GENERAL: We are Edvo Inc., and we consider the privacy of users of our Services, and the security of their personal information, to be a matter of importance.
When we use the terms “we”, “us”, “our” or “Edvo”, we refer to Edvo Inc., and when we use the terms “you”, “your” or “yours” we refer to you, a user of the Services.
TYPES OF INFORMATION WE COLLECT: What we collect depends largely on the interaction that takes place between you and the Services. When you use or interact with the Services, we store all the content you provide, whether directly or indirectly by allowing us to access information you provided Third-Party Providers. Such information may include, without limitation, your curriculum vitae and all information included therein, files, pictures, answers to our questions, and any other information that you provide the Services. This information generally divided to personally identifiable information (“PII”) and information cannot generally be used, by itself, to identify you (“Non-PII”).
PII: PII includes all information included in your curriculum vitae, transcript of your interaction with the Services (i.e. actual conversations with us and with our chat-bots), or in the files you transmit to us, address, name, telephone number, geographic location, publicly available social media profile information, e-mail, IT information (IP addresses, usage data, cookies data and browser data) and other electronic data you submit through the Services, voluntarily or when you interact with the Services.
SPECIFIC CLARIFICATION REGARDING FINANCIAL INFORMATION: PII is also collected when you purchase any paid Services. In such events, we will also collect, for example, PII required to process any payment request or to secure your payment. In this regard, we may retain the last four digits of your credit card to allow you to identify the card used for future purchases. We use a third-party service provider to process your credit card transactions. These third parties’ services are governed by their own Third-Party Policies.
Notwithstanding, Edvo does not store complete financial information. If you have purchased any Services, your payments were processed by Stripe in accordance with its Third-Party Policies.
You can request that your financial information be removed from Stripe by contacting us by email: firstname.lastname@example.org. However, removal of your financial information from Stripe will result in the termination of any active Services that require payment, without releasing you from any obligation towards us, including and without limitation, those set forth under the Edvo Fees; Payment Section under the Terms and Conditions.
NON-PII: Non-PII include, without limitation, date of birth, gender, results of tests you undergo using the Services, answers to non-identifiable questions, etc.
INFORMATION WE SHARE WITH EMPLOYERS: Notwithstanding the different nature of the PII and Non-PII, due to the nature and purpose of the Service, PII and Non-PII are stored and transmitted to Employers on an aggregated basis, and except where explicitly stated herein, you should consider all of the information we collect as PII which includes private, public and identifiable information of you (collectively, “Shared Information”). By applying for an open position with any Employer you instruct us to take a specific action with respect to your Shared Information, including to share all or portion (as we determine) of your Shared Information with such potential Employer. We may aggregate the Shared Information into reports, as we deem to be applicable or appropriate, and share such reports with the Employer.
HOW YOUR SHARED INFORMATION IS TRANSMITTED TO EMPLOYERS, AND WHERE WILL BE STORED BY THE EMPLOYER: We may share the Shared Information with Employers via email, by allowing Employers to access any designated web-portal we may operate, but mainly, by uploading Shared Information to designated accounts on the Employer’s applicant tracking systems (“ATS”). The ATS is usually a separate service, operated by a Third-Party Provider retained or otherwise owned by the Employer. Accordingly, by applying to any open position, you explicitly permit and authorize us to upload your Shared Information to the Employer’s ATS, and you confirm your understanding that your Shared Information may become subject to ATS’ Third Party-Policies. When the Shared Information is being so provided to the Employer, Edvo no longer has exclusive control over such Shared Information, and any action you wish to take with respect to such Shared Information, is subject to the Employer’s discretion and/or to the relevant ATS’ Third Party-Policies. You shall have no claims and/or demands towards Edvo with respect to the foregoing.
