Privacy Policy
Last updated January 21, 2021
Summary of MyJoAlly’s Privacy Policy
- Introduction
We created this summary of MyJobAlly’s Full Privacy Policy to help guide you through it and keep you informed about how we handle your information.
Our Privacy Policy details how we collect, use and disclose the Personal and Non-Personal Data we collect from and about you when you access or use our online and/or mobile websites, applications, services, and software (collectively, our “Sites”).
MyJobAlly’s core mission is to help people get jobs and help Employers find great candidates. Since each of our affiliates shares that core mission.
- Who is responsible for your information?
The MyJobAlly is responsible for your information.
- What information do we collect about you?
Across the Sites we collect information:
- you choose to provide to us through our Sites e.g. contact details, resume details, location data;
- through your activity on our Sites e.g. information from your device and actions taken on the Sites, searches you run or jobs you click on;
- when you apply to jobs, use screener or assessment questions or automated phone screening, or log in from third party sites; and
- where you use chargeable services or are an Employer providing necessary Employer information, e.g., for verification purposes.
Full details of the types of Personal Data we collect from you and details of the legal basis for such collection are detailed in section 2 of our full Privacy Policy.
- Why do we collect this information?
We collect and use your information in order to help Job Seekers find jobs, to help Employers find candidates, and to provide and improve our services to you. To summarize, we use your Personal Data, where applicable, to:
- create your account and send you job alerts or other promotional materials;
- give you relevant search results and job recommendations;
- facilitate communication as part of the job search, application and interview process;
- make your resume available to third-parties, depending on your privacy settings (e.g. private or public resume);
- match Job Seekers with Employer Job Listings;
- prevent fraud, spam and other potentially fraudulent or illegal activities;
- facilitate payment, in connection with chargeable services;
- carry out automated processing in order to provide many of our services;
- enhance and optimize our services and security for Job Seekers and Employers by data sharing with our affiliates;
- improve our services, maintain product quality and protect users; and
- aggregate and share with third parties content posted on MyJobAlly intended to be publicly available.
Full details of the purposes for which we use your Personal Data are set out in sections 4, 5 and 9 of our Full Privacy Policy.
- Who is this information shared with?
Your information is shared with:
- MyJobAlly affiliates;
- Employers and Job Seekers (e.g., if a Job Seeker decide to apply for a job);
- third-party service providers who help us with our operations, e.g. for data storage or fraud detection.
Please see sections 4, 8, 9 and 11 of our full Privacy Policy for more details.
- How long do we store your information?
MyJobAlly stores your Personal Data until it is no longer necessary to provide our services, or until you ask us to delete your Personal Data. We may also be required to retain certain information in order to comply with local laws. If you wish to delete your Personal Data, you should submit a delete request. Please see section 2 of our Full Privacy Policy for further information on how long we store your data.
- What are your rights with respect to your Personal Data?
MyJobAlly takes your privacy very seriously. We provide GDPR-type rights to all our users globally. This includes the rights to access your Personal Data; delete your Personal Data; get your Personal Data in a portable format; and the rights to restrict or object to certain processing of your Personal Data. Where our use of your Personal Data is based on your consent, you also have the right to withdraw that consent. Please see section 10 of our full Privacy Policy for further information in respect of your rights and how they can be exercised.
You also have the right to complain to your local data protection supervisory authority about MyJobAlly’s use of your data as detailed in section 12 of our full Privacy Policy.
- Contacting us
You may contact MyJobAlly, via email at “info @ myjobally.com” (remove spaces when sending email) or via phone on 0803 567 7044.
To contact our Data Protection Officer please email “privacy-dept @ myjobally.com” (remove spaces when sending email).
MyJobAlly’s Full Privacy Policy
- Introduction
MyJobAlly values the trust our users and customers place in us when they give us access to their Personal Data. The 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 MyJobAlly when you access or use MyJobAlly’s or the other Sites’ online and/or mobile services, mobile applications and websites, and software provided by MyJobAlly while using these services or websites. Our core mission is to help people get jobs, and help Employers find great candidates.
1.1 The MyJobAlly Entities Responsible for Your Information
This section determines which MyJobAlly entity acts as the controller of your Personal Data.
For the purposes of this Privacy Policy, “MyJobAlly”, “we” or “us” means MyJobAlly.
MyJobAlly is the controller of all Personal Data processed pursuant to this Privacy Policy, unless otherwise provided for in a separate agreement.
Please also note that the contracting entity indicated in our terms of service may differ from the data controller indicated in this Privacy Policy.
1.2 Some Important Definitions
Personal data (“Personal Data”) refers to any information that relates to an identified or identifiable individual, and non-personal data (“Non-Personal Data”) refers to any information that does not identify you as a specific individual. Please note that at all times MyJobAlly 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.
The Sites are made available for use only by individuals searching for employment openings, or services or information related to their personal employment or job search (“Job Seekers”). Where applicable, the Sites may also be made available to individuals and/or organizations seeking information related to hiring or human resources or seeking to make available information regarding employment openings (“Job Listings” or “Job Ads”), on their behalf or other’s behalf, including but not limited to agencies purchasing for multiple parties (“Employers”).
1.3 The Scope of MyJobAlly’s Privacy Policy
This Privacy Policy covers only data that we collect through the Sites, and not any other data collection or processing, including, without limitation, any third-party operators of web pages to which the Sites link, 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 Sites, including special purpose web pages or mobile applications, including invitations for you to submit ideas to improve the Sites. MyJobAlly may amend this Privacy Policy at any time.
