PRIVACY POLICY

Last updated: 05 July 2023

1. INTRODUCTION

1.1 About. JSE Global Solutions LLC (“we”, “us”, or “our”) operates the business known as Jobsora, which provides services, defined below, including through the website Jobsora.com (“Site”).

1.2 Acceptance. Your use of this Site constitutes your acceptance of this Policy. If you do not agree with this Policy, you may not use our Site. This Policy may change from time to time, and the date of last update is indicated at the top of this page.

1.3 Changes. We reserve the right to make changes to this Policy at any given time. If you want to make sure that you are up to date with the latest changes, please be sure to check back periodically. Your continued use of this Site after we revise this Policy is deemed to be acceptance of the revisions, so please check this page from time to time for updates.

2. ABOUT US AND OUR SERVICES

2.1 Data Controller. The Data Controller, in accordance with the General Data Protection Regulation (EU) 2016/679 (known as GDPR), is JSE Global Solutions LLC is a Bulgarian company ((UIC) 205886342) with its registered address at Sofia, 1000, 24 Han Asparuh str.,1st floor, Bulgaria.

2.2 About our Services. Our Site is a job aggregator, that means that we index job vacancies published online and allow you to search all of these different job postings easily within one place, our Site. It’s effectively like a search engine, for job vacancies. We don’t input into the hiring or selection processes, and are not a recruitment firm, we simply index available vacancies published by others and when you choose to apply for a vacancy you will be redirected to the original job post on the third party site or service directly or using our easy apply service. We also offer lots of tips and hints to job seekers, and have newsletters and other informative content. Some features of the Site include the ability for job seekers to upload a CV, create a CV, or simply get alerts about new posts in careers that are of interest to you. We also offer recruiters opportunities to broadcast their vacancies with us through collaboration. Collectively our activities, products and features on the Site and the Site itself, are referenced in this Policy as the “Services”.

2.3 Commitment to privacy. We take a serious approach to safeguarding privacy rights and respecting them, and in particular we comply as a baseline across our business with the General Data Protection Regulation ((EU) 2016/679, known as GDPR) in recognition of the high standards of rights. Note however that depending on where you live you may not be protected by data privacy laws, or you may have different protection under law. Where we comply with other specific laws, we will state this within this Privacy Policy.

2.4 Protection of minors. We do not solicit or target persons under 18 years of age. We do not knowingly collect any information relating to children under the age of 18. If we discover that a child under 18 has provided us with personal information, or we have otherwise came into possession of personal information of a child, we will promptly delete such personal information from our systems.

3. WHO THIS POLICY APPLIES TO

3.1 This Policy (a) applies to any visitor to our Site, any individual who access the features of our Site, and to any professional recruiter or hirer using our Site, and (b) outlines how we collect, store, process and use personal data of such Jobseekers, Recruiters and Site Visitors.

Jobseeker’ means you, if you are an individual who is searching our Site for job vacancies, or have created an account with us for the purposes of learning about career development and job opportunities/applying for positions.

Recruiter’ means you, if you are a person acting in a business capacity who is using our Site or Services for the purposes of establishing a business relationship with us, or Jobseekers, including recruitment of Jobseekers.

Site Visitor’ means you, if you are not considered a Jobseeker or Recruiter, but are any other person who is accessing or otherwise making use of our Services, including this Site.

4. APPLICABLE LAWS

4.1 Understanding what laws apply to us. Notwithstanding our compliance with GDPR, for any person resident outside of Europe, we do comply with the following other named laws and regulations if you are resident (a) in the UK, we comply with the UK’s Data Protection Act 2018 and the UK’s Retained GDPR, or (b) in California, USA, we comply with the California Consumer Privacy Act (as amended by the 2020 legislation, if applicable to you), or (c) in Virginia, USA, we comply with the Virginia Consumer Data Protection Act (Va. Code Ann. §§ 59.1-575 to 59.1-585). We collectively refer to these stated laws including GDPR in this Privacy Policy as “Data Laws” and any reference to ‘personal data’ within this Policy, has the meaning ascribed to it by Art.4 of the GDPR. For residents of Virginia, USA or California, USA, we refer to your state laws as “US Data Laws”. Please note that, for South African residents, POPIA does not apply to us as we are not located within South Africa, nor are we processing any data within South Africa.

4.2 LAWFUL BASIS FOR PROCESSING PERSONAL DATA

Under certain Data Laws that may apply to our processing of personal data belonging to you we require a lawful basis for processing that personal data.

Contract. In some cases, our lawful basis for processing your Personal Data is ‘contract’, meaning for the purposes of performing a contract to provide the Services to you, or for taking steps prior to entering into a contract such as for Site Visitors considering using our Services, or for Recruiters seeking to collaborate in business with us, or for Jobseekers to receive our career products and features.

