PRIVACY POLICYRecruitroo Ireland Ltd Irish Company Number: 718227 Employment Agency Registration: 4927 VAT Number: IE3990736IH Address: 19 Baggot Street Lower, Dublin 2, D02 X658Last Updated: October 5, 2025IntroductionRecruitroo Ireland Ltd ("Recruitroo," "we," "our," or "us") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, store, and disclose your personal and corporate information through our international recruitment, immigration, and relocation platform.This Privacy Policy applies to:Our website at www.recruitroo.com and its associated subdomainsOur web-based application and platformOur white-label solutions for recruitment agencies and immigration law firmsAll services related to international talent acquisition, immigration processing, and relocation managementBy accessing or using our services, you acknowledge that you have read, understood, and agree to our collection, storage, use, and disclosure of your personal information as described in this Privacy Policy and our Terms of Service.1. Definitions and Key TermsCandidate: An individual seeking employment opportunities through our platform, whether applying directly or being sourced by employers, agencies, or law firms using our services.Client/Customer: The company, recruitment agency, immigration law firm, or organization that uses Recruitroo's services to manage recruitment, immigration, or relocation processes.Cookie: A small amount of data generated by a website and saved by your web browser, used to identify your browser, provide analytics, and remember information such as language preferences or login information.Company/We/Us/Our: Recruitroo Ireland Ltd (19 Baggot Street Lower, Dublin 2, D02 X658), responsible for your information under this Privacy Policy.Country: Ireland, where Recruitroo is incorporated and based.Device: Any internet-connected device such as a phone, tablet, computer, or any other device that can be used to access Recruitroo's services.End User: A candidate or individual whose data is processed through our platform by our customers.IP Address: A unique number assigned to every device connected to the internet, typically assigned in geographic blocks and used to identify the location from which a device is connecting.Personal Data: Any information that directly, indirectly, or in connection with other information allows for the identification or identifiability of a natural person, including but not limited to names, contact details, identification numbers, location data, online identifiers, and factors specific to physical, physiological, genetic, mental, economic, cultural, or social identity.Personnel: Individuals employed by Recruitroo or under contract to perform services on behalf of the company.Platform/Service: The recruitment, immigration, and relocation management platform provided by Recruitroo, including all associated software, tools, dashboards, and features.Special Category Data: Sensitive personal data requiring additional protection, including racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, and data concerning sex life or sexual orientation.Third-Party Service: Advertisers, service providers, technology partners, and others who provide content, services, or whose products or services we may make available through our platform.White-Label Partner: A recruitment agency or immigration law firm that uses our platform under their own branding.2. What Information We CollectWe collect various types of information depending on your relationship with Recruitroo (candidate, employer, agency, law firm, or website visitor).2.1 Information Collected from CandidatesBasic Personal Information:Full name and any previous namesDate of birth and ageGender (where legally permissible)Nationality and citizenship statusContact information (email addresses, phone numbers, physical addresses)Emergency contact informationProfessional Information:CV/ResumeWork experience and employment historyEducational qualifications and certificationsTraining qualifications and professional licensesSkills assessments and test resultsTechnical competency evaluationsJob preferences and salary expectationsProfessional references and referee contact informationLinkedIn profile and other professional social media profilesPortfolio or work samples (where applicable)Immigration and Work Authorization Data:Passport details and copiesVisa status and immigration historyWork permit informationRight to work documentationNational insurance numbers or equivalent identifiersPPS numbers (Ireland) or NI numbers (UK)Biometric information (as required for visa applications)Travel history and documentationFinancial and Tax Information:Bank account detailsTax identification numbersPayment information for servicesSalary and compensation detailsAssessment and Interview Data:Pre-recorded video assessment responsesInterview recordings and notesTechnical assessment resultsPsychometric or aptitude test resultsSkills evaluation scoresRelocation Information:Housing preferencesFamily composition and dependent informationFlight booking detailsLocal registration informationSettlement service requirements2.2 Information Collected from Employers and ClientsCompany Information:Company name, registration number, and legal entity detailsBusiness address and contact informationIndustry and sector informationCompany size and structureVAT numbers and tax informationRepresentative Information:Names and contact details of authorized representativesJob titles and rolesLogin credentials and access permissionsJob and Recruitment Data:Job descriptions and requirementsHiring