Privacy Policy

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1.  Introduction

GotCred is owned and operated by GotSkill Platforms Limited ABN 64 608 184 578 ("GotSkill").

GotCred’s purpose is to help people get jobs done better, faster and safer through provision of its trusted credential storage, sharing and monitoring service between Workers, Employers and their customers.

GotCred values the trust our users and customers place in us when they give us access to their personal data. This Privacy Policy describes how we work to maintain that trust and protect that information.

In particular, this Privacy Policy details our collection, use and disclosure of personal and non-personal data you give to GotCred when you access or use GotCred’s online and/or mobile services and websites, and software provided by GotCred on or in connection with such services or websites (collectively, the “Site”).

1.1  The GotCred Entities Responsible for Your Information

For the purpose of this Privacy Policy:

 (a)  “Employer” means any organisation that has joined GotCred as an Employer and has accepted our Terms and Conditions to receive credentials shared by Workers (with their consent) to the Employer for the purpose of viewing details and notifications about the completeness and currency of credentials of job applicants and employees as required by the Employer.

 (b) “Non-Personal Data” refers to any information that does not identify you as a specific individual.

 (c)  Personal Data” refers to any information that relates to an identified or identifiable individual.

 (d)  Worker” means any natural person who has joined GotCred as an individual member and has accepted our Terms and Conditions for storage, maintenance and sharing of their credentials.

 (e)  “Share” means any Personal and Non-Personal Data selected by a Worker from within their profile which they consent to be provided to a person nominated by that Worker.

Please note that GotCred will adhere to the applicable statutory definition in determining what is and is not Personal Data for the purposes of this Privacy Policy. Where this Privacy Policy refers to “information” or “your information” this may include both Personal and Non-Personal Data.

 

1.2 The Scope of GotCred’s Privacy Policy

This Privacy Policy only covers data that we collect through the Site. The Privacy Policy does not cover any other data collection or processing, including, without limitation, the data collection practices of any affiliate or other third party, including any third-party operators of web pages to which the Site links, and any information that we collect offline or through any websites, products, or services that do not display a direct link to this Privacy Policy.

Occasionally, we may refer to this Privacy Policy in notices on the Site, including special purpose web pages, mobile applications, or other resources, for example, if we invite you to submit ideas to improve the Site. This Privacy Policy applies to information collected by us through such special purpose resources, as modified in the particular notice (e.g with respect to the types of data collected or our uses or disclosures of such information). GotCred may amend this Privacy Policy at any time.

1.3 Changes to the Privacy Policy

Please review the “Last Updated” legend at the top of this page to determine when this Privacy Policy was last amended. Any changes to this Privacy Policy will become effective on the “Last Updated” date indicated above. By using the Site or providing information to us following such changes, you will have accepted the amended Privacy Policy. If GotCred is going to use Personal Data collected through the Site in a manner materially different from that stated at the time of collection, then GotCred will notify users via email and/or by posting a notice on GotCred’s Site for 30 days prior to such use or by other means as required by law.

1.4 GotCred’s approach to privacy and the General Data Protection Regulation (GDPR)

Please note this Privacy Policy describes, in a comprehensive manner, how GotCred processes your data. For more information on GotCred’s approach to privacy and GDPR see section 11.3 of this policy.

2.  Information Collected

You provide different types of information in order for GotCred to provide our services, products and features to you. GotCred associates this information with your account to create your GotCred Profile.

2.1 Information You Provide to GotCred

– From Your Account

We collect data from you when you create an GotCred account, request information, subscribe for a service, participate in a survey, post a rating or review, post a question or answer, post a credential, upload content or otherwise actively send us data on our Site. This may include, but is not limited to, your user name, password, first and last name, email address, telephone number (including mobile phone number), street address, gender, occupation, interests, messages you send to users, and any other data included in a submitted profile or credential, including but not limited to application materials and answers to questions submitted to Employers through GotCred and answers you give to any questionnaires sent to you. This information may be associated with your profile.

You may provide your specific location data when you provide it yourself on the GotCred Apps (as defined in the GotCred Terms of Service Introduction) to help you find more relevant roles (including from the location service on your mobile device when you grant permission to a GotCred App), or when you submit a photo to a credential that includes the provision of the location data of where the photo was taken. GotCred seeks your consent at the time of such provision, and such processing will only be performed where consent is secured.

– Through Your Activity on GotCred

In addition, as part of the standard operation of the Site, GotCred may collect and analyze information from your computer or mobile device and actions taken on the Site, including, but not limited to, your credentials, your searches on GotCred, the titles of roles you search, click on or apply to, where those roles are located, salary interest or experience, the general salary range or experience level of the roles you view (where indicated), your activity time on the Site and each page, page views, clicks, taps, session activity, browser type, operating system, type of device, MAC address, IP address and the domain name from which you accessed the Site.

– When Providing Employer Information

If you are an Employer, GotCred may request that you provide certain Personal Data to GotCred in order to verify your account. This information may include, but may not be limited to, your identity documentation (ID), Business Registration information, a utility bill, or the name and email address of an Employer representative.