If you applied to a Job Listing, please consult the Job Listing for additional information applicable to you. Current and former MyJobAlly employees should contact their human resources coordinators for applicable policies.
1.4 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 Sites or providing information to us following such changes, you will have accepted the amended Privacy Policy. If MyJobAlly is going to use Personal Data collected through the Sites in a manner materially different from that stated at the time of collection, then MyJobAlly will notify users via email and/or by posting a notice on the applicable Sites for 30 days prior to such use or by other means as required by law.
- Information Collected
You provide different types of information in order for MyJobAlly to provide our Sites’ services, products and features to you.
2.1 Information You Provide to MyJobAlly
– From Your Account
We collect data from you when you create an account, request information, subscribe for a service, participate in a survey, post a rating or review, post a question or answer, post a resume, complete an MyJobAlly Assessment, upload content or otherwise actively send us data on our Sites. 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, professional certification or license numbers, messages you send to users, and any other data included in a submitted profile or resume, including but not limited to application materials and answers to screener questions submitted to MyJobAlly or to Employers through MyJobAlly and answers you give to any questionnaires sent to you. All of this information may be associated with your MyJobAlly profile.
You may provide your specific location data when you provide it yourself on the MyJobAlly Apps (as defined in the MyJobAlly Terms of Service Introduction) to help you find more relevant Job Listings. MyJobAlly seeks your consent at the time of such provision, and such processing will only be performed where consent is secured.
If you create an MyJobAlly account, MyJobAlly 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 user name, email address, or zip code. For example, while using a mobile device to access MyJobAlly, MyJobAlly may provide a Job Seeker with relevant Job Listings that are located within the same zip code as where this activity is taking place.
– Through Your Activity on the Sites
In addition, as part of the standard operation of the Sites, MyJobAlly may collect and analyze information from your computer or mobile device and actions taken on the Sites, including, but not limited to, your resume, your searches, the titles of jobs you search, click on or apply to, where those jobs are located, your salary interest or experience, the general salary range or experience level of the jobs you view (where indicated), the Job Listings you apply to, the date, time and type of your activity on the Sites such as how often you update your resume or look for jobs, session activity, browser type, operating system, type of device, mobile device advertising identifier, MAC address, IP address, and any of your other behavior on the Sites.
For Employers, this may also include actions taken with regard to a Job Listing or to Job Seeker’s resume or application, such as pausing or closing a Job Listing, opening, viewing or responding to a resume or application, or making a decision with regard to a resume, application or Job Listing.
– Through Your Activity on MyJobAlly Hire
Employers may be contacted to take advantage of our MyJobAlly Hire service, in which case you may provide MyJobAlly with additional information about hiring needs. This allows MyJobAlly to determine whether or not our Hire product is suitable for an Employer’s needs. When Job Seekers apply for a job recommended to them by MyJobAlly Hire, MyJobAlly facilitates certain aspects of the recruitment process including, for example, negotiations between the Job Seeker and the Employer, as applicable. As such, we collect and process any information submitted to MyJobAlly through this process, including but not limited to any queries a Job Seeker may have about the job or interview, information about progression through the recruitment process and information relating to salary.
– When Using Automated Phone Screening
If you use any automated phone screening product, MyJobAlly will record and store your answers to an Employer’s screening questions and will forward your answers to the Employer. Where you wish to use such a product, you will agree in advance to MyJobAlly listening to and analyzing the recording in accordance with this Privacy Policy.
– When Providing Employer Information
If you are an Employer, we may request that you provide certain information in order to verify your account. This information may include, but may not be limited to, your Business Registration information, or a utility bill, 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.
– When Using Chargeable Services
In connection with chargeable services, we will also collect payment information (e.g., the last four digits of credit, debit, or other payment card numbers and related verification information). Please note that MyJobAlly only has access to the last four digits of credit, debit, or other payment card numbers, and does not store full card numbers or related card security codes.
2.2 Information Collected When You Apply for Jobs or Access MyJobAlly from Some Third-Party Websites
– When You Log In or Use MyJobAlly from Some Third-Party Sites
You may also create an account or log in to your MyJobAlly account using third-party websites including, but not limited to, LinkedIn, Facebook or Google. If you do not already have an MyJobAlly account but log in to MyJobAlly using your LinkedIn, Facebook or Google account, this creates an MyJobAlly account using the same email address used in your LinkedIn, Facebook or Google account. If you agree to provide this information to MyJobAlly, LinkedIn, Facebook or Google will authenticate you and redirect you to MyJobAlly. Please note, when you log in to MyJobAlly using your LinkedIn, Facebook or Google account, LinkedIn, Facebook or Google will cookie you in order to authenticate you as a LinkedIn, Facebook or Google user.
By accessing MyJobAlly through your LinkedIn, Facebook or Google account, you understand that LinkedIn, Facebook or Google will share certain data detailed in the above paragraph for the purposes of authentication to permit you to access MyJobAlly in a secure manner. You may stop this at any point from your LinkedIn, Facebook or Google account. This information will be considered MyJobAlly account information for purposes of your use of MyJobAlly.