timelines and budgetsTeam structure and reporting linesCompensation packagesInterview feedback and hiring decisionsEmployment contractsPayment Information:Billing addressesCredit card or payment account detailsInvoice historyPayment processing information2.3 Information Collected from Agencies and Law FirmsBusiness Information:Registration and licensing detailsProfessional certifications and accreditationsTeam member informationClient portfolio (anonymized where appropriate)Platform Usage Data:White-label branding preferencesClient and case management informationCommunication templates and automation settings2.4 Automatically Collected InformationTechnical Data:IP addressesBrowser type and versionDevice information (type, operating system, unique device identifiers)Time zone settings and locationCookies and similar tracking technologiesReferring website addressesPages viewed and navigation pathsTime spent on pagesPage interaction information (clicks, scrolls, mouse movements)Platform Analytics:Feature usage statisticsLogin frequency and session durationDashboard interaction patternsSearch queries within the platformApplication submission dataDocument upload activity3. Third-Party Data Sources3.1 Information from CandidatesWe may receive candidate information from third parties when:You apply through job boards or aggregator sites that partner with usYou authorize us to access your LinkedIn or other professional networking profilesYour information is provided by a recruitment agency using our white-label platformYou provide consent for background check providers to share informationReferences provide information about youEducational institutions verify your qualifications3.2 Information from CustomersWe receive information from third parties when:You contact us through our website (fraud detection services may verify your information)You connect third-party tools or systems to our platform via APIPayment processors verify transaction detailsSocial media platforms provide publicly available business information3.3 Publicly Available InformationWe may collect publicly available information from:Professional networking sites (LinkedIn, etc.)Business registries and directoriesSocial media platforms (where you have made information public)News articles and press releasesProfessional association membershipsYou can control how much information is publicly available by adjusting privacy settings on these platforms.4. How We Use Your Information4.1 Primary PurposesRecruitment and Talent Matching:Match candidates with suitable job opportunitiesFacilitate employer-candidate connectionsConduct pre-screening and assessmentsCoordinate interviews and technical evaluationsProcess job applications and employment offersMaintain talent pools for future opportunitiesImmigration and Work Authorization:Prepare and submit employment permit applicationsProcess visa applications and renewalsVerify right to work documentationLiaise with immigration authoritiesTrack application status and deadlinesEnsure compliance with immigration regulationsRelocation Services:Coordinate travel arrangementsAssist with local registration requirementsFacilitate PPS/NI number applicationsSupport bank account setupProvide settling-in assistanceOffer post-arrival aftercarePlatform Operations:Provide access to our software and servicesMaintain user accounts and authenticationProcess payments and invoicesDeliver customer supportEnable communication between platform users4.2 Service Improvement and AnalyticsPersonalize user experience based on preferences and behaviorImprove platform features and functionalityAnalyze usage patterns and identify areas for enhancementConduct research and developmentTest new features and servicesGenerate anonymized statistical reports4.3 Communication and MarketingSend transactional emails related to your use of our servicesProvide service updates and important noticesSend newsletters and job alerts (with your consent)Conduct surveys and request feedbackTarget advertising to appropriate audiencesPromote relevant features and services4.4 Legal and ComplianceComply with legal obligations and regulatory requirementsRespond to legal requests and prevent fraudProtect our rights, property, and safetyEnforce our Terms of ServiceResolve disputes and prevent abuseMaintain records for audit and compliance purposes4.5 AI and Automated Decision-MakingWe use artificial intelligence and automated systems to:Match candidates to job opportunities based on skills and requirementsScreen applications and rank candidatesParse resumes and extract relevant informationSuggest improvements to job descriptionsPredict hiring timelines and success ratesProvide chatbot support through "Roo," our AI assistantImportant: While we use AI to assist in the recruitment process, final hiring decisions are always made by humans (employers or recruiters). You have the right to request human review of any automated decision that significantly affects you.5. Information Sharing and Disclosure5.1 Sharing with Employers and ClientsWhen you apply for a job or express interest in an opportunity, we share your information with:The prospective employer or hiring organizationRecruitment agencies managing the positionImmigration law firms processing your application (if applicable)We share only the information necessary for the specific purpose and in accordance with your consent.5.2 Service Providers and ProcessorsWe engage trusted third-party service providers to perform functions on our behalf, including:Technology Infrastructure:Cloud hosting and server managementDatabase storage