Great people don’t stand out on paper.

Effective from: 15.05.2020

1. DEFINITIONS

1.1 VideoCV – VideoCV OÜ (registry code 14098592, registered office Pärnu mnt 142a, 11317 Tallinn, Republic of Estonia).

1.2 Database – the VideoCV database located on the website https://videocv.io that contains job offers, job-seeking notices and other data related to employment.

1.3 User – a natural person who has approved VideoCV Terms and Conditions for Applicant and uses the Services as a job seeker.

1.4 User Data – any and all data relating to the User entered in the Database, including those entered in the registration form, the data entered in the Database CV form, video and other data related to the User. User Data constitutes personal data in the meaning of the Personal Data Protection Act and Regulation 2016/679 of the European Parliament and of the Council (GDPR).

1.5 Terms and Conditions or Conditions – VideoCV terms and conditions for Applicants for using the VideoCV Database, available here.

1.6 Data Recipient – a legal or natural person who uses the Database for seeking and selecting employees, including for themselves or their clients, or for other services offered to employers by VideoCV via the Portal and to whom VideoCV communicates or makes accessible the User Data.

1.7 Parties – VideoCV and the User.

1.8 Employer – Employers who have organized competitions through VideoVC Portal with whom the User is granted the opportunity to share his/her CV and video.

1.8 Services – all VideoCV services aimed at jobseekers as described on the Website https://videocv.io.

1.9 Portal – the environment created for providing services related to mediation of employees and employers administered by VideoCV at the address https://videocv.io.

2. INTRODUCTION

2.1 The EU General Data Protection Regulation (GDPR) aims at protecting individuals from violations of their personal privacy in connection with the processing of their personal data. VideoCV is committed to protect the privacy of Users when processing your personal data and values the importance of the right to information regarding processing of personal data.

2.2 The purpose of this Privacy Policy is to provide information on how VideoCV processes personal data about the Users in connection with the use of our Services and Portal s a data controller. If you have any questions about how your personal data is processed by VideoCV or if you wish to exercise your data subject rights, please contact us.

3. WHY WE PROCESS PERSONAL DATA AND WHAT PERSONAL DATA DO WE PROCESS?

3.1 When you have opted to use our Portal and Services, we need to process your personal data to enable the Services.

3.2 We process personal data that is submitted to us directly by the User in the course of using our Services and the personal data generated by VideoCV or our service providers in the course of provision of the Services.

3.3 Personal data we process about you in the course of using our Portal and Services may include following data about the User:

3.3.1 general personal information: first name; last name;

3.3.2 contact details: address, phone number, email address that the User discloses;

3.3.3 education data and career data: data about the education and the current career of the User that the User discloses, data disclosed by the User in his/her CV;

3.3.4 video data: data about the User that is disclosed by User by uploading a video to the Portal, which includes biometrical data about the User, for example face shape and facial expressions, emotions, voice, etc.

3.4 You can see all data that is collected about you by VideoCV by contacting VideoCV via contact details provided below.

3.5 WHAT IS THE LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA?

3.6 We process your personal data to provide Services to you under the Terms and Conditions. Legal basis for such data processing is GDPR Article 6-1-(b), i.e. processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

3.7 In certain specific situations we might also process your personal data where processing your personal data is necessary for the purpose of our legitimate interests pursued by us. Legal basis for such data processing is GDPR Article 6-1-(f). In such a case we shall ensure that processing is proportionate and that we have carried out legitimate interest impact assessment. For example, for the purpose of our legitimate interest we analyse how our Services and Portal are used by our clients so we can provide better service.

3.8 In certain specific situations we may also process your personal data based on your consent. Legal basis for such data processing is GDPR Article 6-1-(a). In those situations, we process your personal data on the terms as provided in the consent that you have granted to us.

3.9 Additionally, we might process your personal data when processing is necessary for compliance with a legal obligation to which we are subject, for example for accounting purposes under applicable accounting legislation. Legal basis for such data processing is GDPR Article 6-1-(c).

4. WHEN DO WE SHARE YOUR PERSONAL DATA?

4.1 To the extent this is necessary for the provision of our Services, we may share your personal data with certain third parties.