You have the ability to disable the connection between your LinkedIn, Facebook or Google account and your MyJobAlly account at any time by accessing your privacy settings on your LinkedIn, Facebook or Google account. Facebook or Google may also ask for your permission to share certain other details with MyJobAlly, 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 MyJobAlly. This information will be used to provide services to you, including populating your MyJobAlly profile on MyJobAlly. The shared information will remain associated with your MyJobAlly profile until you modify or delete it.
PLEASE NOTE THAT YOUR RELATIONSHIP WITH LINKEDIN, FACEBOOK OR GOOGLE OR ANY OTHER THIRD-PARTY WEBSITE IS GOVERNED SOLELY BY YOUR AGREEMENT WITH SUCH THIRD-PARTY WEBSITE.
– MyJobAlly for Chrome and Our Mobile Software
MyJobAlly may also collect information about third-party websites you visit through our mobile software or while using MyJobAlly for Chrome. This could include information about Job Listings, notes or application statuses that you submit, save, or update, or data regarding how you engage with websites or other actions you take on such websites, including URLs of websites you visit. We may also suggest information from your MyJobAlly profile to include in applications you submit on third-party sites and see whether you make changes to these suggestions but not the changes themselves. We do this in order to allow a Job Seeker to keep a record of particular Job Listings of interest, to detect a job application on a third-party site to give a Job Seeker the option to auto-fill parts of the form using MyJobAlly Resume, or to confirm an application. MyJobAlly for Chrome also allows MyJobAlly to learn about what types of jobs and MyJobAlly 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 to Jobs on Some Third-Party Websites
When you apply for a job on certain third-party Websites, MyJobAlly may also receive information about the status of your job application and the decisions taken by the Employer such as whether the application reached the interview stage and whether a job offer was accepted or rejected. This information helps MyJobAlly further understand the effectiveness of our Sites and its features. MyJobAlly’s use of this information is detailed in section 4 of this Privacy Policy.
2.3 Any Other Personal Data MyJobAlly May Receive from Third Parties
Any Personal Data that MyJobAlly may obtain from other third-party sources, including data from sponsored advertisements that we have on third party sites, will be processed by MyJobAlly in accordance with this Privacy Policy and all applicable laws.
2.4 Storage of Your Information
MyJobAlly 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 job application in their candidate dashboard on MyJobAlly, MyJobAlly may delete information associated with that application. As another example, after an application has been delivered to an Employer, MyJobAlly may retain a copy of that application for a limited time and then delete the copy. We are also required to retain certain information in order to comply with local laws.
MyJobAlly may also store the information detailed in this section 2 of the Privacy Policy on its equipment or the equipment of third parties that MyJobAlly 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
It will be indicated to you at the point of provision as to whether or not particular Personal Data provided by you is required in order to provide particular MyJobAlly services or features to you. Where Personal Data that is required is not provided by you then the particular feature or service may not be available to you.
2.6 The Legal Basis on Which MyJobAlly Collects Your Personal Data
MyJobAlly 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.
– Performance of a Contract
Some of the Personal Data processed by MyJobAlly is performed 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 MyJobAlly sends a Job Seeker’s application to an Employer.
– Legitimate Interest
A second ground relied upon by MyJobAlly for other types of processing of your Personal Data is that it is necessary for the purposes of legitimate interests pursued by MyJobAlly or an Employer. Examples of such legitimate interests will include where MyJobAlly 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, where such processing is strictly necessary for fraud detection and prevention, or where we share your Personal Data with MyJobAlly affiliates as detailed in section 4.14 below. MyJobAlly 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
A third ground relied upon for certain types of processing is that it is necessary in order to allow MyJobAlly to comply with a legal obligation. An example of this would be where MyJobAlly is required to retain business records for fixed periods of time in order to comply with local legal requirements.
– Consent
Finally, in certain limited situations, MyJobAlly relies on your consent in order to process your Personal Data. Where MyJobAlly requires your consent, we seek it at the time of provision, and the processing will only be performed where consent is secured. For example, your consent will be sought in certain instances where you initiate a marketing message such as a Job Alert with MyJobAlly (detailed in section 4 of this Privacy Policy). You can withdraw your consent, as detailed in section 10 of this Privacy Policy where applicable, or by sending an email to “privacy-dept @ myjobally.com” (remove spaces when sending email).
- Limitations of Use
3.1 Where a Job Seeker Wants to Close a Job Seeker Account
When a Job Seeker closes an account, the Job Seeker will no longer have access to any of the data we make available under that account, including but not limited to, search history, job search preferences, saved jobs, jobs the Job Seeker has applied to, Job Alerts, resume, and any other data associated with the account. If the Job Seeker uses the same email address to set up a new account, this data from a previous account will not become available to the Job Seeker again. Please also note that closing your Job Seeker account may result in you losing access to some of our products and the ability to utilize the “log in with MyJobAlly” feature found on certain third party sites.
MyJobAlly 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 MyJobAlly systems, although it will not be readily available under the Job Seeker’s original account. When the Job Seeker presses the close account button on the dashboard, MyJobAlly will begin to process that instruction within 24 hours and will have completed the operation within 40 days.
If a Job Seeker wishes to access or delete their Personal Data held by MyJobAlly, they should follow the steps listed in section 10 of this Privacy Policy.
3.2 Where an Employer Wants to Disable an Employer Account
Employers may disable an account at any time by contacting MyJobAlly Customer Support. Please note that MyJobAlly 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 MyJobAlly, they should follow the steps listed in section 10 of this Privacy Policy.