This information will be used for internal purposes only, subject to any request by law enforcement or a court order. In connection with chargeable services, we will also collect payment information (e.g. the last four digits of credit card numbers and related verification information). Please note that GotCred only has access to the last four digits of Employer credit card numbers and does not store full credit card numbers.

2.2 Information Collected When You Apply for roles or Access GotCred from Some Third-Party Websites

– When You Apply to Jobs on Some Third-Party Sites

GotCred may also collect information about web sites and web pages you visit through GotCred, about job postings that you save, notes or applications statuses that you save or update, or data regarding how you engage with websites or other actions you take on such website, including URLs of websites you visit. We do this in order to allow a Worker to keep a record of particular job listings  of interest, to detect a job application form on a third-party website to give a Worker the option to auto-fill parts of the form using data in your GotCred profile , or to confirm an application. GotCred may learn about what types of jobs and GotCred product features are of interest to you, so that we can provide you with improved job listing searches, job listing recommendations and product features.

 

When you apply through GotCred for a job that is hosted on a third party website, GotCred may also receive information about the status of your job application and the decisions taken by the Employer in disposing of your application, such as, for example, whether the application reached interview stage and whether a job offer was accepted or rejected. This information helps GotCred further understand the effectiveness of our Site and its features. GotCred uses this information for the purpose of improving the products and services we offer to Workers and Employers and as otherwise detailed in section 4 of this Privacy Policy.

When You Log In or Use GotCred from Some Third-Party Sites

You may also create an account or log in to your GotCred account using third-party websites including, but not limited to, Facebook or Google. If you do not already have a GotCred account but log in to GotCred using your Facebook or Google account, this creates a GotCred account using the same email address used in your Facebook or Google account. If you agree to provide this information to GotCred, Facebook or Google will authenticate you and redirect you to GotCred’s Site. Please note, when you log in to GotCred using your Facebook or Google account, Facebook or Google will cookie you in order to authenticate you as a Facebook or Google user.

By accessing GotCred through your Facebook or Google account, you understand that Facebook or Google will share certain data detailed in the above paragraph for the purposes of authentication to permit you to access our Site in a secure manner. You may stop this at any point from your Facebook or Google account. This information will be considered GotCred account information for purposes of your use of the Site.

You can disable the connection between your Facebook or Google account and your GotCred account at any time by accessing your privacy settings on your Facebook or Google account. Facebook or Google may also ask for your permission to share certain other details with GotCred, including but not limited to your name, profile picture, public profile information, and email address. Once you give this permission, the requested information will be shared with GotCred, who may use this information to provide services  to you, including populating your GotCred profile. The shared information will remain associated with your GotCred profile until you modify or delete it.

PLEASE NOTE THAT YOUR RELATIONSHIP WITH FACEBOOK OR GOOGLE OR ANY OTHER THIRD-PARTY WEBSITE IS GOVERNED SOLELY BY YOUR AGREEMENT WITH SUCH THIRD-PARTY WEBSITE.

2.3 Any Other Personal Data GotCred May Receive from Third Parties

Any Personal Data that GotCred may obtain from other third-party sources will be processed by GotCred in accordance with this Privacy Policy and all applicable laws.

2.4 Storage of Your Information

GotCred stores your personal data until it is no longer necessary to provide our services or until you ask us to delete your personal data. As one example, if an Employer deletes a Worker credential share in its dashboard on GotCred, GotCred may delete information associated with that Share . As another example, after a Share has been established with an Employer in connection with a job application, GotCred may retain details of the Share for such time as the Share remains in the Worker’s dashboard. We may also be required to retain certain information in order to comply with local laws.

If you create a GotCred account, your information may be collected and stored in a manner that connects to your account email address. GotCred may also create and assign to your device an identifier that is similar to an account number. We may collect the name you have associated with your device, device type, telephone number, country, and any other information you choose to provide, such as username, email address, or postal code. For example, while using a mobile device to access GotCred, GotCred may provide a Worker with relevant job postings that are located within the same postal code as where this activity is taking place. The collection of this data is solely used in accordance with the purposes outlined in sections 4, 5 and 9 of this Privacy Policy, to the extent applicable.

GotCred may also store the information detailed in this section 2 of the Privacy Policy on its equipment or the equipment of third parties that GotCred has a relationship with. Such storage services will be governed by appropriate protections, as required by applicable rules.

2.5 What Personal Data is Required

GotCred will indicate to you at the point of provision what Personal Data is required from you in order to provide a particular GotCred service or feature. Where the required Personal Data is not provided by you then the particular feature or service may not be available to you.

2.6 The Legal Basis on Which GotCred Collects Your Personal Data

GotCred collects and processes your Personal Data on the basis of different legal grounds, depending on the nature of the Personal Data being provided and the type of processing involved. More information is provided below.

– Performance of a Contract

Personal Data may be processed by GotCred on the basis that it is necessary for the performance of our agreement with you, or in order to take steps at the request of the user prior to entering such an agreement. An example of this would be where GotCred shares a Worker’s credentials with an Employer.