Consent. In some cases, where contract is not the appropriate lawful basis, for example for marketing to you by email, we obtain the relevant consents from you (which you can manage and opt out of through your account settings with ease).

Legitimate interests. Where neither contract nor consent is appropriate, legitimate interests is the lawful basis.

Legal obligation. We may require to process your Personal Data to comply with a legal obligation as permitted by Data Laws, including retaining your Personal Data for set time periods in order to act in compliance with international laws and regulations that we are bound by as a business.

5. HOW WE COLLECT YOUR DATA (INCLUDING PERSONAL DATA)

5.1 Generally. We may collect information about directly from you, automatically through your use of our Services, or from third parties (if applicable). We may combine information collected from or about you from these various sources. The data we collect depends on the context of your interactions with us and our Services, the choices you make, including your privacy choices, and the products and features of our Services that you use or access.

5.2 When you provide it to us or use our Services. We collect information about you directly from you as you input the information to our Site when you use our Services, for example when Recruiters complete contact forms, or when Jobseekers upload CVs and/or create accounts to receive job alerts, or when you sign up to any mailing list and provide personal data such as email.

5.3 When you communicate with us and provide your data. If you contact us in any manner we will keep any information you provide to us including records of correspondence, and you should be aware that we monitor and may record telephone calls and written correspondence for training and security purposes. If you provide feedback or testimonials to us, or take part in any user survey, or participate in events, promotions, product, feature or service launches, or competitions, we will collect any information you provide voluntarily when doing so.

5.4 When you upload content to our Site. If you are uploading or creating a CV, or otherwise uploading any form of content to the Site, or your account with us, we will process that information in accordance with this Policy, (we call that content User Content), as well as other information, such as your name, may be available to us and potentially Recruiters if you choose this.

5.5 Information we collect automatically. If you are using the Services or a Site Visitor browsing the Site, we may automatically collect information about you through your use of our Services, and we explain those types of data below. We may combine information we collect automatically with information we collect directly from you or from other sources. Please see our Cookies section below for more information.

5.6 Information we collect from third parties. We may also collect information about you from third parties, for example, acquired from parties we have partner data sharing agreements with. We may also obtain information from third parties if you sign up to, or log into our Services using a third-party platform (e.g., Facebook, or Google), then we may collect the following information:

  • Facebook. If you log into our Services using Facebook, you must enter your Facebook email address and password. We will ask that you grant us permission to access and collect your email address, name, and profile picture. If you allow us to have access to this information, then we will have access to this information even if you have chosen not to make that information public on Facebook.
  • Google. If you log into our Services using Google, you must enter your Google email address and password. By logging in through Google, you are granting us access to your email address, name, and profile picture.

Please keep in mind that any third-party social networking platform controls the information it collects from you, how it is shared, and what permissions we are able to request. For information about how they may use and disclose your information, including any information you make public, please consult their respective privacy policies.

6. TYPES OF DATA WE COLLECT AND PROCESS

6.1 For all Site Visitors, Jobseekers and Recruiter. If you sign up to our mailing lists, or otherwise request to receive news or updates from us, we will collect information such as your email address. We will also collect data (automatically) about your activity on the Site such as access logs and click logs meaning (a) log information including your Internet protocol (IP) address, the type of browser you are using, information about the device you are using, domain name, the website that led you to our Services, the website to which you go after leaving our Services, your location, and the dates and times you access our Services, and (b) your interaction with the Site such as pages visited, content viewed and searched for, vacancies clicked and viewed. Please also read our Cookie section below for more details about our use of cookies.

6.2 Jobseekers. We may collect and process your personal details including but not limited to your email, name, telephone, location, and any other information you submit when you create an account or otherwise access our Services and opt to input data including data related to your CV such as education, work experience, skills, certifications, publications and similar information you choose to share with us. We may also collect information about your search history in terms of jobs you have searched for, vacancies you have clicked on, locations searched, and types of roles searched, in order to improve the jobs that are displayed. See section 7.7 Profiling for more information.

6.3 Recruiters. If you contact us to discuss commercial relationships with us, we may collect your name, email address, telephone number and company name, together with any other information you freely provide to us when corresponding.

7. HOW WE USE YOUR INFORMATION

7.1 Providing and Improving the Services.

We use the information we collect about you:

  • to provide and maintain our Site and Services and to fulfil your requests for our products, and services on the Site and across our Services;
  • to improve our Services;
  • to develop new features, programs, products, or services and to offer these to you from us, our affiliates and selected third parties that we believe may be of interest to you;
  • to perform technical operations, such as updating our Services and systems;
  • to authenticate and/or validate those who hold accounts such as Jobseekers, and ensure your qualifications to use our Services;
  • for customer service and support purposes;
  • for Jobseekers; if you create or upload a CV, and provide your email address to us, we may mark your account as eligible for our Easy Apply feature to enable faster applications for vacancies advertised.

