PRIVACY

CANDIDATE PRIVACY POLICY

This policy was last updated 23 December 2020.

Elbo Limited (“Elbo”, “we”, “us”, “our”) is committed to protecting your privacy. This Privacy Policy explains the way in which we collect, manage, use and protect any Personal Data we obtain through your engagement with us, as well as your legal rights in respect of your data. By “Personal Data” we mean any information, alone or jointly with other similar information, that could be used to identify you.

This Policy covers any Personal Data we collect in connection with your use of the Elbo app (the “App”), where you can learn more and request for information about the App, sign up as a candidate, access your candidate profile and use Elbo to source jobs and any other consumer services we offer you (together, the “Elbo Services”).

You can navigate to the relevant sections of the policy by clicking the links below:

• About us
• What data do we collect about you?
• How do we use your Personal Data and on what grounds?
• Marketing Communications
• Who do we share your Personal Data with?
• Will my Personal Data be sent abroad?
• Your rights over your Personal Data
• How long do you keep my Personal Data?
• How do you keep my Personal Data secure?
• Third Party Websites
• Children
• Changes to this Privacy Policy
• Contact us

By using our App or engaging with the Elbo Services, you consent to the policies and practices described in this Privacy Policy and in any other agreement that we might have with you, including but not limited to the Candidate Terms & Conditions (as may be amended from time to time).

ABOUT US

For the purposes of applicable data protection laws, Elbo Limited, a company incorporated in England and Wales with its registered address at 82 Wandsworth Bridge Road, London SW6 2TF is the controller of your data. This means that we are the primary entity who decides the purposes and means for dealing with your personal data.

WHAT DATA DO WE COLLECT ABOUT YOU?

When you access the App or receive the Elbo Services, we may collect a variety of Personal Data about you, including:

Personal Data that you provide to us directly
Elbo primarily collects Personal Data provided by you directly when you receive or request the Elbo Services. For example, this includes:

• Name
• Email address
• Phone number
• Skype usernames and contact details for any other communication platforms you provide us for prospective employers or clients to contact you and conduct interviews
• Location (to denote suitable job locations)
• Bank details and any other commercial details regarding your self-employment or limited company you submit to us (e.g. VAT registration number, certificate of incorporation, business bank details, business address)
• · Home address and any other personal information contained in your proof of address verification documents (e.g. customer account number)
• Any personal information you submit or upload to your profile regarding your work history, experience and qualifications, e.g. affiliated employers, job titles, languages spoken, personality test results
• Photographs and other personal information contained within the copies of your passport, ID card or driving licence you submit to us for identity verification purposes (e.g. passport number).
• Any other information that you voluntarily submit to us when you engage the Elbo Services, e.g. register for an account, submit an employer’s reference / testimonial, fill out your candidate profile (including your video vitae), complete any feedback forms, schedule an interview with a prospective employer or client or raise an enquiry/correspond with us through phone, email, Skype or the App.

If you are a prospective client or employer signing up to Elbo to find new applicants for job openings, please see our separate Elbo Client Website Privacy Policy for details of how we manage your personal data.

We will let you know at the point of collecting your information whether this is optional, or whether it is necessary for you to provide this information to meet certain statutory or contractual requirements. If the latter and you do not wish to provide us with this information, this may limit the services we are able to provide to you.

Personal Data received from other sources
We may also receive information about you from:

• Our third party service providers providing the Elbo Services on our behalf (see “Who do we share your personal data with?” below)
• Any contacts that provide your details to us as part of our referral scheme
• Any contacts providing references about you at your request
• Any clients who contact or engage you for a job via Elbo, when completing any interview/hire feedback forms requested from us
• Publicly available resources (e.g. Linkedin, Facebook, your company website)
• Automatically collected technical information regarding your visits to the App including, but not limited to, IP addresses, traffic data, location data, weblogs and other communication data. For further details, please see our Cookie Policy.

HOW DO WE USE YOUR PERSONAL DATA AND ON WHAT GROUNDS?

We will only use your personal data if we have a permitted lawful basis to do so. The primary purpose for which we collect information about you is to provide candidates or potential candidates with the Elbo Services. We also collect information about you for the following purposes:

To perform our contract with you (i.e. to provide you with your requested Elbo Services)

• To create, manage and save your progress in creating your candidate profile, and enable your use of the Elbo Services by using the data to match you up with suitable job listings
• To provide you with information, products or services that you request from us
• For handling contacts, queries, complaints or disputes
• To enable potential employers to contact you regarding a prospective job for you (e.g. to schedule interviews and make job offers).