– Legitimate Interest

Other types of processing of your Personal Data is necessary for the purposes of legitimate interests pursued by GotCred. Such legitimate interests will include where GotCred sends you marketing about our products and services, where we believe you have a reasonable expectation that we will perform a particular type of processing on your behalf, or where such processing is strictly necessary for fraud detection and prevention. A further example would be where GotCred shares your Personal Data with GotCred affiliates as detailed in section 4.13 below.

GotCred will only rely on such a ground where an assessment has been performed balancing the interests and rights involved and the necessity of the processing in order to provide our services, products and features to you.

 - Compliance with a Legal Obligation

GotCred may need to perform certain types of processing in order to allow GotCred to comply with a legal obligation. An example of this would be where GotCred is required to retain business records for fixed periods of time in order to comply with local legal requirements.

– Consent

Finally, in certain situations, GotCred relies on your consent in order to process your Personal Data. Where GotCred requires your consent in order to collect, process or share certain Personal Data, we seek your consent at the time of provision, and such processing will only be performed where consent is secured.

For example, your consent will be sought when you elect to share selected credentials when you provide it yourself on the GotCred Apps to help you find relevant roles (including from the location service on your mobile device when you grant permission to an GotCred App), when you submit a photo that includes the provision of the location data of where the photo was taken. You can withdraw your consent, as detailed in section 10 of this Privacy Policy where applicable, or by sending an email to [email protected].

3.  Limitations of Use

3.1 Where a Worker Wants to Close a Worker Account

When a Worker closes an account, the Worker will no longer have access to any of the data we make available under that account name, including but not limited to, shares history, credentials data and images, roles the Worker has applied for, expiry alerts, resumes, and any other data associated with the account. If the Worker uses the same email address to set up a new account, the data from a previous account may not become available to the Worker again. Please also note that closing your Worker account may result in you losing access to all GotCred products and the ability to utilize the “Log in with GotCred” feature that may be found on certain third-party sites.

GotCred reserves the right to keep any materials in a closed account as necessary to preserve and protect its rights to the extent permitted by law (for example, to preserve records of a dispute) or to comply with its obligations under local law (for example, if requested to retain by law enforcement). A closed account does not mean that all of the data is expunged from the GotCred systems, although it will not be readily available under the Worker’s original account name. When the Worker presses the close account button on the dashboard, GotCred will begin to process that instruction within 24 hours and it aims to have completed the operation within 30 days.

If a Worker wishes to access or delete their Personal Data held by GotCred, they should follow the steps listed in section 10 of this Privacy Policy, and such a request will be processed in accordance with applicable rules.

3.2 Where an Employer Wants to Close an Employer Account

Employers may close an account at any time by contacting GotCred Customer Support at [email protected] Please note that GotCred must preserve business records pertaining to that account to comply with its obligations under law. Alternatively, if an Employer agent wishes to access or delete their Personal Data held by GotCred, they should follow the steps listed in section 10 of this Privacy Policy, and such a request will be processed in accordance with applicable rules.

3.3 Where a Worker Wants to Delete a credential share

If a Worker wants to delete a credential share on GotCred’s Site, they should withdraw consent for that share on the GotCred app and are advised to contact the Employer share recipient directly to request deletion of their share records. For credential shares which you, the Worker submit through GotCred (including the use of a GotCred share) to an Employer, (with related materials submitted), please note: 1) that your credential shares and materials may be controlled by an Employer; 2) we may direct you to that Employer for Personal Data deletion requests where that Personal Data is held by that Employer; and 3) GotCred depends on the Employer or the Employer’s agent to provide GotCred with the correct destination for all credential shares.

3.4 Where the Employer Contact Details Provided to GotCred Are Incorrect

In the event that the Share party details provided to GotCred are incorrect, your intended Share data will not be received by the intended recipient of the Share. GotCred has no liability for such Shares.

3.5 Minimum Age of our Users

The Site is not for use by anyone under the age of 16. However, if local laws provide for an alternative minimum age for GotCred to lawfully provide the services in the Site to you, then that shall apply as the applicable minimum age. In all jurisdictions outside the European Union, if you are under the age of 18 or the age of majority in your jurisdiction, you must use GotCred under the supervision of your parent, legal guardian or responsible adult.

GotCred adopts a range of measures to try to ensure that we do not accept individuals who do not meet the minimum age and any other applicable age requirements. If you do not satisfy these age requirements, please email [email protected].

4.  Purposes, Uses and Disclosures of Information

We may use any information collected pursuant to this Privacy Policy, including Personal Data, for the purposes set forth in sections 4, 5 and 9 of this Privacy Policy, to the extent applicable. GotCred associates Personal Data with your GotCred profile in order to perform the activities described in this Privacy Policy. GotCred uses such information to help Workers fill roles and to help Employers fill roles. In order to do this, we use your Personal Data to:

 1)  provide our services, products and features to you, to help Workers fill roles and Employers fill roles;

 2)  to measure and improve those services, products and features; and

 3)  to protect our users and provide them with customer support.

More detail on these purposes, uses and disclosures of your information is set out below.

4.1 Creating an Account, Sending You Alerts and Other Promotional Materials

If and to the extent permitted by applicable law, GotCred may use your contact information to (i) create an account; (ii) send you Alerts (as defined below); and (iii) send you information about GotCred, including promotional materials. GotCred may use third-party partners to perform these activities on GotCred’s behalf.