3.3 Where a Job Seeker Wants to Delete a Job Application
If a Job Seeker wants to delete a job application performed on the Sites, they are advised to contact the prospective Employer directly to request deletion of their application or done it themselves if the option is available. For job applications which you, the Job Seeker submit through the Sites (including the use of an MyJobAlly Apply button) to an Employer, (with related materials submitted), please note: 1) that your applications and materials may be controlled by an Employer and 2) we may direct you to that Employer for Personal Data deletion requests where that Personal Data is held by that Employer.
3.4 Where the Employer Contact Details Provided to MyJobAlly Are Incorrect
MyJobAlly depends on the Employer or the Employer’s agent to provide MyJobAlly with the correct destination for all applications. In the event that the electronic destination provided to MyJobAlly is incorrect, your application materials will not be sent to the intended recipient of the application. MyJobAlly has no liability for such applications. If you do not wish to send your application materials in this manner, you should send them directly to the Employer.
3.5 @MyJobAlly Addresses
When communicating through MyJobAlly’s message relay system, you will see an email address with an @myjobally.com ending. You understand that you retain no ownership rights in these email addresses, which are specific to Employers’ Job Listings, but are owned by MyJobAlly. However, MyJobAlly’s relay system will show the name associated with your account or job application in the “To:” or “From:” field. In addition, the above shall apply to any email addresses added to a thread when communicating via MyJobAlly’s message relay system. Specifically, if you choose to add additional recipients to an ongoing email thread through MyJobAlly’s message relay system, the additional recipient(s) will also be assigned @ myjobally.com addresses as well. Please note that emails which include an email address ending in @MyJobAlly.com will be stored on our systems. You should not send a message to an email address ending in @ myjobally.com if you do not wish for this to happen.
Please also note that since these message proxy and relay services depend on the functionality of third-party providers, there may be technical delays on the part of those email service providers.
3.6 Minimum Age of our Users
The Sites are not for use by anyone under the age of 16. However if local laws provide for an alternative minimum age for the provision of the Sites’ services to you, then that shall apply as the applicable minimum age. In all jurisdictions, if you are under the age of 18 or the age you must use the Sites under the supervision of your parent, legal guardian or responsible adult.
We adopt 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 “privacy-dept @ myjobally.com” (remove spaces when sending email).
- 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. MyJobAlly associates Personal Data with your Job Seeker profile in order to perform the activities described in this Privacy Policy. MyJobAlly uses such information to help Job Seekers find jobs and to help Employers find candidates. In order to do this we use your Personal Data to:
- provide our services, products and features to you, to help Job Seekers find jobs and Employers find candidates;
- to measure and improve those services, products and features; and
- 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 Job Alerts and Other Promotional Materials
If and to the extent permitted by applicable law, MyJobAlly may use the information you provide to MyJobAlly, including your contact information, to (i) create an account; (ii) send you Job Alerts; (iii) send you Invitations to Apply for a job and (iv) send you information about the Sites, including by displaying our promotional materials to you on third-party sites. MyJobAlly may use third-party partners to perform these activities on MyJobAlly’s behalf.
A Job Alert is an email that you sign up for containing Job Listings in response to a search query you have run. A company alert is one type of Job Alert which contains Job Listings and other information you have requested regarding a company. Job Alerts may also include jobs that are recommended for you, MyJobAlly Targeted Ads, companies you may be interested in following, or other actions you may want to take on the Sites. The frequency of Job Alerts may be adjusted by MyJobAlly on the Sites.
An Invitation to Apply is an email sent to you inviting you to apply for a job through MyJobAlly, MyJobAlly’s optimized hiring and recruitment service. MyJobAlly may send you an Invitation to Apply based on your previous job search and application history on MyJobAlly, and any information, including Personal Data, you upload to the Site.
We may also use your information in order to show you targeted advertisements and other content that has been customized for you on third-party websites. Such advertisements will only relate to the Sites services, products, and features, all of which focus on helping Job Seekers find jobs and Employers find candidates. If you wish to opt out of receiving any marketing messages from the Sites, please see section 10.3 of this Privacy Policy.
4.2 Giving You Relevant Search Results and Recommended Jobs
In order to optimize our services, products and features for you, we may use your previous search and browsing history (e.g. the jobs you click on), or application materials and answers to screener questions, to identify you, determine relevant search results and reach out to you about jobs you may be interested in. We may also use profile data to tailor your experience on the Sites and to display content according to your preferences. We may return different results for the same search query and have full discretion with respect to the Job Listings we present in response to any particular search. In the event that you have applied to a job that is being serviced by MyJobAlly product, MyJobAlly may invite you to apply for additional roles.
4.3 Your Contact Information
When you give the Sites contact information (such as your name and email address) and other forms of Personal and Non-Personal Data, you agree that we may utilize this information for the purposes outlined in sections 4, 5 and 9, to the extent applicable. In particular, you agree that we may, as part of our services to you, communicate with you, or initiate communication with you on behalf of a third party, through your account or through other means such as email, telephone (including mobile phone), text message or postal mail. This includes communication through the use of contact information that you may provide to us or that we may otherwise obtain from third-party resources. Should you apply to a job that is supported by MyJobAlly product, a Hiring Specialist may use your contact information to conduct or coordinate interviews with you, and provide you with updates throughout the hiring process. We may also analyze our users’ contact information in the aggregate to better understand our users and improve our products and services.