For our legitimate interests

• For market research and analytical purposes, e.g. to improve our understanding of candidate match-up and hiring trends and profiles. Where we do this for Elbo’s own business, this will be for our own legitimate interests. Where we provide this for our clients, e.g. or in order to provide our clients of consultancy services with analytical insights, we will only do so on an anonymized, aggregated basis (see “Aggregated analytical data” below)
• To ensure network and information security in the Elbo Services and your Personal Data
• For improving existing services and developing new products and services
• Protecting Elbo and our customers by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to us
• To effectively handle any legal claims or regulatory enforcement actions taken against Elbo
• To generally run the App and for internal operations, in order to provide you with an up to date, efficient and reliable service
• Making important communications about your candidate profile and Elbo Services (e.g. interview reminders, hiring process updates)

To comply with our legal obligations

• To comply with our legal and regulatory obligations (including under applicable data protection laws)
• For preventing, investigating and detecting crime, fraud or anti-social behavior and prosecuting offenders, including working with law enforcement agencies
• To fulfil our duties to our employees and other

With your consent

• For keeping you informed of Elbo promotions and offers (see “Marketing communications” below)
• Using your images or profiles in Elbo’s promotional materials and press releases (e.g. client testimonials).

Where we rely on consent to process your Personal Data, you have the right to withdraw your consent to these activities at any time, which will mean (unless another lawful basis applies to your data) that we will cease to process the affected data after consent is withdrawn. However, please note this may result in us being unable to provide you with certain features of the Elbo Services.

AGGREGATED ANALYTICAL DATA

From time to time Elbo may use your Personal Data to provide our clients of consultancy services with market insights into employment/job trends, details of skill shortages in different locations and other analytical data regarding job markets and roles. Where we analyse and share candidate data with our clients for this purpose this will strictly be on an anonymized, aggregated basis, meaning your Personal Data will be pooled to provide general group data only and no personal identifiers about you or other candidates will be disclosed.

MARKETING COMMUNICATIONS

If you have opted-in to receive update emails about Elbo, we will also use your Personal Data to keep you updated about the latest Elbo offers and promotions through marketing communications. This includes sharing your contact details with our third party marketing provider Rocaba Media Limited, who sends and manages Elbo marketing communications on our behalf.

This means we may use your contact information to contact you by email with announcements and newsletters regarding information that we think may be of interest to you.

We will only make, or pass on your contact details for the purpose of marketing communications if you have given us your consent to do so.

You have the right to withdraw your consent to these activities at any time, which will mean (unless we have another lawful basis to continue using your data) that we will cease to use your Personal Data for these marketing purposes. If you wish to stop receiving marketing emails from Elbo, you can do so by clicking the “unsubscribe” link at the bottom of each marketing email from us.

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

We may disclose the Personal Data that we collect with the following third parties:

• Potential employers or clients signed up with Elbo, whose job listings match your profile, who interview or engage you for a job or who receive consultancy services from us for aggregated Personal Data only (see “Aggregated analytical data” above)
• Our third party providers of our business and operational services. These parties are authorized to process your Personal Data on our behalf and pursuant to our instructions, and only as necessary to provide the Elbo Services. These include our providers of:
  • Payment processing and accounting services, as necessary to process payment
  • Back office processing and recruitment/HR admin services
  • Marketing services, including Rocaba Media Limited
  • Product design and development services
  • Technology platform hosting and support services

• Any potential or actual third party buyer of our business and/or assets in the event that we sell, trade or licence ownership of any part of the Elbo business or assets (including management of the Apps)
• Third parties we may be required to disclose such personal data to in order to comply with our legal obligations, to enforce our legal rights or to protect our members, g. any relevant authority or enforcement body and fraud protection and credit risk reduction agencies or emergency services.

WILL MY PERSONAL DATA BE SENT ABROAD?

The majority of our service providers required to process your Personal Data are based in the UK and will be processing your Personal Data subject to the same data protection laws as us. Some of our development and technical support providers are located in India, but they will have no access to our live system database and do not process any Personal Data on our behalf.

Where we do need to transfer your Personal Data in the future to any countries outside the EU, we ensure that such transfers are made subject to appropriate safeguards as required by applicable data protection laws to ensure that a similar degree of protection is afforded to your Personal Data, including by ensuring that overseas recipients of your data have been self-certified under the Privacy Shield framework, are located in a country deemed to hold adequacy status or through the use of EU Commission approved standard contractual clauses.

For more details on the safeguards in place for transfers of your Personal Data abroad, including how to obtain copies of these where relevant, please Contact Us using the details below.