An “Alert” is defined as an email or in-app notification that you sign up for containing information in response to a search query you have run or the status of your credentials. A “Company Alert” is one type of job alert which contains job listings and other information you have requested regarding a company. “Role Alerts” may include roles that GotCred identifies for you, GotCred targeted ads, companies you may be interested in following, or other actions you may want to take on the Site. GotCred may adjust the frequency of Role Alerts.

GotCred may also share your information with third parties (including operators of third-party websites and/or social networking sites) in order to show you targeted advertisements and other content that has been customised for you. Such advertisements will only relate to GotCred’s services, products, and features, all of which focus on helping Workers fill roles and Employers fill roles. If you wish to opt out of receiving any marketing messages from GotCred please see section 10.3 of this Privacy Policy.

4.2 Giving You Relevant Search Results and Recommended Roles

In order to optimize our services, products and features for you, GotCred may use your previous search and browsing history (e.g. the roles you may wish to fill) to identify you and determine relevant search results and provide you with recommended roles or reach out to you about roles you may be interested in. We may also use credential data to tailor your experience on the Site, to show you content that GotCred thinks you may be interested in, and display content according to your preferences. GotCred may return different results for the same search query and has full discretion with respect to the role listings it presents in response to any particular search.

4.3 Your Contact Information

When you give GotCred contact information (such as your name and email address) and other forms of Personal Data and Non-Personal Data, you agree that GotCred may utilise this information for the purposes outlined in sections 4, 5 and 9, to the extent applicable. In particular, you agree that GotCred may, as part of its services to you, communicate with you, or initiate communication with you on behalf of a third party, through your GotCred account or through other means such as email, telephone (including mobile phone), or postal mail, including through the use of contact information that you may provide to GotCred or that GotCred may otherwise obtain from third-party resources.

4.4 Your Credentials and Resume Information

Your information, including Personal Data, gets placed on the Site when you upload or edit a credential or resume, which becomes part of your GotCred profile. GotCred reserves the right to charge third parties a fee for accessing your information, including Personal Data, as part of GotCred’s services. At your direction, GotCred may also share your credentials or resume to third parties if you choose to share them. The extent to which your information is made available to third parties depends on the privacy settings you choose on GotCred, in accordance with this Privacy Policy. When a Worker creates a profile on GotCred, their profile and credentials are not shared by default, and the Worker may change their credential and resume sharing settings at any time.

– Changing Your Resume Privacy Settings

When you share your credentials or resume on GotCred with an Employer, it will not be public by default. Additionally, Employers who have saved your shared credentials or while it was shared may continue to have access to your credentials or resume even after you have cancelled the Employer share.

4.5 Matching Workers With Employers

You acknowledge that GotCred may determine whether the words of your credentials or resume or any other individuals’ resume match the words of certain job descriptions, and vice versa, in order to improve the Site or any other GotCred product or service (including by notifying you or Employers about potentially relevant credential descriptions and resumes to Workers and Employers).

GotCred may also provide information collected pursuant to this Privacy Policy, including Personal Data, to Employers that may be interested in contacting you. By sharing credentials for a role, or by replying to a message from an Employer, you agree to the disclosure of your shared information to that Employer. GotCred may also use information provided to GotCred via your GotCred profile to pre-populate application information for you and for similar purposes.

If you have a GotCred account, you agree that GotCred may contact you or suggest you to Employers that might be interested in a person who matches your behavior on GotCred.

4.6 Sending Messages on GotCred

GotCred may provide two-way message proxy and relay services to the users of our GotCred products (“Relay Service”). By utilizing any Relay Service, you acknowledge that you are asking GotCred to send these messages on your behalf. This includes your Share credentials or other information.

We process, monitor, review, store and analyse such content, including via automated means, for data analysis, quality control, enforcement of the Site use terms and conditions  and other GotCred policies, content moderation, and to improve the Site or any other GotCred product or service. Examples of such improvements would be improving the open rate of messages by optimizing their delivery, optimizing our search results, improving role listings, permitting applicants to manage their credential Shares after transmitting them to GotCred, ensuring you are provided with personally relevant product features and communications, and preventing fraud and spam. As a result of this activity, or due to technical malfunction, in certain circumstances such content may be delayed or may not be delivered to the intended recipient. GotCred may (but is not obligated to) notify you in such an event. By using a Relay Service or otherwise providing user content through the Site, you agree to this activity and acknowledge that this activity is necessary for maintaining the quality of the Site and for providing the Relay Service.

4.7 Sending You Text Messages

GotCred may offer you the opportunity to receive text messages from GotCred. In such an event you will enter your phone number in your GotCred profile. By entering your mobile phone number, you are representing and confirming it is your number and that you have the right to accept text messages at the number. You agree to accept such text messages on your mobile phone, including messages sent by automated telephone dialing system. To unsubscribe at any time, reply to the text with STOP or contact GotCred Customer Support at [email protected]

4.8 Facilitating Telephone Relay System Between Workers and Employers

Where applicable, GotCred may offer Workers and Employers the option to avail of a telephone relay system to facilitate contact. Such a system generally uses masked or proxy telephone numbers to protect users and is only available to users who select it on the Site. No recording of conversations or messages is performed through this relay system, although data relating to whether a call was answered, and call duration may be gathered. Such functionality is provided to GotCred by third party service providers such as Twilio.