and managementEmail delivery servicesAnalytics platformsPayment Processing:Credit card processingPayment gateway servicesBilling and invoicing systemsCommunication Services:Video interviewing platformsEmail marketing servicesSMS notification servicesCustomer relationship management (CRM) systemsSpecialized Services:Background check providersDocument verification servicesTranslation servicesAssessment and testing platformsTravel booking servicesAll service providers are contractually obligated to protect your information and use it only for the purposes we specify.5.3 White-Label PartnersIf you interact with our platform through a white-label partner (recruitment agency or law firm), your information will be shared with that partner as the primary service provider. The partner remains responsible for their own handling of your data in accordance with their privacy policy.5.4 Business Partners and AffiliatesWe may share information with:Current and future affiliated companies and business partnersCompanies we collaborate with for co-branded servicesSuccessors-in-interest in the event of merger, acquisition, or sale of assets5.5 Advertising and Marketing PartnersWith your consent, we may share limited information with:Advertising networks for targeted advertisingSocial media platforms for custom audience targetingMarketing partners for promotional campaignsAnalytics providers to measure campaign effectivenessWe share only non-sensitive, aggregated, or pseudonymized data for these purposes.5.6 Legal and Regulatory AuthoritiesWe may disclose your information when we believe in good faith that disclosure is necessary to:Comply with legal obligations, court orders, or regulatory requirementsRespond to lawful requests from government authoritiesProtect our rights, property, or safety, or that of othersPrevent or investigate fraud, security issues, or illegal activityEnforce our Terms of Service or other agreements5.7 Analytics and ResearchWe may share anonymized, aggregated, or de-identified data that cannot reasonably identify you with:Web analytics partnersAcademic or industry researchersPublic policy organizationsIndustry benchmarking servicesThis helps improve understanding of recruitment trends, immigration processes, and labor market dynamics.6. International Data Transfers6.1 Cross-Border ProcessingRecruitroo is incorporated in Ireland and operates internationally. Your information may be transferred to, stored in, and processed in:Ireland (our primary location)The United KingdomOther European Economic Area (EEA) countriesCountries where our service providers, partners, or data centers are locatedThis may include countries that do not have data protection laws equivalent to those in your country of residence.6.2 Safeguards for International TransfersWhen we transfer personal data outside the EEA, we implement appropriate safeguards, including:European Commission-approved Standard Contractual ClausesAdequacy decisions recognizing equivalent data protectionBinding Corporate Rules (where applicable)Your explicit consent for specific transfersFor transfers to service providers in countries without adequacy decisions, we ensure they provide adequate data protection through contractual commitments and security measures.6.3 Your Rights Regarding TransfersBy using our services, you acknowledge and consent to the international transfer of your data as described. If you have concerns about data transfers, please contact us at the details provided in Section 28.7. Data Retention7.1 General Retention PrinciplesWe retain your information only for as long as necessary to:Fulfill the purposes described in this Privacy PolicyComply with legal, regulatory, tax, or accounting requirementsResolve disputes and enforce our agreementsMaintain business records and analytics7.2 Specific Retention PeriodsActive Candidates:Candidate profiles and application data: Duration of active recruitment process plus up to 24 months (with consent for talent pool inclusion)Assessment and interview data: Duration of recruitment process plus 12 monthsUnsuccessful application data: 6-12 months after final decision (unless consent given for longer retention)Successful Placements:Immigration and placement documentation: 6 years after end of employment (to comply with legal and regulatory requirements)Employment contracts and related records: 6 years from contract end dateFinancial records related to placement: 7 years for tax and accounting purposesClient and Customer Data:Account information: Duration of business relationship plus 7 yearsContract and billing records: 7 years after contract endCommunication records: 3 years from last interactionDeleted Accounts:When you delete your account, we delete or anonymize your personal data within 60 daysSome information may be retained in backup systems for up to an additional 60 daysWe may retain anonymized statistical data indefinitelyLegal Obligations:Information subject to legal holds or litigation: Until the legal matter is resolvedInformation required by regulatory authorities: As mandated by applicable law7.3 Data Deletion and AnonymizationWhen retention periods expire, we either:Permanently delete the information from our systemsAnonymize the data so it can no longer identify youArchive data in a secure, segregated environment if required by lawYou may request earlier deletion of your data by contacting us, subject to any legal obligations requiring retention.8. Data Security8.1 Security MeasuresWe implement comprehensive technical and organizational measures to protect your information, including:Technical