7.2 Communications.

We use the information we collect about you:

  • for any person who has subscribed to a mailing list, provided their email, or for any Jobseeker who has set their account to receive communications, to provide you with news and newsletters, special offers, promotions, and other information from ourselves, our affiliates and selected third parties we think may interest you and for other informational, marketing, or promotional purposes. Our communications with you may include communications via email;
  • to notify you when we make changes to our terms or policies if necessary; and
  • to otherwise enforce or exercise any rights in our terms and policies
  • for Jobseekers: to contact you about your account with us (including managing your account and providing you with customer support and product updates and new vacancy alerts/career tips and hints);
  • for Jobseekers, Site Visitors and Recruiters: to respond to your enquiries;

7.3 Research and Analytics.

We use the information we collect about you:

  • To analyze how you interact with our Services;
  • to monitor and analyze usage and activity trends; and
  • for other research, analytical, and statistical purposes.

7.4 Protecting Rights and Interests.

We use the information we collect about you:

  • To protect the safety, rights, property, or security of our business, the Services, any third party, or the general public;
  • to detect, prevent, or otherwise address fraud, security, or technical issues; to prevent or stop activity which we, in our sole discretion, may consider to be, or to pose a risk of being, an illegal, unethical, unlawful, or legally actionable activity (or which we are informed about from any other source including law enforcement or third party rights holders);
  • to use as evidence in litigation or any other civil dispute, matter or criminal matter; and
  • to enforce this Privacy Policy or our Terms of Use or other policies which apply to your use of the Services which you have agreed to comply with as a Site Visitor, Jobseeker or Recruiter.

7.5 Legal Compliance.

We use the information we collect about you to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.

7.6 Use of non-personal information.

We use aggregate information about you, and non-personal information that we collect, to:

  • improve the design, functionality, and content of our Site and Services and to allow us to personalize our Services;
  • provide, maintain, personalize, protect, improve, and develop our products, programs, and services and to operate our business;
  • analyze usage and performance of our Site and Services and for other research, analytical, and statistical purposes; and
  • tailor content displayed or delivered to you, for us and our affiliates, business partners, and selected third parties to offer you products, programs, or services when you use the Services.

7.7 Profiling.

Profiling means that we may analyse your information and User Content in order to tailor the content that is displayed or broadcast to you whether on the Site or through our communications with you, for example, for Jobseekers this means that you will be shown vacancies that we believe may be most relevant to you after analysis of your CV, and Site activity such as past searches. Consent to profiling is given by you when accepting this Privacy Policy, although you may opt out at any time and revoke that consent by contacting us.

8. HOW AND WHEN WE DISCLOSE YOUR DATA

8.1 Disclosing Jobseekers’ information to Recruiters or third party hirers. If any of our Services include features that allow you to share User Content with us, such as your CV, and you then use a feature such as Easy Apply, we may share your User Content and information about you to that Recruiter, or advertiser of the job post to which you have applied.

8.2 Sharing with our affiliates. We may disclose your information to current or future affiliates or subsidiaries for research, marketing, and other purposes consistent with this Privacy Policy. Within our corporate group business, we may require to share your information to allow us to provide the services to you, if our companies support us in the context of being service providers, which may include, data hosting, server maintenance, customer support, data analytics, marketing, legal and financial services, and safety and security services.

8.3 Sharing to third party service providers. We may disclose your information to our vendors, service providers, agents, or others who perform functions on our behalf and we take all steps to ensure that such providers are under contract to comply with applicable Data Laws.

8.4 Sharing/transferring your personal data for corporate activity purposes. We may disclose your information to another party in connection with, including during negotiations of, an acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer to a buyer or prospective buyer of our business, our professional advisers, such as our lawyers or compliance advisors, or accountants, where it is necessary for them to advise and to any other persons if we are under a duty to disclose or share your information in order to comply with any legal obligation. In the event of our business being sold or otherwise acquired by another party your data may form part of the transferred business or assets and you understand that this may be the case, and further (in respect of UK and EU residents only) you understand and consent to the physical transfer of your data outside of the UK or EU if applicable, if that party is located outside of the UK or EU.

8.5 Sharing for protection of rights and interests. We may disclose your information to protect the safety, rights, property, or security of our business, the Services, any third party, our users, or the general public; to detect, prevent, or otherwise address fraud, security, or technical issues, or loss or risk to life or threat of serious harm; to prevent or stop activity which we, in our sole discretion, may consider to be, or to pose a risk of being, an illegal, unlawful, unethical, or legally actionable activity; to use as evidence in litigation; and to enforce this Privacy Policy or our Terms of Use.