4.4 Your Resume Information
Your information, including Personal Data, gets placed on the Sites when you upload or edit a resume, which becomes part of your Job Seeker profile. We reserve the right to charge third parties a fee for accessing your information, including Personal Data, as part of the Sites’ services. At your direction, we may also send your resume to third parties if you choose to apply for a Job Listing. We may also use information in your Job Seeker profile to offer suggestions to you when you apply for jobs on third party websites in our mobile software. The extent to which your information is made available to third parties depends on the privacy settings you choose, in accordance with this Privacy Policy. When a Job Seeker creates a profile on MyJobAlly, their resume is set to public by default, and the Job Seeker may change their resume privacy settings at any time. This is detailed below.
– Private Resumes
Private resumes are only made available to those to whom the Job Seeker has initiated an application or provided their resume. Where this occurs, you make your resume, your name and other Personal Data that you place on your resume available to third parties. Those third parties may be interested in you as an employee, and may forward your resume to other third parties.
– Public Resumes
Public resumes may be available to anyone accessing our Site. This includes users of MyJobAlly’s Resume Search product, Employers whose Company Page you may be following, and anyone with access to the URL associated with your public resume, such as search engines and other third parties that may crawl our Site. We offer you this visibility to help you find a job.
When you make your resume public (or upload a file as your resume and set it to public) on our Site, you authorize MyJobAlly to share the contents of your resume, including your name and any other Personal Data that you may include in it, publicly on the Site.
Our Resume Search product allows Employers to find great candidates by searching public resumes. By posting a public resume, you authorize MyJobAlly to make your entire public resume available to any user who searches for you on our Site, and to allow employers to see if you were recently active on the Sites, your readiness to work, and your available contact methods. If you upload a file as your resume and set it to public, you authorize MyJobAlly to extract the contents of this file and share them on our Site, including within our Resume Search product. We may remove your name and contact information from your public resume in certain instances, such as for users of our Job Packages product without a subscription. Employers who have subscribed to our Job Packages product will be able to see your name and any other contents of your public resume, except that we remove your contact information (such as your email and telephone number) until you express interest in an Employer. In either case, Employers may still contact you through our Site using our Relay Service. You also authorize MyJobAlly to share any file you upload as your resume and set to public on our Site with Employers where you express interest in them.
MyJobAlly expressly prohibits all scraping of its Site, although some third parties may use our Site in violation of these terms to obtain your public resume information.
MyJobAlly may also provide browser extensions and other tools to help Employers better interact with Job Seekers and their resume information, including tools that allow Employers to download your resume information and enhance and transfer it to third parties engaged to process information on their behalf, such as applicant tracking systems and other recruitment management tools. Employers are solely responsible for complying with all applicable laws that relate to their use of information obtained from MyJobAlly and other sources, including any obligations Employers may have to restrict how others interact with resume information downloaded from our Site.
4.5 Matching Job Seekers With Employers
You acknowledge that MyJobAlly may determine whether the words of your resume or any other individuals’ resume match the words of certain job descriptions, and vice versa, in order to improve the Sites or any of our other products or services (including by displaying or otherwise making available potentially relevant job descriptions and resumes to Job Seekers and Employers).
MyJobAlly may also provide information collected pursuant to this Privacy Policy, including Personal Data, to Employers that may be interested in contacting you. By applying to a job, answering screener questions, providing your contact information to show interest in a Job Listing, using MyJobAlly, or by replying to a message from an Employer, such as by expressing your interest in a particular Job Listing, you agree to the disclosure of your information to that Employer. MyJobAlly may also provide the results of any MyJobAlly Assessments you complete to Employers, where you agree to such provision at the time of taking such an assessment. MyJobAlly may also use information provided to MyJobAlly via your resume to pre-populate application information for you and for similar purposes.
If you have an account or a hosted resume, you agree that we may contact you or suggest you or your public resume to Employers that might be interested in a person who matches your activity on MyJobAlly.
4.6 Optimizing Job Campaigns
When Job Seekers click on a Job Listing or apply for a job powered by MyJobAlly on our Sites or on a third-party website, including an Employer’s website or a website operated by an Employer’s applicant tracking system, MyJobAlly may collect certain information through this feature about Job Seekers and any actions taken while on the Sites, as detailed in Section 2 of this Privacy Policy. MyJobAlly uses this information to help us understand the effectiveness of our Sites and to ensure that Job Listings are performing at the optimal level on our Sites and on other third-party websites.
4.7 Sending Messages on MyJobAlly
MyJobAlly provides two-way message proxy and relay services to the users of our MyJobAlly products (“Relay Service”), including, but not limited to: MyJobAlly Resume, MyJobAlly Apply, Post a Job, MyJobAlly Chat, WhatsApp, private calling, and other electronic communication services whether in the form of phone, text, video or audio. By utilizing any Relay Service, you acknowledge that you are asking MyJobAlly to send these messages on your behalf. This includes your resumes, cover letters, applications, messages, questionnaire answers, responses, offer letters and other materials. MyJobAlly may provide read receipts to the sender of a message through a Relay Service indicating that the recipient has viewed the message. MyJobAlly may also separately inform the sender and recipient of a message through a Relay Service whether the sender or recipient recently has been active on the Site.