4.2 By way of using our Portal and Services, the User is granted the opportunity to share his/her CV and video. Therefore, by way of using our Portal and Services we share your personal data (including your CV and video) with the Employers, by making your video and CV available to the Employers via Portal. The User can choose the specific Employers with whom the User wants his/her data to be shared.

4.3 We may also share your personal data with third party suppliers providing services to us, e.g. IT suppliers or other service providers. At the moment of adopting this Privacy Policy, we use the following service providers:

4.3.1 Amazon Web Services, Inc. for data storage and data centre service (Amazon Web Services, Inc., mailing address Amazon Web Services, Inc., 410 Terry Avenue North, Seattle, WA 98109-5210, ATTN: AWS Legal). Privacy terms for Amazon Web Services are available here: https://aws.amazon.com/privacy. As Amazon Web Services, Inc is the company operating in the United States, your personal data may be processed in the United States. Amazon Web Services, Inc complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework (collectively, “Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, Switzerland, and the United Kingdom to the United States in reliance on Privacy Shield. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.

4.3.2 Mongo DB (MongoDB Inc., postal address: 1633 Broadway, 38th Floor New York, NY 10019; email address: privacy@mongodb.com) for data storage. As Mongo DB is the company operating in the United States, your personal data may be processed in the United States. MongoDB complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework (collectively, “Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, Switzerland, and the United Kingdom to the United States in reliance on Privacy Shield. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.

4.3.3 Ziggeo, Inc. for video hosting (mailing address privacy@ziggeo.com). Privacy terms for Ziggeo are available at https://ziggeo.com/privacy . As Ziggeo, Inc. is the company operating in the United States, your personal data may be processed in the United States. Ziggeo, Inc. complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework (collectively, “Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, Switzerland, and the United Kingdom to the United States in reliance on Privacy Shield. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov .

4.3.4 Google Analytics by Google, LLC., to for data analytics to acquire knowledge on how our Portal is used. By using Google Analytics, Google, LLC might collect info from our users such as the age, gender, number of visits, visited pages, some demographic information and alike, even possibly including pages that you came from and are going to. We use the data we receive from this tool to help us analyse the traffic on our pages, for marketing and remarketing purposes, for advertising and for general improvements of our website. Google Analytics records the data together with the IP that you are using at that time. As a default setting of browsers, and other software and hardware usually found in use, personal data such as emails or names would not be available to Google Analytics. More specific information on how Google collects your details on our website is available at: https://policies.google.com/technologies/partner-sites . As Google, LLC is the company operating in the United States, your personal data may be processed in the United States. Google, LLC complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework (collectively, “Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, Switzerland, and the United Kingdom to the United States in reliance on Privacy Shield. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.

4.3.5 Facebook Pixel by Facebook, Inc., to measure, optimise and build audiences for your advertising campaigns. Privacy terms for Facebook, Inc., are available at https://www.facebook.com/privacy/explanation . As Facebook, Inc is the company operating in the United States, your personal data may be processed in the United States. Facebook, Inc complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework (collectively, “Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, Switzerland, and the United Kingdom to the United States in reliance on Privacy Shield. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

4.4 We may also share your personal data with third parties if you have granted consent for sharing. In such cases, we share your personal data as provided by the consent by you.

4.5 Please note that when we are transferring your personal data to third countries, we will ensure that the transfer is subject to appropriate safeguards under GDPR and that your rights are protected.

5. HOW LONG IS YOUR PERSONAL DATA RETAINED?

5.1 VideoCV does not retain personal data longer than it is necessary for the purposes of processing personal data or pursuant to applicable law.

5.2 VideoCV retains your personal data as long as it is necessary for the provision of the Services. As a general rule, personal data collected by VideoCV and job advertisement (your VideoCV) will be deleted by VideoCV 1 year after posting by you. Your post and all personal data therein will be deleted, unless we have a legal basis for retaining your personal data for longer time period. Legal basis for retaining your data for 1 year is VideoCV legitimate interest under GDPR Article 6-1-(f) to protect our rights in the light of potential legal disputes during the limitation period under law.

5.3 Pursuant to the Accounting Act, we retain accounting documents for 7 years.

5.4 If you wish to obtain more specific information about how long is personal data about you retained by VideoCV, please contact us.