8.6 Sharing for legal or regulatory compliance. We may be required by law, through potential or actual litigation, court order, public or governmental authorities, or rules and regulations within or out with your country of residence to disclose all or part of your information to third parties. We may also deem it necessary to make such a disclosure in the event of an issue of national security, law enforcement or other such similar situations as we deem necessary including, for example, allegations of alleged infringement of copyright, trade marks or other third parties’ rights by users or any criminal activity, whether formal or informal, from law enforcement or a government official or regulatory body.

8.7 Sharing of aggregate and anonymised information. We may disclose aggregate, anonymous, or de-identified information about you for marketing, advertising, research, compliance, or other purposes.

9. MARKETING AND COMMUNICATIONS

9.1 Marketing by us, to you. We may share your information with our affiliates or third parties to develop and deliver targeted advertising to you of our or third-party products and services, or to help us to prepare marketing reports. We may send you information about our or our affiliates’ products and services, news and offers, and selected third party products and services that we think may be of interest to you. We may do this by contacting you through your email address or mobile phone number that you have provided. Any communication received from us, as consented to by you, will clearly state that it is being sent by us. You have the option to opt-out of our marketing communications at any time (see below).

9.2 Third party marketing. If you have consented to receive marketing communications from third parties your data may be passed on to such third parties as we enter into data sharing agreements with, from time to time, for marketing and analytical reporting purposes. We cannot be held liable for the content of the third party’s communications or products/services they are promoting. If you have provided this consent, but change your mind, you can opt-out at any time (see below). Please be advised that you will also require to contact the individual third parties who have been marketing to you if you wish to stop receiving their communications directly. Such parties can include other career specialist services, what we call our Partners, who offer similar services to ourselves. Currently, our Partners and their associated privacy policies are:

9.3 Opting from marketing and communications. If you are, a Jobseeker, or a person who has previously consented to receive marketing communications, and have changed your mind about the marketing consent you have granted to us, or you wish to update your choices about receiving tips and advice or such other communications (or the frequency of these), you can follow the opt out procedures contained in any marketing email, or you can adjust your communications preferences easily within your account to tailor the messages you’d like to keep receiving. Please be aware that it may take up to ten (10) business days for us to process opt-out requests.

9.4 Opt-out exceptions. If you are a Jobseeker and request to opt out of our marketing or communication emails, please be aware that opting out of marketing emails will not impact upon email communications you may continue to receive which are relevant to the administration of your account, or relative to any other Services you have requested to receive from us (unless those have been opted out of also or adjusted in your account settings), or which are required in order to communicate with you regarding any support, response, regulatory, legal or other permitted use as described in this Policy.

10. STORAGE AND RETENTION OF YOUR DATA

10.1 Storage locations and international transfers. If we are processing and storing your personal data as a Site Visitor, Jobseeker or Recruiter, then that data is stored on our servers in the Netherlands. If you are a resident of the European Economic Area ('EEA') please be informed that we may transfer your data outside of the EEA countries. By submitting your personal data to us as a resident of EEA, you agree to any such transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy and we enter into appropriate agreements with any third parties in compliance with Data Laws for such transfer purposes.

10.2 Retaining your personal data. We retain the data collected pursuant to this Privacy Policy for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law, including Data Laws. Thereafter if the collected data is no longer needed for purposes specified in this Privacy Policy, we delete all aforementioned data in our possession within a reasonable timeframe, ensuring we only retain the data we need (or parts of it, for example for legal purposes). Typically this may see us retain some elements of data for up to 3 years. Irrespective of the above, we may still retain some of the data to the extent such retention is necessary to enforce our terms or policies, and comply with technical and legal requirements and constraints related to the security, integrity and operation of Services and international law enforcement, regulatory requests, or matters of dispute. If your account is ever terminated by us, or you have been identified by us as a potential or otherwise threat to our business, our Services, our Site or our users, your email address will be retained on our internal blacklist for as long as we deem necessary to protect the business and its users.

11. YOUR RIGHTS TO YOUR DATA

11.1 Introduction. Data Laws give users a number of rights which you are free to exercise at any time regarding any personal data that you have provided to us and we generally apply the rights afforded by the GDPR to all users, even if they are not resident in Europe. We will respond to requests to access or delete your personal data promptly and in any case within any time limits set by applicable Data Laws (if applicable to us in your case). We have summarised the rights here and how you can exercise them to ensure that we are reasonably and fairly processing your personal information in line with your rights, however you should obtain your own legal advice if you wish to rely on any legislative rights not covered here which you believe in good faith we have a duty to respond to. Subject to our own legitimate interests and any regulatory requirements placed upon us we will endeavour to meet requests made in exercising your rights.

11.2 Specific rights for residents of California, USA or Virginia, USA. If you are a resident of California, or Virginia, USA, please review Section 13 which contains specific rights applicable to you.

