead classification
nQ_visitId  70 years Sets a unique ID for the session. This allows the website to obtain data on visitor behaviour for statistical purposes.
Cloudflare
__cfruid Session pending Identify trusted web traffic.
__cfduid 5 years  The ‘__cfduid’ cookie is set by the CloudFlare service to identify trusted web traffic.

Removing cookies from your device

You can delete all cookies that are already on your device by clearing the browsing history of your browser. This will remove all cookies from all websites you have visited.

Be aware though that you may also lose some saved information (e.g. saved login details, site preferences).

Managing site-specific cookies

For more detailed control over site-specific cookies, check the privacy and cookie settings in your preferred browser

Blocking cookies

You can set most modern browsers to prevent any cookies being placed on your device, but you may then have to manually adjust some preferences every time you visit a site/page. And some services and functionalities may not work properly at all (e.g. profile logging-in).

FURTHER HELP

If you still have any concerns relating to our use of cookies, please contact us at [email protected]

Thank you for registering your interest.

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