6. HOW DO WE PROTECT YOUR PERSONAL DATA?

6.1 To protect your personal data from unauthorized access, unlawful processing or disclosure, accidental loss, modification or destruction, we use appropriate technical and organisational measures that comply with applicable laws. These measures include but are not limited to the implementation of appropriate computer security systems, protection of paper and electronic format files by technical and logical means, controlling and limiting access to documents and buildings.

7. COOKIES

7.1 Our Portal uses cookies. This section incorporates our cookie policy (the Cookie Policy) that applies when you use the Portal.

7.2 Cookies are small data files stored on your hard drive by a website. Cookies help us monitor and improve the functionality and usage of our Portal and your experience on Portal. We can use cookies to see which areas and features are popular and to count visits to our Platform to recognise you as a returning visitor and to tailor your experience of the Portal according to your preferences. We may also use cookies for targeting or advertising purposes.

7.3 We use following type of cookies on our Portal: 7.3.1 Strictly necessary cookies, that are essential in order to enable you to move around and navigate on Portal and use the features of Portal. 7.3.2 Functional cookies, that record information about choices you have made and allow to tailor Portal. Functionality cookies remember choices you make such as language preference, country location, or other online settings and provide personalized or enhanced features that you select, so that next time you visit you won’t have to enter all this information again. 7.3.3 Statistics cookies, that record information about the way our Portal is used, to acquire knowledge on how often our Portal is visited, where on our Portal our visitors spend the most time, how often they interact with a page or part of a page, this allows us to make the structure, navigation, and content of our Portal as user-friendly as possible.

7.4 The specific cookies that we use in the Portal are the following:

Name	Purpose	Retention period
_ga	Registers a unique ID that is used to generate statistical data on how the visitor uses the website	2 years
_gat	Used by Google Analytics to throttle request rate	1 day
_gid	Registers a unique ID that is used to generate statistical data on how the visitor uses the web site	1 day
_fbp	Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers	90 days
_fbc	Used by Facebook when a visitor arrives to the website from an Ad and the destination URL includes the click identifier “fbclid”	90 days
cc	Set to track if a visitor has consented to personally identifiable tracking or not.	1 year

7.5 You can delete or block cookies on Portal through your browser settings at any time. However, some cookies might be necessary for the functionality of Portal. Therefore, you understand that when blocking or deleting the cookies some features of Portal might not function correctly.

7.6 For more general information about cookies including the difference between session and persistent cookies please see www.allaboutcookies.org.

7.7 We also use of widgets for social media which allows users access content on different social media platforms (among others: Facebook, Instagram, YouTube, LinkedIn). To better understand how and what information is collected via social media and what cookies are used by such third party, please see the current privacy policy for each of the social platforms respectively.

7.8 In case you have any question concerning Cookie Policy, you may contact us via contact details provided below.

8. YOUR RIGHTS

8.1 VideoCV is dedicated ensuring that all data subject rights arising under applicable law are always guaranteed to you. In particular, any User who is data subject has: 8.1.1 the right to access the personal data that VideoCV processes about him/her; 8.1.2 the right to request that VideoCV rectifies any inaccurate personal data about you; 8.1.3 the right to request VideoCV to erases your personal data and/or restricts of processing of your personal data if we do not have valid legal basis for processing; 8.1.4 the right to receive your processed personal data in a structured, commonly used and machine-readable format and have the right to transmit your personal data to another controller; 8.1.5 the right to object to the processing of your personal data.

8.2 If you believe that your rights have been infringed, you may contact and lodge a complaint to the supervisory authority applicable for your jurisdiction (Data Protection Inspectorate in Estonia address Tatari 39, Tallinn 10134, , info@aki.ee or other competent authority in your jurisdiction).

9. GOVERNING LAW AND JURISDICTION

9.1 This Privacy Policy shall be governed by the laws of the Republic of Estonia. Any disputes arising from these Privacy Policy shall be settled in the Harju County Court in the Republic of Estonia, unless you have a right to turn to the court of your residence pursuant to statutory law.

10. CONTACTS

10.1 If you have any questions about this Privacy Policy or Cookie Policy or if you have any concerns about how we use your personal or if you want to exercise your rights as described above, you may contact us via e-mail or in writing using the following contact information:

VideoCV OÜ

Address Pärnu mnt 142a, 11317 Tallinn, Republic of Estonia

Phone: (+372) 518 1394

E-mail: info@videocv.io