11.3 Verifying you when you make a request. We may require you to provide identification if you are exercising some of these rights, for cases where it is not immediately obvious that you are truly the person to whom the personal information relates, as we need to be certain before making any changes to someone’s personal information that it is your information (or you have that person’s authority to act for them). If identification documents are requested as part of the process; that document will only be collected, stored and processed by us for the sole purpose of confirming your identity in response to your request, and upon completing your request we will delete it.

11.4 Use of your email address. We may need to communicate with you in response to your request, and we may require to update you on progress/confirm outcomes. We do this by email. If you contact us by email, we have the fair expectation of a legitimate interest to provide a response to you following your instigating of the communication. Where any rights exercised by you result in you seeking to object to us processing your personal information or otherwise deleting your personal information, then in order to ensure we do not process any personal information of yours in future, we will retain your email address for the purpose of our opt out list only, and we will delete or anonymise all other information held.

11.5 Retaining other information. Sometimes we need to keep a record of some data for security purposes (for example to assist law enforcement agencies with any criminal investigations or other regulatory authorities or dispute matters) or for payment processing (to prove to banks that we were authorised to take payments from you if you pay to use the Services), even if you have requested removal of your data. Any such data retained will only be used for these limited purposes.

11.6 Important information about removal. We can only be responsible for removing any personal data or User Content that we hold on our servers, or hold otherwise within our control or possession.

12. EXPLAINING YOUR DATA RIGHTS AND HOW TO EXERCISE THOSE RIGHTS

12.1 Accessing your personal data and/or amending/correcting your personal data.

  • You can request a copy of the personal data that we hold about you, and/or request a correction or amendment to your personal data, by emailing compliance@jobsora.com
  • stating your request, and you must include your name, email address and any relevant information to help us locate your information.
  • Upon receipt of your request and following verification of your identity if required by us to process your request, we will process your request within a reasonable time (or within any time limit set by Data Laws). In respect of making a request to access your personal data, known as a data subject access request under some Data Laws, if you seek to make multiple requests within a short time period, we reserve the right to charge a nominal fee to cover the cost of our response to multiple access requests.

12.2 Objecting to processing of your personal data

  • It’s ok to change your mind about what personal data you are allowing us to use and keep and what you don’t want us to use or keep. We have to advise you however, that opting out of some personal data processing/storage may result in a loss of functionality of the Services and a reduced user experience. You can tell us at any time that you want us to stop processing your personal information by emailing compliance@jobsora.com stating your request, and you must include your name, email address and any relevant information to help us locate your information.
  • Upon receiving a request from you, and after verifying your identity, we will promptly stop processing your personal information (subject to retention explained in Section 10.2) and, if you are a Jobseeker, we will take steps to close your account as we will be unable to administer your account and provide the Services to you if we are unable to process your personal data necessary for the account operation.

12.3 Your right to ask us to delete or destroy your personal information:

  • You can request that we remove and delete your personal information (which, for Jobseekers or other account holders, will mean your account will be closed). We treat any request to destroy personal information as being a request to fully delete all such personal information, unless you tell us otherwise, we will assume that you wish to be removed entirely, subject to data retention explained in Section 10.2. You can tell us at any time that you want us to delete your personal data by emailing compliance@jobsora.com stating your request, and you must include your name, email address and any relevant information to help us locate your information.
  • Upon receiving a notice from you via the form submission you make, further to any verification we may need to make, we will take all reasonable and practical steps to remove your personal information from our Services, and in the case of Jobseekers, or other account holders, we will close your account.

12.4 Additional rights for residents of UK or EU only

  • Right to “be forgotten”. This right allows you to request full erasure of your personal data, and is for residents of the UK and EU only.
  • Right to data portability. This right allows you to receive personal information in a structured, commonly used, and machine-readable format and is for residents of the UK and EU only. Please email compliance@jobsora.com with your name, email and any relevant additional information to enable us to process your request.
  • Exercising these additional rights. Please email compliance@jobsora.com stating your request if you are a UK or EU resident, and include your name, email address and any relevant information to help us locate your information. Upon receiving a notice from you via the form submission you make, further to any verification we may need to make, we will take all reasonable and practical steps to process your request within a reasonable time (or within time limits set by any Data Laws).
13. SPECIAL NOTICE FOR RESIDENTS OF CALIFORNIA, OR VIRGINIA, USA

13.1 If you are resident in California, or Virginia, USA, we have prepared this Notice to comply with the US Data Laws, if applicable to you/us. Any reference to ‘personal information’ in this Section 13 has the meaning given to that phrase by the applicable US Data Laws.

13.2 Personal Information collected. In addition to the information provided in this Privacy Policy at Sections 5 and 6, this Section 13 further details important information related to categories of personal information collected, what personal information is collected, and the sources of that personal information.