Safeguards:End-to-end encryption for sensitive data transmission (SSL/TLS)Encryption of data at rest in our databasesSecure authentication mechanisms and password hashingMulti-factor authentication (MFA) options for account accessRegular security patching and updatesFirewalls and intrusion detection systemsAutomated threat monitoring and alertingRegular security scanning and penetration testingOrganizational Safeguards:Strict access controls limiting who can view your dataRole-based permissions ensuring employees access only necessary informationBackground checks for personnel with access to sensitive dataComprehensive security training for all staffConfidentiality agreements with employees and contractorsIncident response and breach notification proceduresRegular security audits and compliance reviewsData protection impact assessments for high-risk processingPhysical Safeguards:Secure data centers with restricted physical access24/7 monitoring and surveillanceBackup power and disaster recovery systemsGeographic redundancy for critical data8.2 Payment SecurityCredit card information is encrypted and transmitted to payment processors via PCI DSS compliant systemsWe do not store complete credit card numbers on our serversPayment processing is handled by certified third-party payment gatewaysTransaction data is encrypted and tokenized8.3 Limitations of SecurityWhile we implement robust security measures, no system is completely secure. We cannot guarantee absolute security of information transmitted to or stored on our systems. Security risks include:Potential unauthorized access through sophisticated attacksHuman error or intentional misconductVulnerabilities in third-party systems or softwareSocial engineering or phishing attacksYou can help protect your information by:Using strong, unique passwordsEnabling multi-factor authenticationNot sharing account credentialsBeing cautious about phishing emailsKeeping your contact information current for security alertsReporting suspicious activity immediately8.4 Data Breach ResponseIn the event of a data breach that poses a risk to your rights and freedoms, we will:Investigate and contain the breach promptlyNotify affected individuals within 72 hours where required by lawReport the breach to relevant supervisory authoritiesProvide information about the breach, its likely consequences, and measures takenOffer assistance and support to affected individualsImplement additional safeguards to prevent future breaches9. Your Rights and Choices9.1 Rights Under GDPR (EEA Residents)If you are located in the European Economic Area, you have the following rights:Right of Access: Request confirmation of whether we process your personal data and obtain a copy of your data.Right to Rectification: Request correction of inaccurate or incomplete personal data.Right to Erasure ("Right to be Forgotten"): Request deletion of your personal data when:The data is no longer necessary for the purpose collectedYou withdraw consent and there is no other legal basis for processingYou object to processing and there are no overriding legitimate groundsThe data has been unlawfully processedDeletion is required to comply with legal obligationsRight to Restriction of Processing: Request restriction of processing when:You contest the accuracy of the dataProcessing is unlawful but you don't want data deletedWe no longer need the data but you need it for legal claimsYou have objected to processing pending verification of legitimate groundsRight to Data Portability: Receive your personal data in a structured, commonly used, machine-readable format and transmit it to another controller.Right to Object: Object to processing based on legitimate interests, direct marketing, or research purposes.Right to Withdraw Consent: Withdraw consent at any time for processing based on consent, without affecting the lawfulness of processing before withdrawal.Right to Lodge a Complaint: Lodge a complaint with a supervisory authority (Data Protection Commission in Ireland).Rights Related to Automated Decision-Making: Not be subject to decisions based solely on automated processing that produce legal or similarly significant effects, unless necessary for contract performance, authorized by law, or based on explicit consent.9.2 Rights Under UK GDPR (UK Residents)UK residents have similar rights as those under EU GDPR, enforceable through the Information Commissioner's Office (ICO).9.3 How to Exercise Your RightsTo exercise any of these rights:Email: Send a request to shane@recruitroo.comOnline: Use our contact form at www.recruitroo.com/contactMail: Write to us at 19 Baggot Street Lower, Dublin 2, D02 X658When submitting a request, please include:Your full name and contact informationSpecific details about your requestProof of identity (to verify your identity and protect your data)Any relevant account informationWe will respond to your request within one month, though complex requests may take up to three months. We will inform you if we need additional time.9.4 Verification and FeesTo protect your privacy and security, we may:Request additional information to verify your identityContact you using the information we have on fileRequire you to log into your account as verificationWe do not charge a fee for most requests, but we may charge a reasonable fee or refuse requests that are:Manifestly unfounded or excessiveRepetitive in natureWould require disproportionate effort9.5 End User RightsIf you are a candidate whose data is processed by one of our customers (employers, agencies, or law firms), you should direct rights requests