We process, monitor, review, store and analyze such content, which may include Personal Data, including via automated means, for data analysis, quality control, enforcement of the Sites’ rules and other MyJobAlly policies, content moderation, and to improve the Sites or any other MyJobAlly product or service. Examples of such improvements would be improving the open rate of messages by optimizing their delivery, optimizing our search results, improving Job Listings, permitting applicants to manage their applications after transmitting them to MyJobAlly, ensuring you are provided with personally relevant product features and communications, and preventing fraud and spam. Some of this activity is performed on MyJobAlly’s behalf by service providers, as described in the section of this Privacy Policy titled ‘Transfers of Information to Service Providers’. 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. MyJobAlly 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 Sites and for providing the Relay Service.
4.8 Sending You Text Messages About Employer Appointments
MyJobAlly may offer you the opportunity to receive a text message from MyJobAlly when an Employer has scheduled an interview or event with you, when an Employer seeks to contact you based on your public resume, or has responded to your application via MyJobAlly’s email relay. In such an event you will enter your phone number on the MyJobAlly consent form. By entering your phone number you are representing and confirming it is your number and you have the right to accept text messages at the number. MyJobAlly will only send you a text message reminder for such interviews or messages through MyJobAlly’s email relay, and you agree to accept such text messages on your cell phone including messages sent by automated telephone dialing system. To unsubscribe at any time, reply to the text with STOP or contact MyJobAlly Customer Support. Replying STOP in response to an MyJobAlly SMS alert will unsubscribe you from all MyJobAlly SMS alerts except those related to Text2Apply and Hiring Events. In order to unsubscribe from those products, you must respond STOP within the specific text flows of those products.
4.9 Facilitating telephone relay system between Job Seekers and Employers
Where applicable, MyJobAlly may offer Job Seekers and Employers the option to use a telephone relay system to facilitate contact for the purpose of submitting applications, conducting job interviews or other communication related to a Job Listing. Such a system 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 MyJobAlly by third party service providers, such as Twilio.
4.10 Facilitating text messaging relay service between Job Seekers and Employers
MyJobAlly may offer Job Seekers and Employers the ability to utilize an autodialed text messaging relay service to facilitate contact for the purpose of submitting applications and for other communications related to Job Listings. To use this service, a Job Seeker must text an Employer’s preset keyword to a telephone number or short code that we make available on our Sites or in advertising materials (such as a sign or flyer at an Employer’s place of business). By texting the preset keyword to the telephone number or short code, you are consenting to receive text messages about the Employer’s Job Listings and as part of the application process, and acknowledge MyJobAlly may use your Personal Data to submit your application to the Employer and otherwise in accordance with this Privacy Policy. To unsubscribe at any time from such services, reply STOP by text message to the telephone number or short code provided or contact MyJobAlly Customer Support. DUE TO THE UNSTRUCTURED CONVERSATIONAL FORMAT OF THIS SERVICE, WE MAY NOT RECOGNIZE OTHER UNSUBSCRIBE ATTEMPTS.
4.11 Preventing Fraud and Spam
MyJobAlly may also use information collected pursuant to this Privacy Policy to help diagnose problems with the Sites and our products and services, to prevent potentially fraudulent or illegal activities, and to protect individuals from other activities that may be detrimental to you or others. MyJobAlly may investigate and disclose information from or about you or your use of MyJobAlly 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 Sites; or (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
MyJobAlly also reserves the right to drop messages from our relay system that we determine do not adhere to the Sites’ rules or any of the terms of our terms of service. MyJobAlly further reserves the right to conduct investigations to determine whether you are perpetrating a scam, spamming MyJobAlly or its users, or otherwise conducting fraudulent activity on the Sites by various means. MyJobAlly also reserves the right to turn over any information gathered via such investigations to the police or other third parties if we have a good faith belief that you are using the Sites in violation of this Privacy Policy or the applicable terms of service.
MyJobAlly 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 Job Listing.
4.12 Facilitating Payment
If you provide credit, debit or other payment card and related details to us in order to make a payment, we 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, debit, or other payment card and related billing and payment information that you provide to us may be shared by us with companies who work on our behalf, such as payment processors and/or credit agencies, solely for the purposes of checking credit, effecting payment and servicing your account.
4.13 Automated Processing of Your Personal Data
In order to optimize the performance of the Sites, we perform automated processing of Personal Data evaluating certain specific aspects relating to a user. In particular we use automated processing to analyze or predict a user’s personal preferences or interests. Where it occurs, such processing is carried out if it is necessary for the performance of our agreement with our users, to allow us to provide our services to Job Seekers and Employers, including analyzing applications 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 us to match Job Seekers with Employers effectively, to provide Job Seekers with Job Alerts, recommended jobs, and Invitations to Apply to jobs that the Job Seeker is likely to be more interested in, to send particular Job Seeker applications 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. You may contact “privacy-dept @ MyJobAlly.com” (remove spaces) to contest any decision generated by said automated processing.
4.14 Sharing your Information with Our Affiliates
Our core mission is to help Job Seekers find great jobs, and Employers find great candidates, which is a mission we share with each of our affiliates. In order to support that mission, we share certain information with our affiliates. Such information sharing is governed by this Privacy Policy.