13.3 Categories of personal Information Collected. We collect identifiers (‘Identifier Data’), internet or other electronic network activity information (‘E-Data’), geolocation data (‘Location Data’) and Employment-related information (‘Employment Data’). We do not collect sensitive personal information as defined by US Data Laws.

13.4 What personal information is collected. In addition to any information stated in Sections 5 and 6 of this Privacy Policy, we can provide the following details:

  • Identifier Data may include full names, email addresses, phone numbers, IP addresses, device identifiers, social media profiles, business emails, job titles and company or employer information, business mailing addresses.
  • E-Data may include data related to how you interact with our Site or Services (as defined in our Privacy Policy) over the internet and across your devices.
  • Geolocation Data may be physical location data derived from IP addresses or business location addresses.
  • Employment Data may include business email addresses, telephone numbers, physical business addresses or mailing addresses, employment status, employment history, job titles and employer names or business names.

13.5 Sources of the personal information collected. In addition to anything else stated within this Policy, the sources of personal information collected for each of the data sets listed at section 13.4 above, are directly or indirectly from your activity on our Site or Services, your User Content, your communications with us or acquired from third parties (with such parties being responsible for their compliance with all US Data Laws when sharing your data to us).

13.6 Purpose of collection of personal information. Section 7 of our Privacy Policy set out the purposes of collection and we will not collect personal information for any purpose other than any purpose disclosed to you within this Privacy Statement or our Privacy Policy.

13.7 Sharing your personal information. How we share your personal information is set out in Sections 8 and 9 of this Policy. Please note that we may share/sell your personal information (email address, vacancy and city location of vacancy search) with our Partners, which are:

Virginia state law provides exceptions for sharing personal information meaning that, if you opt-out of data sharing, we do not need to honour that opt out, if we require to disclose your information in the following permitted ways (i) to a third party acting as a data processor for us e.g. payment processing provider, (ii) to a third party for purposes of providing a product or service that you have requested we/they provide to you, (iii) to our affiliate companies, (iv) if the information is information you have intentionally made available to the general public via a mass media channel and did not restrict such information to a specific audience e.g. information which is publicly available through such platforms, and (v) as part of a merger, acquisition or such similar corporate transaction.

13.8 Retaining your data. US Data Laws require us to share information with you about our data retention periods, ensuring that we are minimizing the amount of time we are holding your personal information and limiting this to as long as is necessary. We fully describe our data retention provisions in sections 10.2 and 11.5 of this privacy policy.

13.9 Your rights depending on whether you live in California, USA or Virginia, USA:

  • You have the right to obtain from us access to the information we hold on you, and you are entitled to know if we have shared that information with any third parties. If you would like to request this information, please submit your request by emailing compliance@jobsora.com or writing to us (see the end of this Policy for our full contact details).
  • You have the right to ask us to delete all the personal information we hold on you. If you would like to request the deletion of your information, please submit your request by emailing compliance@jobsora.com or writing to us (see the end of this Policy for our full contact details).
  • It is important to protect you that we ensure the person making the request to access or delete your personal information is really you and we will contact you to let you know what else we need from you before we send you a copy of your personal information, which currently involves providing us with photographic identification (which is used for the purpose of verifying your identity and is not otherwise used or stored by us). You are entitled to receive a response from us within 45 days to any request for access to or deletion of your personal information. Any disclosures made by us will only cover a period of 12 months prior to the date of the request and you may only make a request for access to, or for data portability, twice within any 12 month period – any additional requests will be at our discretion to process.
  • Please note that Your Right to Access and Right to Deletion are not absolute and are subject to certain exceptions. For instance, we cannot disclose specific pieces of Personal Information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the Personal Information, your account with us if you are a User, or the security of the our systems of networks. Further, we may be entitled to retain certain information in order for us to provide Services contemplated at the time your information was collected and which can be reasonably anticipated, to assess and detect and prevent any security incidents or malicious, fraudulent or otherwise illegal or unlawful activity, to comply with any additional laws, for scientific or analytical research if so permitted, to comply with obligation placed upon us by any court, government or regulatory authority, to assist law enforcement, or to make any other internal uses of the information what remain compatible with the purposes for which it was initially collected.
  • You have the right to understand how we share or sell your personal information (as described in this Privacy Policy), and importantly you have the right to limit our use of your data/opt out of having your Personal Information sold/shared as defined in the US Data Laws. To opt out of any data selling please visit our dedicated ‘Limit/Do Not Sell/Share My Info‘ page which provides details of how you can easily limit our data use and/or opt out of any future sales/sharing of your information, if applicable.
  • You have the right to appoint an authorized agent to submit a request to opt-out of the sale of personal information on your behalf if you provide the authorized agent written permission to do so. If you use an authorized agent to submit a request, he or she must provide their name, email address, phone number, and written permission from you that includes your contact information. We will contact you using the information provided and verify your identity directly with us. We cannot respond to your request to provide additional disclosures or delete any personal information if we cannot verify your identity and the authorized agent’s authority to make the request on your behalf. Written permission is not required if the agent provides proof of power of attorney.
  • You have the right to not be discriminated against by us for exercising your rights, and we do not discriminate against any person, although you understand that it may not be possible for us to provide the Services if we don’t have access to certain information that is required to ensure the Services can be properly provided to you.
  • For residents of Virginia, USA only, you may have the right to appeal our refusal of any data request your make, through an appeal process. To appeal our refusal to provide the information (if this ever occurs), please write to us at compliance@jobsora.com We are legally obligated to respond within 60 days to you. If we do not accept your appeal you will then be entitled to escalate the matter by the submitting a complaint to the Virginia Attorney General’s office by mailing mailoag@oag.state.va.us or writing to 202 North Ninth Street. Richmond, VA 23219. We cannot guarantee these details are accurate and if you require to contact the AG Office, please double check all contact information.
14. COOKIES