to that organization. We will assist them in responding to your requests as appropriate.10. Cookies and Tracking Technologies10.1 What Are CookiesCookies are small text files stored on your device by your web browser. We use cookies and similar technologies to enhance platform functionality, analyze usage, and personalize your experience.10.2 Types of Cookies We UseStrictly Necessary Cookies: Essential for platform operation, enabling core functionality like secure login, session management, and access to restricted areas. These cannot be disabled without affecting platform functionality.Performance and Analytics Cookies: Collect information about how you use our platform, including pages visited, errors encountered, and time spent. This helps us improve platform performance and user experience.Functionality Cookies: Remember your preferences and settings, such as language selection, dashboard layouts, and notification preferences.Targeting and Advertising Cookies: Used to deliver relevant advertisements and measure campaign effectiveness. These track your browsing activity across websites.10.3 Third-Party CookiesOur platform may use cookies from third-party services:Google Analytics (analytics and reporting)Facebook Pixel (advertising and remarketing)LinkedIn Insights (professional networking and advertising)Video hosting platforms (embedded content)These third parties may collect information according to their own privacy policies.10.4 Managing CookiesBrowser Settings: Most browsers allow you to control cookies through settings. You can:View cookies stored on your deviceDelete existing cookiesBlock all or specific cookiesSet preferences for different websitesNote that blocking or deleting cookies may affect platform functionality, including:Requiring you to log in repeatedlyLosing saved preferences and settingsExperiencing reduced functionalityPreventing access to certain featuresCookie Consent: We provide a cookie consent banner on first visit, allowing you to accept or customize cookie preferences. You can update these preferences at any time through platform settings.Opt-Out Links:Google Analytics: https://tools.google.com/dlpage/gaoptoutNetwork Advertising Initiative: https://www.networkadvertising.org/choices/Digital Advertising Alliance: https://www.aboutads.info/choices/10.5 Do Not Track SignalsSome browsers offer "Do Not Track" (DNT) signals. Our platform does not currently respond to DNT signals, as there is no industry-wide standard for implementation.11. Email Communications and Marketing11.1 Types of EmailsTransactional Emails: Essential communications related to your use of our services, including:Account creation and verificationPassword resets and security alertsApplication confirmations and status updatesInterview invitations and schedulingOffer letters and contract documentsImmigration application updatesPayment receipts and invoicesImportant service announcementsYou cannot opt out of transactional emails while using our services.Marketing Emails: Promotional communications, including:Job alerts and opportunity notificationsNewsletter and industry insightsPlatform feature updatesWebinar and event invitationsSurvey requestsPartnership announcements11.2 Consent and PreferencesWhen you provide your email address:For job applications: We may send transactional emails and, with consent, marketing emailsFor newsletter signup: You consent to marketing emailsFor customer accounts: You consent to transactional and service-related emailsWe only send marketing emails to individuals who have:Explicitly opted in through our website or platformProvided consent through a third party with appropriate permissionsMaintained an active business relationship with us11.3 UnsubscribingEvery marketing email includes:An unsubscribe link in the footerInstructions for updating email preferencesOption to manage communication preferences in your account settingsAfter unsubscribing:Changes take effect within 10 business daysYou will still receive transactional emailsYou can re-subscribe at any time11.4 Targeted AdvertisingWe may use your email address for:Custom audience targeting on platforms like Facebook and LinkedInRetargeting campaigns to show relevant advertisementsLookalike audience creation to reach similar usersThis requires your consent, which you can withdraw at any time by:Updating your marketing preferencesUnsubscribing from marketing emailsContacting us directly12. Special Category Data12.1 DefinitionSpecial category data (also called sensitive personal data) includes information about:Racial or ethnic originPolitical opinionsReligious or philosophical beliefsTrade union membershipGenetic dataBiometric data for unique identificationHealth informationSexual orientation or sex life12.2 Limited ProcessingWe generally avoid collecting special category data. However, immigration and work authorization processes may require processing such data, including:Biometric information for visa applications (photographs, fingerprints)Health information for medical examinations required by immigration authoritiesEthnic or national origin data required on official forms12.3 Legal Basis for ProcessingWe process special category data only when:Explicitly required by law (immigration regulations)You have provided explicit consentNecessary for employment purposes with appropriate safeguardsRequired to protect your vital interestsNecessary for legal claims12.4 Enhanced ProtectionsSpecial category data receives enhanced protection:Accessed only by authorized personnel with specific trainingEncrypted both in transit and at restStored