4.9 Facilitating Text Messaging Relay Service Between Workers and Employers

GotCred may offer Workers and Employers the ability to avail themselves of an autodialed text messaging relay service to facilitate contact. To unsubscribe at any time from such services, reply STOP by text message to the telephone number or short code provided or contact GotCred Customer Support. 

4.10 Preventing Fraud and Spam

GotCred may also use information collected pursuant to this Privacy Policy to help diagnose problems with the Site and GotCred’s service, to prevent potentially fraudulent or illegal activities, and to protect individuals from other activities that may be detrimental to you or others. GotCred may investigate and disclose information from or about you or your use of GotCred, if we have a good faith belief that such investigation or disclosure (a) is reasonably necessary to comply with legal process (including subpoenas, search warrants, court orders) and law enforcement instructions and orders; (b) is helpful to prevent, investigate, or identify possible wrongdoing in connection with the use of the Site; (c) may protect our rights, reputation, property, safety, or that of the public; or (d) as necessary to meet national security requirements.

We may use a variety of methods to detect and address anomalous activity and screen content to prevent abuse such as spam or fraud. However, such detection methods are not perfect and false positives may occur. These efforts may, on occasion, result in a temporary or permanent suspension or termination of some functions for some users.

– Preventing Fraud and Spam in Messages

GotCred also reserves the right to drop messages from our relay system that GotCred determines do not adhere to Site Rules or any of the terms of this agreement. GotCred further reserves the right to conduct investigations to determine whether you are perpetrating a scam, spamming GotCred or its users, or otherwise conducting fraudulent activity on GotCred by various means, including but not limited to investigating your functionality by setting up profiles and names that belong to GotCred. GotCred also reserves the right to turn over any information gathered via such investigations to the police or other third party if GotCred has a good faith belief that you are using the Site in violation of these terms.

GotCred reserves the right to verify and confirm the identity of any party associated with an email relay. This includes but is not limited to verifying the identity of the sender of an email with the Employer agents associated with that email address on the relevant role.

4.11 Facilitating Payment

If you provide credit, debit or other payment card or related details to us in order to make a payment, GotCred will use such information only for the purpose of processing the payment (e.g. the last four digits of credit card numbers and related verification information). Any credit card and related billing and payment information that you provide to GotCred may be shared by GotCred with companies who work on GotCred’s behalf, such as payment processors and/or credit agencies, solely for the purposes of checking credit, effecting payment to GotCred and servicing your account.

4.12 Automated Processing of Your Personal Data

In order to optimize the performance of the GotCred Site and services for users, GotCred performs automated processing of Personal Data evaluating certain specific aspects relating to a user, in particular to analyse or predict aspects concerning a user’s personal preferences or interests in terms of GotCred’s Site and services. Where it occurs, such processing is carried out if necessary for the performance of our agreement with our users, to allow GotCred to provide its services to Workers and Employers (including analysing credentials and resumes on behalf of Employers), or in other cases on the basis of a user’s consent.

For example, in certain cases such processing allows GotCred to match Workers with Employers effectively, to provide Workers with Alerts and recommended roles that the Worker is likely to be more interested in, to send particular redacted Worker credentials to an Employer, to display search results, or to perform certain spam and fraud detection activities to protect our users. Such processing is subject to the safeguards detailed in this Privacy Policy to protect the privacy of our users. Please contact [email protected] to contest any decision generated by said automated processing.

4.13 Sharing your Information with GotCred Affiliated Entities and Websites

GotCred’s purpose is to help people get jobs done better, faster and safer. We help Workers get and retain roles they are qualified for and Employers find and retain Workers who are qualified for the work they need done. In order to support that purpose, we share certain information with our affiliates. Such information sharing is governed by this Privacy Policy.

Information shared by you with GotCred may be shared with any GotCred affiliated entity, no matter where located, to provide you with services, to improve and optimize functionality on the Site, and other purposes as described in this Privacy Policy. Sharing strengthens GotCred’s ability to help Workers get and retain roles they are qualified for and Employers find and retain Workers who are qualified for the work they need done. The services provided to you and the functionality of the Site could not be provided without such transfers. If you do not wish your information to be transferred in this way you should not use this Site.

For the purposes of this Policy, “affiliates” means any entity that directly or indirectly, controls, is controlled by, or is under common control of or with a GotCred entity, now or in the future. “Control” for these purposes means having a majority of shares or the right and ability to direct management. This includes GotCred affiliated entities located outside the European Economic Area (“EEA”) or Switzerland.

Examples of our affiliates and affiliated websites include SkillTracker Global Pty Ltd.

Such data sharing with GotCred affiliates will be performed for a number of specific reasons.

– Improved Services

It provides Workers with more personalised and improved content, performance, features and services on GotCred and its affiliates’ sites. For example, GotCred and its affiliates may use your previous search and browsing history (e.g. the roles you click on), IP address, or your credentials, resume or profile information, to determine relevant search results, Alerts, displays and moderate insights. Such sharing is also performed to facilitate improved data analysis, testing, research, and service improvement.