Information shared by you with MyJobAlly may be shared with an affiliated entity to provide you with services, to improve the Sites and optimize functionality on the Sites, and other purposes as described in this Policy. In particular, such sharing strengthens our ability to help Job Seekers find jobs and Employers find great candidates. The services provided to you and the functionality of the Sites could not be provided without such transfers. If you do not wish your information to be transferred in this way you should not use the Sites.
– Improved Services
Data sharing with affiliates provides Job Seekers with more personalized and improved content, performance, features and services. For example, MyJobAlly and its affiliates use your previous search and browsing history (e.g. the jobs you click on), IP address, or your resume or profile information, to determine relevant search results, Job Alerts, display and moderate career insights, such as company reviews, Job Listing salary data, interview tips and more. Such sharing is also performed to facilitate improved data analysis, testing, research, and service improvement.
This sharing also allows Employers to have better insight into the performance of their Job Listings. For example, we may share data related to user clicks on their Job Listings which in turn allows Employers to understand the extent to which they are attracting candidates. By providing Employers with the information they need to better utilize our platform, they can provide stronger Job Listings.
– More Employers, More Job Listings and More Job Seekers
Such data sharing allows Job Seekers to access an even broader database of Job Listings and Employers, and for Employers to access more Job Seekers. For example, this allows MyJobAlly to recommend jobs or Employers on our Sites or on websites of our affiliates. It also facilitates applications and the display of Job Listings from the Sites to affiliates’ websites and vice versa.
For example, MyJobAlly and its affiliates recommend a Job Seeker to an Employer, and a Job Listing to a Job Seeker. This applies to Job Seekers, Employers and Job Listings on MyJobAlly and any of its affiliates. MyJobAlly and its affiliates 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 MyJobAlly and our affiliates to process your Personal Data for the purpose of improving user security and internal operations, troubleshooting, and detecting and preventing fraud and spam.
4.15 Transfers of Information to Employers
MyJobAlly sends Job Seeker Personal Data to Employers on the instruction of Job Seekers. Such transfers are performed in the course of the job search, application and interview process. 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.
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.
4.16 Transfers of Information to Job Seekers
MyJobAlly sends certain Employer-related information to Job Seekers. This includes publishing Job Ads, Company Pages, and salary information on the Sites and publishing Job Listings on third-party websites. MyJobAlly may also provide information to Job Seekers about an Employer’s activity and responsiveness on the Sites in order to help Job Seekers evaluate employment opportunities. This may include the Employer representative’s name, the Employer’s city/state location, whether the Employer has taken an action with regard to the Job Seeker’s resume or application such as opening, viewing, responding to or making a decision in regard to it, whether the Employer has engaged with other Job Seekers or viewed other Job Seekers’ resumes, and whether the Employer has taken an action in regard to a Job Listing such as pausing or closing it. As an Employer, when you use the Sites (for example by posting a Job Listing or contacting a Job Seeker through the MyJobAlly) you agree that MyJobAlly may provide this information to Job Seekers.
4.17 Transfers of Information to Service Providers
We may use third parties to perform services in connection with our operations, to improve the Sites 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 made for the purposes set forth in sections 4, 5 and 9 of this Privacy Policy.
– 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
MyJobAlly may transfer your Personal Data in limited situations to certain third-party vendors that assist MyJobAlly with protecting our users and maintaining the quality of our services, products and features provided to those users. An example would be vendors MyJobAlly uses for fraud detection purposes. Examples of those vendors include: SiftScience, Emailage, and PerimeterX. Another example would be vendors MyJobAlly uses to prevent accounts being created using account credentials that have been publicly disclosed. An example of such a vendor is: SpyCloud.
– Facilitating Payments
MyJobAlly may also share any credit, debit, or other payment card and related billing and payment information that you provide to MyJobAlly with companies who work on MyJobAlly’s behalf, such as payment processors and/or credit agencies, solely for the purposes of checking credit, effecting payment to MyJobAlly and servicing your account.
– Installing or Using an MyJobAlly 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 an MyJobAlly App. This may include your IP address or other unique identifier, and event data related to the installation of the MyJobAlly App.
This may be done for a variety of purposes, including facilitating user log-in through third party accounts. It may also assist us to understand and optimize our users’ complete customer journey by helping us: (i) understand how users arrive to the Sites; (ii) better measure the performance of our ads; and (iii) understand where a user has accessed the Sites through different devices.
When you download or install an MyJobAlly App, you acknowledge and accept that your Personal Data may be transferred to these service providers. You also agree to MyJobAlly’s Cookie Policy, Privacy Policy and the applicable 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.
Examples of the types of technologies that may support this behavior include pixels, javascript snippets, or cookies.
– 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 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.
– Verifying Professional Certifications and Licenses
We may also share certain professional certification or license numbers that you provide to MyJobAlly with the issuing entity or organization in order to verify the certification or license is valid. We only perform this verification at your request when, for example, you add certain certifications or licenses to your MyJobAlly profile.
4.18 Transfers of Publicly Available Information
When users post content on the Sites in a manner that is intended to make that content publicly available and searchable by individuals, MyJobAlly reserves the right to aggregate and share that information with third parties. For example, if an Employer posts a job on the Sites, MyJobAlly may share that Job Listing or information contained within that Job Listing with third parties, at MyJobAlly’s discretion and subject to agreement with such third parties. MyJobAlly also reserves the right to share information aggregated from public sources in this capacity.