14.1 About cookies. Cookies are small text files which a website may put on your computer or mobile device when you first visit a site or page. The cookie will help our Site, or another website, to recognize your device the next time you visit. For example, cookies can help us to remember your username and preferences, analyze how well our website is performing, or even allow us to recommend content we believe will be most relevant to you.

14.2 Use of cookies and why. We may use cookies for the following reasons and purposes:

  • To provide the service you have asked for. Some cookies are essential so you can navigate through the website and use its features. Without these cookies, we would not be able to provide the services you’ve requested. For example, some cookies allow us to identify subscribers and ensure they can access the subscription only pages. If a subscriber opts to disable these cookies, the user will not be able to access all of the content that a subscription entitles them to. These cookies don't gather information about you that could be used for marketing or remembering where you've been on the internet. Essential cookies keep you logged in during your visit.
  • To improve your browsing experience. These cookies allow the website to remember choices you make, such as your language or region and they provide improved features. These cookies will help remembering your preferences and settings, including marketing preferences, remembering if you've filled in certain forms, so you're not asked to do it again, remembering if you've been to the Site before and restricting the number of times you're shown a particular advertisement. We might also use these cookies to highlight Site services that we think will be of interest to you based on your usage of the website.
  • Analytics. To improve your experience on our Site, we like to keep track of what pages and links are popular and which ones don't get used so much to help us keep our Site relevant and up to date. It's also very useful to be able to identify trends of how people navigate (find their way through) our Site and if they get error messages from web pages. This group of cookies, often called "analytics cookies" are used to gather this information. These cookies don't collect information that identifies you. The information collected is anonymous and is grouped with the information from everyone else’s cookies. We can then see the overall patterns of usage rather than any one person’s activity.
  • To show advertising that is relevant to your interests. We may sell space on our Site to advertisers. The resulting ads often contain cookies. These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with our permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers.

14.3 Managing your cookie choices. Most browsers allow you to turn off cookies. To do this, look at the "help" menu on your browser. Switching off cookies may restrict your use of the Site and/or delay or affect the way in which it operates.

15. DATA SECURITY MEASURES

15.1 What we are doing. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Site/Services and any transmission is at your own risk. We take reasonable administrative, physical, and electronic measures designed to safeguard and protect your information from unauthorized access or disclosure. This includes using secure software and storing your information in encrypted form behind a firewall designed to block access from outside our network. Although we use commercially reasonable efforts to safeguard the privacy of your information, transmissions on the Internet cannot be made absolutely secure. Where any information is required to be disclosed to third party service providers to ensure the provision of Services to you, all such third parties are subject to strict agreements to ensure the continued safeguarding of your data as much as possible. We assume no responsibility or liability for disclosure of any of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our reasonable control.

15.2 What you should do to protect yourself. You should take steps to protect against unauthorized access to your device and your User account by, among other things, choosing a robust password that nobody else knows or can easily guess and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

15.3 Third party links. Our Services as an aggregator will contain links to third-party websites and applications. Any access to and use of such linked websites and applications is not governed by this Privacy Policy but instead is governed by the privacy policies of those third parties. We are not responsible for the information practices of such third-party websites or applications and you should use caution and closely review any privacy policies applicable to any third-party websites or applications that may be linked to through our Site or Services.

16. CHILDRENS PRIVACY

16.1 No targeting to minors. Our Site is not directed to children under the age of 18. We do not knowingly collect any personal information about children under the age of 18. If we obtain actual knowledge that we have collected personal information about a child under the age of 13, that information will be immediately deleted from our database.

16.2 Awareness of children’s data. If a parent/guardian believes that his or her child has submitted personal information to us, he or she can contact us via e-mail. We will promptly delete the information upon learning that it relates to a child under the age of 18. Please note that it is possible some of this information may remain archived in web logs and back-up archives after we delete the information from our active database.