– More Employers, More Role Listings and More Workers

Such data sharing allows Workers to access an even broader database of job listings and Employers, and for Employers to access more Workers. For example, this allows GotCred to recommend roles for Employers on GotCred or on websites of GotCred affiliates. It also facilitates credential sharing and the display of role listings from the Site to GotCred affiliates’ websites and vice versa.

GotCred or a GotCred affiliate is able to recommend a GotCred Worker (and that Worker’s credentials or resume) to an Employer hosted by GotCred or to an Employer hosted by a GotCred affiliate. Equally, a GotCred affiliate is able to recommend a role listing hosted by a GotCred Employer to a Worker hosted by a GotCred affiliate. GotCred and its affiliates can also share Employer data (such as account information and behavioral data) to provide a better experience to those Employers.

– Better Security for Users

Such data sharing allows GotCred and GotCred affiliates to process your Personal Data for the purpose of improving user security and internal operations, troubleshooting, and detecting and preventing fraud and spam.

4.14 Transfers of Information to Employers

GotCred sends Worker Personal Data to Employers on the instruction of Workers. Such transfers are performed in the course of the role search and credential sharing. This is further described in sections 2 and 4 of this Privacy Policy. Such Personal Data will be processed in accordance with these terms and those of the relevant Employer. Workers that apply for roles through GotCred that are outside their own country may involve sending their Personal Data to countries with lower levels of data protection.

Employer account holders agree to comply with all their responsibilities under applicable data protection rules with respect to the collection, processing and storage of Personal Data, as well as providing adequate protection of all data subject rights provided for under all applicable data protection rules.

4.15 Transfers of Information to Workers

GotCred sends certain Employer-related information to Workers. This includes publishing job ads, company pages, and salary information. As an Employer, when you use GotCred you agree that GotCred may provide this information to Workers.

4.16 Transfers of Information to Service Providers

We may use third parties to perform services in connection with our operations, to improve the Site and our services, products, and features, to protect our users and better understand their needs, and to optimize the services and the users’ experiences. These service providers may have access to Personal Data in the course of providing these services, which may involve transfers of such Personal Data to other countries. Such transfers are only made for the purposes set forth in sections 4, 5 and 9 of this Privacy Policy, to the extent applicable and necessary.

– Improving our Services

These third parties may provide data points including how much time you spend on specific pages, which links you choose to click, and data that helps determine user preferences. This information enables us to build and maintain our services with user feedback. These third parties may use cookies and other technologies to collect data on your behavior and devices such as the device type, browser information, and preferred language.

– Maintaining Quality and Protecting Users

GotCred may transfer your Personal Data in limited situations to certain third-party vendors that assist GotCred with protecting our users and maintaining the quality of our services, products and features provided. An example would be vendors GotCred may use for fraud detection purposes. Another example would be vendors GotCred uses to prevent accounts being created using account credentials that have been publicly disclosed.

– Facilitating Payments 

GotCred may also share any credit card and related billing and payment information that you provide to GotCred with companies who work on GotCred’s behalf, such as payment processors and/or credit agencies, solely for the purposes of checking credit, effecting payment to GotCred and servicing your account.

– Installing or Using a GotCred App

In order to provide you with certain services and support ad attribution, limited user data may be shared with certain service providers when you install, download or use a GotCred App. This may include your IP address or other unique identifier, and event data related to the installation of the GotCred App.

This may be done for a variety of purposes, including facilitating user log-in through third party accounts. It may also assist GotCred to understand and optimize our users’ complete customer journey by helping us: (i) understand how users arrive to GotCred; (ii) better measure the performance of our ads; and (iii) understand where a user has accessed GotCred through different devices.

When you download or install a GotCred App, you acknowledge and accept that your Personal Data may be transferred to these service providers. You also agree to GotCred’s Cookie Policy, Privacy Policy and Terms of Service, and are informed that you may avail of your rights at any time, as detailed in section 10 of this Privacy Policy, including the right to object to the legitimate interest use of your personal data for marketing purposes.

– Storage

Please also be aware that we may also use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that may be non-negotiable. These service providers have informed us and the general public that they apply security measures they consider adequate for the protection of information within their system, or that they have a general reputation for applying such measures. However, we will not be liable (to the fullest extent permitted by law) for any damages that may result from the misuse of any information, including Personal Data, by these companies.

4.17 Transfers of Publicly Available Information

When users post content on GotCred in a manner that is intended to make that content publicly available and searchable by individuals, GotCred reserves the right to aggregate and share that information with third parties. For example, if an Employer posts a job on GotCred, GotCred may share that job posting or information contained within that job posting with third parties, at GotCred’s discretion (subject to agreement between GotCred and any such third parties). GotCred also reserves the right to share information aggregated from public sources in this capacity.

4.18 Third-Party Sites You Link to from GotCred

You may also use certain third-party sites or services that you link to from GotCred’s Site. In such cases, all information you provide to a third party is provided to that third party and not to GotCred and is subject to the third-party’s privacy policy and terms of service. Please see section 8 of this Privacy Policy titled Links to Third-Party Sites for more information.