4.19 Third-Party Sites You Link to from MyJobAlly
You may also use certain third-party websites or services that you link to from the Sites. In such cases, all information you provide to a third party is provided to that third party and not to MyJobAlly, 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 Websites for more information.
4.20 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.
- Additional Uses and Disclosures of Non-Personal Data
This policy also applies to our use of Non-Personal Data. We may use and disclose Non-Personal Data for any purpose, 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.
- Security
MyJobAlly seeks to use reasonable security measures to help protect against the loss, misuse and alteration of the Personal Data under MyJobAlly’s control. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. 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 see the following page for more information.
Please also be aware that we may use third-party cloud service providers as detailed by Section 4.17 of this policy.
- 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 our use of Cookies.
- Links to Third-Party Sites
The Sites may make available links to other third-party websites. When you click on such links, you may leave our Sites. Your web browser may also disclose to the third-party website the URL of the Sites page you clicked from, and this URL may include search terms and filters you used on the Sites. The Sites 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 SITES IS AVAILABLE, AND ANY THIRD PARTY OPERATING ANY WEBSITE TO WHICH THE SITES CONTAIN A LINK. YOU MAY HAVE RIGHTS DIRECTLY ENFORCEABLE AGAINST THESE THIRD PARTIES SO YOU SHOULD CONSIDER THEIR PRIVACY POLICIES TO LEARN MORE.
- 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 MyJobAlly’sbusiness (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 carried out by MyJobAlly of such third parties.
- Exercising Rights With Respect to Personal Data
As a user of these Sites, you may exercise the rights explained below. Please note, we may attempt to verify your identity through the email address or telephone number associated with your use of our Sites prior to fulfilling any such request and reserve the right to deny a request where we are unable to satisfactorily complete this process. If you authorize someone to make a request on your behalf, we may also deny your request if we are unable to verify with you that the individual making the request is authorized to act on your behalf.
10.1 The Right to Rectify Your Personal Data
Users of these Sites are able to edit and update most of their Personal Data held by each Site on the Site in question, and if you have any queries or complaints we encourage you to contact us.
Alternatively, if you do not wish to do this you may make a formal request to have MyJobAlly rectify any inaccurate Personal Data on your behalf by sending an email to “privacy-dept @ MyJobAlly.com” (remove spaces when sending email) 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 us.
Alternatively, if you do not wish to do this you may make a formal request to object to, or restrict, processing of your Personal Data by each Site. For example, you have the right to object to the legitimate interest processing of your Personal Data by each Site for marketing purposes.
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 a number of options available to you.
If you wish to opt out of a particular marketing email from the Site, you may do so by clicking “unsubscribe” (or an equivalent action) where applicable. Please note that this will only opt you out of that particular marketing message.
If you wish to adjust all of your job alerts, you can click on “edit this job alert” (or an equivalent action) to adjust your subscriptions. You can also access and adjust your subscriptions (for job alerts, recommended jobs, and other notifications) from your account dashboard (where applicable), or contact Customer Support to do so.
In addition, you may opt out of all marketing messages by sending an email to privacy-dept @ MyJobAlly.com (remove spaces when sending email). 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
Users of these Sites are able to access most of their Personal Data provided to each Site on the Site in question, and if you have any queries or complaints we encourage you to contact us. Alternatively, if you do not wish to do this you may make a formal request to access your Personal Data held by MyJobAlly.
10.5 The Right to Delete Your Personal Data
Users of these Sites are able to edit and update most of their Personal Data held by each Site on the Site, and if you have any queries or complaints we encourage you to contact us.
Alternatively, if you do not wish to do this, you may make a formal request to delete your Personal Data provided to each Site.
PLEASE NOTE: by requesting the deletion of your Personal Data, you will no longer be able to create an account with the Site in question using the same email address. If you simply wish to close your account, please click the “close my account” button in your account page. If you use MyJobAlly Apply for an application or take any other action on the Site in question using the same email address associated with your deletion request, you may not receive certain communications associated with those actions from the Site in question or other users of that Site. Additionally, by making a personal data deletion request, you acknowledge that you will be removed from consideration for all active sweepstakes, contests, prize draws, and other promotions.
If you are a Job Seeker and want to delete a job application performed from the Site in question, please contact the prospective Employer directly to request deletion of your application. If you are a Job Seeker who submitted a job application to work at MyJobAlly, please refer to the privacy policy you received when you applied, or reach out to your recruiter, for additional instructions on how to exercise your rights.
10.6 Withdrawing Consent
There are certain activities where we ask for your consent to use your Personal Data. You have the right to withdraw this consent at any time. Where you are providing location information via a mobile app, you may turn off your location services on your device at any time. For other services that rely on your consent, you can withdraw your consent via the workflow for that given service. Please note that any processing that we have carried out before the withdrawal of your consent remains lawful.
10.7 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 us confirming your request. Where permitted, please note there may be a charge for subsequent requests from the same individual, which will be determined by MyJobAlly and only imposed to the extent permitted by applicable law.
- Personal Data from Individuals in the EEA and Switzerland
11.1 GDPR Protections
Where appropriate, MyJobAlly Ireland’s transfers of Personal Data of individuals in the EEA and Switzerland to jurisdictions outside the EEA and Switzerland are performed based on the European Commission’s standard contractual clauses. These agreements also incorporate the protections and requirements provided for under Chapter V (and Article 28, where appropriate) of the GDPR.