17. IMPORTANT INFORMATION

17.1 LIMITATION OF LIABILITY. SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF CERTAIN DAMAGES, SO THE FOLLOWING LIMITATION AND EXCLUSIONS MAY NOT APPLY TO YOU AS A PERSON, A SITE VISITOR, A JOBSEEKER, A RECRUITER OR ANY OTHER FORM OF USER OF OUR SERVICES WHICH INCLUDES THE SITE. TO THE FULLEST EXTENT ALLOWED BY APPLICABLE LAW, UNDER NO CIRCUMSTANCES AND UNDER NO LEGAL THEORY (INCLUDING, WITHOUT LIMITATION, TORT, CONTRACT, STRICT LIABILITY, OR OTHERWISE) SHALL WE (OR OUR LICENSOR(S) OR SUPPLIER(S)) BE LIABLE TO YOU OR TO ANY OTHER PERSON FOR (A) ANY INDIRECT, SPECIAL, INCIDENTAL, OR CONSEQUENTIAL DAMAGES OF ANY KIND, INCLUDING DAMAGES FOR LOST PROFITS, LOSS OF GOODWILL, WORK STOPPAGE, ACCURACY OF RESULTS, OR COMPUTER FAILURE OR MALFUNCTION, OR (B) ANY AMOUNT, IN THE AGGREGATE, IN EXCESS OF THE GREATER OF (I) $100 OR (II) FOR PAYING CUSTOMERS, THE AMOUNTS PAID BY YOU TO US IN CONNECTION WITH THE SERVICES IN THE THREE (3) MONTH PERIOD PRECEDING THIS APPLICABLE CLAIM, OR (C) ANY MATTER BEYOND OUR REASONABLE CONTROL.

17.2 GOVERNING LAW AND JURISDICTION. This Privacy Policy will be governed by the laws of England and Wales (unless any Data Laws take precedence). Any disputes relating to this Privacy Policy, or the Services to which they relate, will be heard exclusively in the courts located in England, UK.

17.3 LANGUAGE. This Privacy Policy is written in the English language and any proceedings relating to these documents and any related dispute shall be conducted in English. If we make these documents available in any other language, the terms in the English language version shall prevail.

18. Our company information
  • Our company name: JSE Global Solutions LLC
  • Our company number: (UIC) 205886342 registered in Bulgaria
  • Our registered office address: Sofia, 1000, 24 Han Asparuh str.,1st floor, Bulgaria
  • Our support email: compliance@jobsora.com
  • Our website: jobsora.com
19. Important Representative Contact Information

19.1 Contacting our Data Protection Officer

Should you have any reason to contact our Data Protection & Information Officer, they can be contacted by emailing compliance@jobsora.com or writing to GDPGuard, 4th Floor, Silverstream House, 45 Fitzroy Street, Fitzrovia, London, W1T 6EB

Any communications to the DPIO which do not relate to data protection and privacy matters will not be responded to.

19.2 GDPR Art. 27 Representative

In accordance with GDPR, as we are established in Europe, we are not required to designate an EU Representative and all enquiries may be made to the Data Protection & Information Officer.

19.3 UK Applied GDPR Art.27 Representative

In compliance with the UK Data Protection Act 2018, we are required to designate a UK Representative and we have appointed a third party representative for this service which is Laroch Data Management (a trading name of Fidushield Group Ltd) and you may contact them by mailing your request to Laroch Data Management, Technology House, 9 Newton Place, Glasgow, G3 7PR

19.4 Swiss Federal Act on Data Protection (FADP) Representative

Residents of Switzerland may be entitled to exercise your rights under the Swiss Federal Act on Data Protection (FADP). These are broadly the same rights as listed throughout this Privacy Policy, although your supervisory authority is the Federal Data Protection and Information Commissioner (FDPIC). We have appointed DataRep as our Data Protection Representative in Switzerland so that you can contact them directly regarding rights or questions you have relating to the Swiss FADP. If you want to raise a question to us or exercise your rights under the Swiss FADP, you may do so by: (i) Sending an email to DataRep at DataRequest@datarep.com or (ii) Mailing your inquiry to: DataRep, Leutschenbachstrasse 95, ZURICH, 8050, Switzerland. Please ensure your request is addressed to DataRep, and any cover letter quotes JSE Global Solutions LLC as the reference. Any mail addressed directly to JSE Global Solutions LLC, sent to this Swiss address, will not be received. For information on how our Swiss representative handles your information, please visit www.datarep.uk/privacy-policy

20. Complaints

We hope that we will be able to directly resolve any complaint that you may have, however, if you are not happy with how we handle any complaint, depending on your place of residence, you may be able to raise a complaint at any time to your country’s national data protection authority in accordance with Data Laws applicable to your country of residence.

Valikko