4.19 Transfers of Personal Data for individuals in the EU (including the European Economic Area (“EEA”)) and Switzerland

Please see section 11 of this Privacy Policy for information related to this.

5.  Additional Uses and Disclosures of Non-Personal Data

In addition to the other uses and disclosures of information set forth in this Privacy Policy, and notwithstanding anything in this Privacy Policy to the contrary, we may use and disclose, for any purpose, any Non-Personal Data, except where we are required to do otherwise under applicable law. If we combine any Non-Personal Data with Personal Data, then we will only use and disclose such combined information for the purposes described in sections 4 and 9 of this Privacy Policy while it is so combined.

6.  Security

GotCred seeks to use reasonable security measures to help protect against the loss, misuse and alteration of the Personal Data under GotCred’s control. However, no method of transmission over the internet, or method of electronic storage, is 100% secure. In addition, please note that emails, messages sent via your web browser, and other similar means of communication with other users, are not encrypted. Therefore, while we strive to protect your information, we cannot guarantee its security.

Please also be aware that we may use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that may be nonnegotiable; these service providers have informed us or the general public that they apply security measures they consider adequate for the protection of information within their system, or they have a general reputation for applying such measures. However, we will not be liable (to the fullest extent permitted by law) for any damages that may result from the misuse of any information, including Personal Data, by these companies. Please see section 11 of this Privacy Policy for liabilities pertaining to the transfer of Personal Data of individuals in the EEA and Switzerland. 

7.  Cookies

“Cookies” are small pieces of information that are stored by your browser on your computer’s hard drive. Please see our Cookie Policy for further information regarding GotCred’s use of Cookies.

– Do Not Track Requests

We do not respond to the browser “Do Not Track” (DNT) signal if enabled by the user in their web browser. We do not share any information about your use of GotCred with third parties. When third parties that we have integrated into GotCred sites (as described in the GotCred Cookie Policy) set or read their own third-party cookies, they may or may not respond to the DNT signal.

8.  Links to Third-Party Sites

The Site may make available links to other websites. When you click on such links, you may leave our Site. Your web browser may also disclose to the third-party site the URL of the GotCred page you clicked from, and this URL may include search terms and filters you used on GotCred. The Site may also make available company pages, which may contain information provided by third-party Employers.

WE ARE NOT RESPONSIBLE FOR THE INFORMATION COLLECTION, USE, DISCLOSURE OR OTHER PRIVACY PRACTICES OF ANY THIRD PARTY, INCLUDING OUR AFFILIATES, THIRD-PARTY SERVICE PROVIDERS, ANY EMPLOYERS (INCLUDING ANY EMPLOYER THAT PROVIDES A COMPANY PAGE), ANY THIRD-PARTY SOCIAL MEDIA PLATFORM, ANY THIRD PARTY MAKING AVAILABLE THE DEVICES OR OPERATING SYSTEMS FOR WHICH THE SITE IS AVAILABLE, AND ANY THIRD PARTY OPERATING ANY WEBSITE TO WHICH THE SITE CONTAINS A LINK. YOU MAY HAVE RIGHTS DIRECTLY ENFORCEABLE AGAINST THESE THIRD PARTIES SO YOU SHOULD CONSIDER THEIR PRIVACY POLICIES TO LEARN MORE.

9.  Acquisitions and Other Reorganizations

Information collected pursuant to this Privacy Policy, including Personal Data, may be disclosed to one or more third parties in connection with any change of ownership or control in GotCred’s business (whether by merger, sale, or otherwise), or any other reorganization or joint venture, or assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceeding), and any such information may be used by such third party in accordance with this Privacy Policy. Equally, information collected pursuant to this Privacy Policy, including Personal Data, may be disclosed to one or more third parties in connection with any acquisition or merger involving GotCred.

10.  Exercising Rights with Respect to Personal Data

GotCred users that provide their Personal Data to GotCred may avail of the rights detailed below. If you would like to seek access to Personal Data we hold about you, or if you have any questions or complaints about how we collect, use, disclose, manage or store your personal information, you can contact our Privacy Officer as follows:

Privacy Officer 

GotCred
Phone: +61 (0)8 9321 8619
Email: [email protected]
Mail: Unit 5, 62 Ord Street, West Perth, WA 6005, Australia

10.1 The Right to Rectify Your Personal Data

GotCred users are able to edit and update most of their Personal Data held by GotCred on the Site, and if you have any queries or complaints, we encourage you to contact our Privacy Officer.

Alternatively, you may make a formal request to have GotCred rectify any inaccurate Personal Data on your behalf by sending an email to [email protected] from the email address associated with your account.

10.2 The Right to Object to or Restrict the Processing of Your Personal Data

If you have any queries or complaints about how we process your Personal Data, we encourage you to contact our Privacy Officer.

Alternatively, you may make a formal request to object to, or restrict, processing of your Personal Data by GotCred. For example, you have the right to object to the legitimate interest processing of your Personal Data by GotCred for marketing purposes. In order to do so, please send an email to [email protected] from the email address associated with your account.

