- Stipulate your rights and responsibilities forthcoming out of working with Josie;
- Explain exactly what we do with your data and how we use it to help you with advice, recommendations, or suggestions that you give permission to or request from us;
- Make sure that you understand what data we collect with your permission, and what we do - and not do - with it;
- Determine accountability for protecting your rights and your privacy under this policy;
All the information we collect is related to providing the JOSIE services and its features. In these terms and conditions, any reference to JOSIE shall mean any applicable company or site directly owned or co-owned by JOSIE (www.talentdatalabs.com).
We do not knowingly collect or solicit personal information from anyone under the age of 16. If you are under 16, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us personal information, please contact us at [email protected].
Broadly speaking, there are three categories of information we collect: 1) information that we must have in order for you to use our platforms; 2) information that we can use to provide analytics, assessments, additional features and improved experiences, if you choose to share that information with us; and 3) publicly available information from which we directly make inferences.
The first category includes:
- Registration Information, including name, birth date (age), email, address, and other information that you provide when you sign up for our services;
- Your location, we help you find events, institutions, jobs, trainings, and other geographically specific happenings based on where you are or want to be.
- Technical and sensor information necessary to operate the JOSIE platform. This includes the type of browser and device you use, data from the touchscreen, and information from your device’s gyroscope and accelerator sensors. This enables you to control the JOSIE platform and allows us to do simple things like scale the platform to your device, rotate videos, and recommend tasks based on whether you’re sitting still or are on the road.
We will never gather or use your personal data without first getting your explicit permission. The gathering of personal data enables us to help you create a profile for you and you alone. We will not share any of your personal data with any third party unless you have given us explicit permission to do so.
The second category includes information that enables us to offer you additional features and advice. Amongst other applications, this data enables us to give you advice on courses of action to achieve your goals in life. While using our platform you will be able to choose exactly which data you wish to commit and therefore which features you wish to enable. Given your explicit permission, we may share some of this data with any of our Users, Partners or Clients to enable them to offer you relevant opportunities that fit into your preferences. Here are some examples:
- Non-sensitive demographic data: such as age group, nationality, language, and city of residence.
- Professional profile related data related to your career and personal development over time:
- Professional background, companies you have worked for, roles you have had.
- Educational background, schools you went to, courses you followed, grades.
- Data related to the preferences you may have for your future career or education but also for your social environment and general wishes.
- Any form or survey information gathered through our research or platform:
- Work attitudes, cultural profile, working behavior, work style preferences, matching preferences, your interests.
- Companies you are interested in, schools you are interested in, skills you want to learn.
- Personality and other standardized testing data such as g-factor.
- Your photos: we will only access images that you specifically choose, and we will never scan or import your photo library or camera roll. This allows you to choose individual pictures to change your profile picture. You can stop sharing photos and revoke access at any time.
- Your contacts: we will never scan or import your contacts unless you ask us to. If you choose to do so, we will only use your contact information to help you find or nominate friends or contacts who use Josie.
The final category includes any non-copyrighted information, not hosted or facilitated by JOSIE or any of its websites, that is made accessible, retrievable. or publicly available online by the Data Subject. According to article 9 paragraph 2 of the General Data Protection Regulation (EU 2016/697) this data falls under the responsibility of the Data Subject and, as long as this data remains public or publically available, no direct rights, privileges, or liabilities can be inferred from any data stored or derived from this category.
We will be clear with you about how and when we might share information. In some contexts, we will share certain information. For example, like most services, if you sign up for JOSIE through a third party like Linkedin, Gmail, or Facebook, we share some information with them and they share some information with us in order to enable your account. And we also share de-identified (anonymous) information with our Human Resources Industry partners to help them understand how the company they run is performing, with research partners who help us with knowledge creation efforts, and with advertisers that allow us to offer a free service. There also may be times when you want us to share information. For example, when you want to nominate or invite a friend, you might want some data to be visible to your friends… and you might not. Similarly, you can ask us to share information (like your email address) with employers or job search sites, or other partners who may want to directly send you opportunities, news or promotional offers, but you can also revoke that permission at any time.
DATA PROTECTION OFFICER
Vasagatan 28, 111 20 Stockholm, Sweden
Email: [email protected]
Tel. +46 704 328 077
Given further permission, your data will be used to match you with different events, opportunities, partners, and users. In accordance with Article 13 and 15 of the General Data Protection Regulation (EU 2016/697) you retain the right to choose which data you will use for these operations.
We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:
- Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services)
- Social media services (if you interact with them through your use of the Services)
- Third-party business partners who you access through the Services (e.g. third party applications)
- Other parties authorized by you
We also share information with third parties when you have given us consent to do so (as indicated at the point such information is collected).
We also share Personal Data when we believe it is necessary to:
- Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
- Protect us, our business or our users, for example, to enforce our Terms of Service, prevent spam or other unwanted communications and investigate or protect against fraud
- Maintain the security of our products and services
If we choose to buy or sell assets, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that are transferred or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets. You acknowledge that such transfers may occur and that any acquirer of us or our assets may continue to use your Personal Information exclusively as set forth in this policy.
We retain Personal Data about you for as long as you have an open account with us and for three years after you close your account. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterward, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally. However, user signup data (your name, your email address, and the fact that you were a JOSIE user) may be retained in third-party analytics services beyond closure of your account, unless you request that your data be deleted.
Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device which may include “cookie” information. “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people.
We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity. For example, JOSIE is continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction or alteration. Some of the safeguards we use to protect Personal Data are firewalls, data encryption, and information access controls. For additional information and requests, please contact: [email protected]
You have, according to article 13 and article 15 of the General Data Protection Regulation (EU 2016/697), certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email [email protected]. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
- Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by accessing your account settings.
- Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by accessing your account settings.
- Erasure: You can request that we erase some or all of your Personal Data from our systems.
- Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
- Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
- Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes.
- Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
- Right to File Complaint: You have the right to lodge a complaint about CA’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.
The Services are hosted and operated in the Singapore and Europe (“E.U.”) through JOSIE and its service providers, and if you do not reside in the E.U., laws in the E.U. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to JOSIE in Singapore or Europe and will be hosted on Singaporean or European servers, and you authorize JOSIE to transfer, store and process your information to and in Singapore or Europe., and possibly other countries. You hereby consent to the transfer of your data to Singapore or Europe pursuant to the GDPR.
JOSIE is committed to the General Data Protection Principles (“Principles”) of (1) notice, (2) consent, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access and (7) recourse, enforcement and liability with respect to all Personal Data. The Principles require that we remain potentially liable if any third party processing Personal Data on our behalf fails to comply with these Principles (except to the extent we are not responsible for the event giving rise to any alleged damage). Josie’s compliance with the GDPR is subject to the investigatory and enforcement powers of the European Commission.
CHANGES TO THE POLICY