separately from other personal dataSubject to stricter access controls and audit loggingRetained only for the minimum necessary periodShared only when legally required or with explicit consent13. Children's Privacy13.1 Age RestrictionsOur services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from minors without parental consent.13.2 Parental NoticeIf you are a parent or guardian and believe your child under 18 has provided us with personal information without your consent, please contact us immediately at shane@recruitroo.com.13.3 Remedial ActionUpon learning that we have collected personal information from a child under 18 without verified parental consent, we will:Delete that information from our systems promptlyTerminate any associated accountsTake steps to prevent future collection13.4 Age VerificationWe may request age verification where appropriate to ensure compliance with this policy.14. Updates to This Privacy Policy14.1 Policy ChangesWe may update this Privacy Policy periodically to reflect:Changes in our services or business practicesNew legal or regulatory requirementsTechnological developmentsFeedback from users and stakeholders14.2 Notification of ChangesWhen we make material changes:We will update the "Last Updated" date at the top of this policyWe will notify you via email (to the address on file)We may display a prominent notice on our platformFor significant changes, we may request your renewed consent14.3 Review PeriodWe will provide reasonable time (typically 30 days) for you to review changes before they take effect for material updates.14.4 Continued UseContinued use of our services after changes become effective constitutes acceptance of the updated Privacy Policy. If you do not agree with changes, you may:Delete your accountDiscontinue use of our servicesContact us to discuss concerns15. Legal Basis for Processing (GDPR)15.1 Contractual NecessityWe process your data when necessary to:Provide our recruitment and immigration servicesFulfill our contractual obligations to youEnable you to access and use our platform15.2 Legitimate InterestsWe process data based on our legitimate interests to:Improve and optimize our servicesConduct business analytics and researchDetect and prevent fraud and abuseMaintain security and integrity of our systemsConduct direct marketing (where you have not objected)We balance our legitimate interests against your rights and do not process data where your interests override ours.15.3 Legal ObligationsWe process data to comply with:Employment and labor lawsImmigration regulationsTax and accounting requirementsAnti-money laundering and know-your-customer rulesCourt orders and legal processes15.4 ConsentFor certain processing activities, we rely on your consent:Marketing communicationsCookies and tracking technologies (non-essential)Sharing data with third parties beyond contractual requirementsProcessing special category data (where not otherwise legally required)You may withdraw consent at any time, though this will not affect the lawfulness of processing before withdrawal.15.5 Vital InterestsIn rare circumstances, we may process data to protect vital interests, such as:Emergency medical situationsPreventing serious harmLife-threatening circumstances16. Data Protection OfficerWhile not legally required to appoint a Data Protection Officer (DPO), we have designated a data protection contact for privacy-related inquiries.Data Protection Contact: Email: shane@recruitroo.com Address: Recruitroo Ireland Ltd, 19 Baggot Street Lower, Dublin 2, D02 X658Our data protection contact is responsible for:Overseeing data protection strategy and complianceHandling data subject rights requestsAdvising on data protection impact assessmentsServing as point of contact with supervisory authoritiesMonitoring compliance with GDPR and other regulations17. Third-Party Links and Services17.1 External WebsitesOur platform may contain links to third-party websites, including:Job boards and employment sitesSocial media platformsPayment processorsGovernment immigration portalsPartner services17.2 No ResponsibilityWe are not responsible for:Privacy practices of third-party websitesContent or accuracy of external sitesSecurity of third-party platformsTerms and conditions of external services17.3 User ResponsibilityWhen you leave our platform via a link:Our Privacy Policy no longer appliesYou are subject to the third party's privacy policy and termsYou access and use external sites entirely at your own riskWe recommend reviewing the privacy policies of websites you visit17.4 Third-Party Services IntegrationWhen you integrate third-party services with our platform (e.g., social media login, calendar sync), you authorize data sharing between our platform and that service according to your settings and the third party's policies.18. Supervisory Authority18.1 Right to ComplainIf you believe we have processed your personal data in violation of applicable law, you have the right to lodge a complaint with a supervisory authority.18.2 Ireland - Data Protection CommissionFor individuals in Ireland or the EEA:Data Protection Commission 21 Fitzwilliam Square South Dublin 2, D02 RD28 IrelandPhone: +353 (0)761 104 800 Email: info@dataprotection.ie Website: www.dataprotection.ie18.3 UK - Information Commissioner's OfficeFor individuals in the United Kingdom:Information Commissioner's Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF United KingdomPhone: 0303 123 1113 Website: www.ico.org.uk18.4 Other JurisdictionsIf you are located outside Ireland or the UK, you may contact the data protection