YOUR RIGHTS OVER YOUR PERSONAL DATA

You can exercise all the rights applicable to you by contacting us (see details in the “Contact Us” section below) or submitting an enquiry through the “Contact Elbo” form in your client account.

You may, in circumstances, have the following rights in relation to the Personal Data we hold about you.

You can request to:

• access a copy of the information held about you
• rectify any incorrect or incomplete data we hold about you. It is both in our interest and yours that any personal information we hold about you is accurate, complete and current. If the data we hold about you is inaccurate in any way, please contact us to have your personal information corrected. You can also update any incorrect contact information yourself by updating your profile information or submitting an enquiry through the “Contact Elbo” form in your client
• delete, restrict or remove the data we hold about you. You can request to temporarily suspend your account or delete it and all Personal Data about
• transfer the data we hold about you to another party
• object to any further processing of your data, if we are processing your Personal Data on the basis of our legitimate interests (see “How do we use your personal data and for what grounds” above), or for direct marketing

We will endeavor to respond to your requests within one month and free of charge. Please note that in respect of all these rights, we reserve the right to:

• refuse your request based on the exemptions set out in the applicable data protection laws.
• request for proof of your ID to process the request or request further information
• charge you a reasonable administrative fee for any repetitive, manifestly unfounded or excessive

If we refuse your request to exercise these rights, we will give reasons for our refusal and allow you to challenge our decision. If we have shared your data with others, we will tell them about your request to rectify, erase, restrict or object to the processing where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.

If you have any concerns about how we handle your data, please contact us. If you are not satisfied after we’ve tried to resolve your issue, you’ll be entitled to lodge a complaint with our data protection regulator, the Information Commissioner’s Office.

HOW LONG DO YOU KEEP MY DATA?

We keep your data for as long as it’s necessary to meet the relevant purposes for which we’ve collected your data, including for the purpose of satisfying any legal, accounting or reporting requirements.

To determine the appropriate length of time for holding your data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm, from unauthorized use or disclosure of your personal data, the purpose for which we process your data and whether we can achieve those purposes through other means, along with the applicable legal requirements.

HOW DO YOU KEEP MY PERSONAL DATA SECURE?

We are committed to taking reasonable efforts to secure the information that you choose to provide us, and we use a variety of security procedures to help protect against unauthorized access to or alteration, disclosure, or destruction of Personal Data. We restrict access to Personal Data to our employees, contractors and service providers (described in “Who we share your data with” above) who need to know the information to operate, develop, or improve the Elbo Services.

Unfortunately, no transmission of Personal Data over the Internet can be guaranteed to be 100% secure. Accordingly, and despite our efforts, Elbo cannot guarantee or warrant the security of any information you transmit to us, or to or from our online services. Elbo has no responsibility or liability for the security of information transmitted via the Internet. If you have questions about this Privacy Policy or the security of your Personal Data, please contact us as indicated under the “Contact Us” section below.

THIRD PARTY LINKS

This Privacy Policy only addresses Elbo’s use and disclosure of your Personal Data. The App may contain links to other websites and apps, including those of our business partners, suppliers, social media pages and affiliates. If you follow a link to any of these sites, please note that sites have their own privacy policies and we are not responsible for these policies or for their misuse of any Personal Data. We encourage you to carefully read the privacy policy of any external links before you submit any personal information through them.

In particular, all jobs featured on the Jobs Feed tab are supplied by a number of online sites including but not limited to Linkedin, Indeed and Workinstartups, and the handling of all job applications, correspondence regarding the job or any other matters relating to the listing will be managed by the listed prospective job provider. Elbo does not process any personal data on behalf of any online sites or the employer or the intermediary listed on any job on the Jobs Feed tab.

CHILDREN

The Elbo Services are not intended for use by or targeted at children under 13, and we do not knowingly or intentionally collect information about children under 13. Children under 13 should not use the App.

CHANGES TO THIS PRIVACY POLICY

As Elbo and the Elbo Services change from time to time, we may need to update this Privacy Policy to reflect changes to our information practices, technology and legal requirements. We will post any changes to this Privacy Policy on the App from time to time and, where appropriate, notify you by e-mail. Please periodically review this Privacy Policy before using the Elbo Services as continued use of the Elbo Services shall indicate your acceptance of any changes. All personal information held by us will be governed by the most recent Privacy Policy posted on the App.

CONTACT US

If you have any questions about this Privacy Policy or our treatment of the information you provide us, please contact as at:

Address: Elbo Limited, 82 Wandsworth Bridge Road, London SW6 2TF
Email: info@elbo.io