10.3 Opting Out of Marketing Messages and Withdrawing Consent

If you no longer want to receive marketing materials from us based upon your Personal Data, there are several options available to you.

If you wish to opt out of a particular marketing email from GotCred, you may do so by clicking “unsubscribe” (or an equivalent action). Please note that this will only opt you out of that particular marketing message.

If you wish to adjust all your credential shares, you can click on “edit share” (or an equivalent action) to adjust your shares from your account dashboard or contact GotCred Customer Support at [email protected] 

In addition, you may opt out of all marketing messages or withdraw your consent from any consent-based processing by sending an email to [email protected] In your message, please detail which activities from which you wish to opt out or withdraw your consent. We will comply with your request as soon as reasonably practicable, and in accordance with applicable laws.

Finally, please note that we may still send other messages to you, such as administrative messages.

10.4 The Rights of Access to and Portability of Your Personal Data

GotCred users are able to access most of their Personal Data held by GotCred on the Site, and if you have any queries or complaints, we encourage you to contact our Privacy Officer.

Alternatively, you may make a formal request to access your Personal Data held by GotCred. In order to do so, please send an email to [email protected] from the email address associated with your account and paste the following sentence in your email: “I am requesting to access my personal data.” GotCred will provide your Personal Data to you in a portable format to allow it to be transmitted to third parties. If you have interacted with GotCred using more than one email address, please send details of the additional email addresses so that we may provide this personal data as well.

10.5 The Right to Delete Your Personal Data

GotCred users can edit and update most of their Personal Data held by GotCred on the Site, and if you have any queries or complaints, we encourage you to contact us here. Alternatively, you may make a formal request to delete your Personal Data held by GotCred.

In order to do so, please email to [email protected] from the email address associated with your account and paste the following sentence in your email: “I am requesting to delete my personal data.” Once your request has been confirmed, GotCred will initiate the necessary steps to execute this exercise, including the deletion of your GotCred account. If you have interacted with GotCred using more than one email address, please send details of the additional email addresses so that we may delete this personal data as well.

PLEASE NOTE: by requesting the deletion of your Personal Data, you will no longer be able to create an account with GotCred using the same email address. If you simply wish to close your account, please click the “close my account” button in your account page. Additionally, if you use “GotCred Apply” for an application or take any other action on the Site using the same email address associated with your deletion request, you may not receive certain communications associated with those actions from GotCred or other GotCred users.

10.6 Some Limitations

Such rights of rectification, objection, restriction, access, portability and deletion are subject to certain limitations, as provided for by applicable laws. Individual requests will be completed within the time allotted by relevant regulations, which starts to run from the point of GotCred confirming your request. Where permitted, please note there may be a charge for subsequent requests from the same individual, which will be determined by GotCred and only imposed to the extent permitted by applicable law.

11.  Personal Data from Individuals in the EEA and Switzerland

11.1 Privacy Shield Principles and Framework

GotCred has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity, and Purpose Limitation, Access, Recourse, Enforcement and Liability. If there is any conflict between the provisions in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

11.2 Principle of Onward Transfer

In the context of an onward transfer of data to a third party, a Privacy Shield organization has responsibility for the processing of Personal Data it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. GotCred shall remain liable under the Principles if its agent processes such Personal Data in a manner inconsistent with the Principles, unless GotCred proves that it is not responsible for the event giving rise to the damage.

11.3 GDPR Protections

GotCred transfers made according to the Privacy Shield Framework are performed based on agreements that also incorporate the protections and requirements provided for under Chapter V (and Article 28, where appropriate) of the GDPR. This incorporates EU data protection requirements to ensure adequate protection of such personal data transfers.

11.4 Independent Dispute Resolution for Individuals in the EU and Switzerland

In compliance with the US-EU (applicable in all EEA countries) and Swiss-US Privacy Shield Principles, GotCred commits to resolve complaints about your privacy and our collection or use of your Personal Data.

Individuals in the EEA or Switzerland with inquiries or complaints regarding this Privacy Policy should first contact GotCred at: ‘GotCred Privacy Program at Unit 5, 62 Ord street, West Perth WA, Australia 6010’ or by emailing [email protected].

12.  General Inquiries and Complaints

12.1 Contacting GotCred

You may contact GotCred via post to Unit 5, 62 Ord street, West Perth WA, Australia 6010 or you may contact us via our Site contact form. If you would like to contact GotCred’s Data Protection Officer, please send an email to [email protected]

12.2 Complaints

If you believe your data protection rights have been infringed by GotCred, you have the right to complain to the appropriate data protection supervisory authority in your jurisdiction.

In you are in Australia, you may refer the matter to the Office of the Australian Information Commissioner:

Office of the Australian Information Commissioner

Complaints must be made in writing.

Phone: 1300 363 992

Mail: Office of the Australian Information Commissioner

GPO Box 5218

Sydney NSW 2001

Website: www.oaic.gov.au

If you are in the EEA or Switzerland and have a complaint with respect to transfers and processing performed in accordance with EU-US (applicable in all EEA countries) and Swiss-US Privacy Shield Principles then you may avail of independent dispute resolution, as detailed in section 12 of this Privacy Policy.