authority in your country of residence.19. California Privacy Rights (CCPA)19.1 ApplicabilityIf you are a California resident, the California Consumer Privacy Act (CCPA) provides additional rights regarding your personal information.19.2 Categories of InformationWe collect the following categories of personal information (as defined by CCPA):Identifiers (names, addresses, email, phone numbers, IP addresses)Personal information under Cal. Civ. Code ยง 1798.80(e) (name, employment history, education)Protected classification characteristics (age, nationality, citizenship)Commercial information (transaction history, payment information)Internet or network activity (browsing history, interactions with our platform)Professional or employment-related information (CV, work history, skills)Education information (qualifications, certifications)Inferences drawn from the above to create profiles19.3 CCPA RightsCalifornia residents have the right to:Right to Know: Request disclosure of personal information collected, sources, purposes, and third parties with whom it's shared.Right to Delete: Request deletion of personal information, subject to certain exceptions.Right to Opt-Out: Opt out of the sale of personal information. Note: We do not sell personal information.Right to Non-Discrimination: Not receive discriminatory treatment for exercising CCPA rights.19.4 Exercising CCPA RightsTo exercise these rights, contact us at shane@recruitroo.com or www.recruitroo.com/contact. We will verify your identity before responding to requests.20. Governing Law and Jurisdiction20.1 Governing LawThis Privacy Policy is governed by the laws of Ireland, without regard to conflict of law provisions.20.2 JurisdictionYou consent to the exclusive jurisdiction of the Irish courts for any disputes arising from this Privacy Policy, except for:Individuals with rights under Privacy Shield or Swiss-US frameworkMandatory consumer protection laws in your jurisdictionClaims that must be brought in supervisory authority proceedings20.3 International UsersYour use of our services may also be subject to local, state, national, or international laws in your jurisdiction.21. Acceptance of This PolicyBy using Recruitroo's services or contacting us directly, you signify your acceptance of this Privacy Policy.If you do not agree to this Privacy Policy:Do not use our website or servicesDo not register for an accountDo not submit applications or informationContact us to discuss your concernsContinued use of our platform following the posting of changes to this Privacy Policy that do not significantly affect the use or disclosure of your personal information will constitute acceptance of those changes.22. Accountability and Compliance22.1 Regular AuditsWe conduct regular internal audits to ensure:Compliance with this Privacy PolicyAdherence to data protection regulationsEffectiveness of security measuresProper handling of data subject rights requests22.2 Staff TrainingAll personnel with access to personal data receive:Comprehensive data protection trainingRegular updates on privacy best practicesSpecific training on handling sensitive informationClear guidelines on data breach response22.3 Data Protection Impact AssessmentsWe conduct Data Protection Impact Assessments (DPIAs) for:New processing activities involving high risksSignificant changes to existing processingImplementation of new technologiesProcessing special category data at scale22.4 Records of Processing ActivitiesWe maintain detailed records of:Categories of data processedPurposes of processingData recipients and transfersRetention periodsSecurity measures implemented23. Specific Use Cases23.1 Talent Pool and Future OpportunitiesWhen we retain your information for future job opportunities:We will request explicit consent to keep your data in our talent poolYou can specify preferences for types of roles and communicationsWe will send periodic updates about relevant opportunitiesYou can update or withdraw your profile at any timeYour data will be reviewed and refreshed periodically23.2 White-Label Platform UsageIf you interact with our platform through a white-label partner:The partner is the primary data controller for their relationship with youWe act as a data processor providing platform servicesBoth we and the partner are responsible for protecting your dataYou should review both our Privacy Policy and the partner's policyRights requests may be directed to either us or the partner23.3 Assessment and Testing DataFor technical assessments and pre-recorded interviews:Video and audio recordings are stored securely and encryptedAccess is restricted to authorized recruiters and hiring managersRecordings are retained only during the active recruitment processYou may request deletion after the recruitment process concludesWe use recordings solely for candidate evaluation purposes23.4 Immigration Application ProcessingWhen we process immigration applications:We collect only data required by immigration authoritiesWe transmit data securely to government agenciesWe maintain records as required by immigration lawWe cannot control how immigration authorities use your dataGovernment agencies have their own privacy policies and practices24. Your Responsibilities24.1 Accurate InformationYou are responsible for:Providing accurate and complete informationUpdating your information when it changesNotifying us of errors or inaccuraciesEnsuring information submitted on behalf of others is authorized24.2 Account SecurityYou must:Keep your password and login credentials confidentialUse strong, unique passwordsEnable multi-factor authentication when availableLog out of shared or public devicesNotify us immediately of unauthorized access24.3 Lawful UseYou agree to:Use our services only for lawful purposesNot misrepresent your identity or qualificationsNot submit false or fraudulent informationComply with all applicable laws and regulationsNot attempt to access others' data or accounts25. Business Transfers and Succession25.1 Merger, Acquisition, or SaleIn the event of:Merger with another companyAcquisition by another entitySale of all or substantially all of our assetsBankruptcy, reorganization, or similar proceedingsTransfer of the business or portions thereofWe reserve the right to transfer information, including personal data, to a third party, provided that:The third party agrees to adhere to terms substantially similar to this Privacy PolicyYou are notified of the transferYou have the opportunity to delete your account before the transferThe third party commits to protecting your data25.2 Due DiligenceDuring business transfer negotiations:Potential buyers may review certain data as part of due diligenceSuch reviewers will be bound by strict confidentiality agreementsAccess will be limited to what is necessary for evaluationWe will minimize disclosure of personal data where possible26. Dispute Resolution26.1 Informal ResolutionWe encourage you to contact us first to resolve any privacy concerns:Email: shane@recruitroo.comWe will acknowledge your concern within 48 hoursWe will investigate and respond substantively within 30 daysWe will work in good faith to resolve disputes amicably26.2 MediationIf informal resolution fails, we are willing to engage in:Good-faith mediation with a neutral third partyAlternative dispute resolution mechanismsIndustry-standard dispute resolution procedures26.3 Legal ActionIf other methods fail, you may pursue:Complaints with supervisory authoritiesLegal action in accordance with applicable lawRemedies available under GDPR, CCPA, or other regulations27. Accessibility27.1 Accessible FormatWe strive to make this Privacy Policy accessible to all users. If you need this policy in an alternative format:Large printAudio formatTranslated languageScreen-reader compatible versionPlain language summaryPlease contact us at shane@recruitroo.com.27.2 AssistanceIf you need assistance understanding or exercising your privacy rights, we can provide:Phone support for explanationsWritten summaries of key pointsGuidance on submitting requestsSupport in your preferred language (where available)28. Contact Information28.1 General Privacy InquiriesEmail: shane@recruitroo.com Website: www.recruitroo.com/contact Phone: +353 (contact via website for current number) Mail: Recruitroo Ireland Ltd, 19 Baggot Street Lower, Dublin 2, D02 X658, Ireland28.2 Data Subject Rights RequestsFor requests to access, correct, delete, or port your data, please use the contact information above with "Data Subject Rights Request" in the subject line.28.3 Security ConcernsTo report security vulnerabilities or data breaches, contact us immediately at shane@recruitroo.com with "URGENT: Security" in the subject line.28.4 Business HoursOur privacy team is available:Monday - Friday: 9:00 AM - 5:00 PM GMT/ISTEmergency security matters: 24/7 via emailWe aim to respond to all inquiries within 48 hours.29. Definitions of Processing ActivitiesCollection: Gathering personal data from any sourceRecording: Storing personal data in any formatOrganization: Structuring and arranging personal dataStructuring: Organizing data in databases or systemsStorage: Keeping personal data for any periodAdaptation/Alteration: Modifying or updating personal dataRetrieval: Accessing stored personal dataConsultation: Viewing or reviewing personal dataUse: Processing data for any purposeDisclosure: Sharing data with third partiesDissemination: Making data available to othersAlignment/Combination: Merging data from multiple sourcesRestriction: Limiting how data can be processedErasure: Deleting or destroying personal dataDestruction: Permanently removing data beyond recovery30. Glossary of Technical TermsAnonymization: Process of removing identifying information so data cannot be linked to individualsData Controller: Entity that determines purposes and means of processing personal dataData Processor: Entity that processes data on behalf of a controllerData Subject: Individual whose personal data is being processedEncryption: Converting data into coded format to prevent unauthorized accessPseudonymization: Processing data so it cannot be attributed to a specific person without additional informationProfiling: Automated processing to evaluate personal aspects of an individualProcessing: Any operation performed on personal dataAppendix: Document Version HistoryVersion 3.0 - October 5, 2025Comprehensive update of entire policyAdded AI and automated decision-making disclosuresEnhanced data security sectionExpanded international transfer provisionsAdded California privacy rights (CCPA)Clarified white-label platform arrangementsUpdated data retention periodsAdded accessibility provisionsVersion 2.0 - October 1, 2023Updated for GDPR complianceAdded cookie policy detailsExpanded data subject rightsVersion 1.0 - 2022Initial privacy policyLast Updated: October 5, 2025 Effective Date: October 5, 2025 Next Scheduled Review: October 2026This Privacy Policy is a living document and will be updated as our services, regulations, and best practices evolve. We encourage you to review it periodically to stay informed about how we protect your privacy.
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