LOG DATA, COOKIES AND WEB BEACONS: Our servers may automatically record certain information about how you use the Services (we refer to this information as “Log Data”). Log Data is not Shared Information, but it may include PII and non-PII such as a user’s Internet Protocol (IP) address, device and browser type, operating system, the pages or features of our Services to which you browsed and the time spent on specific sections of our Services, the frequency with which the Services are used by a you, search terms, and other statistics. We use this information to administer the Services and we analyze (and may engage third parties to analyze) this information to improve and enhance the Service by expanding its features and functionality and tailoring it to our users’ needs and preferences. For removal of doubt, Log Data does not include transcripts of your interactions with the Services, which is considered Shared Information.
SENSITIVE INFORMATION: Subject to the following paragraph, we ask that you not send or disclose to us any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or union membership) on or through the Service or otherwise.
PURPOSE OF DATA COLLECTION AND HOW DATA IS USED: All the information we collect is being collected and used in order to provide the Services, including: (i) to operate, maintain, administer and improve the Services; (ii) to manage and communicate with you regarding the Services, including by sending you announcements related to the Services, such as technical notices, updates, security alerts, and support and administrative messages; (iii) to process payments you make through the Services or via third-party vendors; (iv) to better understand your needs and interests, and personalize your experience with the Services; (v) to send you information about product by email; (vi) to respond to your Service-related requests, questions and feedback; (vii) as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (viii) enforce the Terms and Conditions; (ix) protect our rights, privacy, safety or property, and/or that of you or others; and (x) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
Additionally, we use Shared Information to: (i) locate and propose to you open positions with Employers; (ii) provide information about you to Employers, if you have applied to any position with such Employers; and (iii) prepare and furnish to Employers comparative and non-comparative, PII and Non-PII information and reports regarding candidates who used the Services to apply or throughout the process of applying (including by taking any exams) for any open position.
We may create anonymous data from your Shared Information and other individuals whose Shared Information we collect. We make personal Shared Information anonymous by excluding information that makes the data PII, and use that anonymous data for our lawful business purposes (including for analytics purposes). In such events the provisions herein which relates to Shared Information shall not apply with respect to such data.
YOUR DATA PROTECTION RIGHTS AND CHOICES: If you wish to access your personal information that Edvo collects, you can do so at any time by contacting us using the contact details provided under “How to Contact Us” heading below.
If you are a resident of the European Economic Area (“EEA”), you can object to processing of your PII, ask us to restrict processing of your personal information or request portability of your PII where it is technically possible. You can exercise these rights by contacting us using the contact details below. Further, if you are a resident of the EEA, if we have collected and processed your PII with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your PII conducted in reliance on lawful processing grounds other than consent.
You have the right to complain to a data protection authority about our collection and use of your PII. Contact details for data protection authorities in the EEA, Switzerland and certain non-European countries (including the U.S. and Canada) are available here.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
RETENTION OF PII: We will retain PII we process for as long as needed to provide our Services or for an indefinite time to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our agreements. If required by law, we will delete PII by erasing it from our database.
We may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (i) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (ii) enforce the Terms and Conditions; (iii) protect our rights, privacy, safety or property, and/or that of you or others; and (iv) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
SECURITY: We take reasonable and appropriate measures to protect PII from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the PII. While Third-Party Providers used by us in connection with the Services declare they take similar measures, we can cannot guarantee, provide any warranty or otherwise be held liable for any failure or breach thereof. If a security breach causes an unauthorized intrusion into our Services that materially affects you or your PII, then we will make commercially reasonable efforts to notify you via email as soon as possible and later report the action we took in response.
LEGAL BASIS FOR PROCESSING YOUR EEA PII: If you are located in the EEA, our legal basis for collecting and using your PII as described above will depend on the PII concerned and the specific context in which we collect it. We will normally collect PII from you only where we have your consent to do so, where we need the PII to perform an agreement with you, or where the processing is in our legitimate business interests. In some cases, we may also have a legal obligation to collect PII from you.
If we ask you to provide PII to comply with a legal requirement or to enter into a contract with you, we will make this clear at the relevant time and advise you whether the provision of your PII is mandatory or not (as well as of the possible consequences if you do not provide your PII). Similarly, if we collect and use your PII in reliance on our legitimate business interests, we will make clear to you at the relevant time what those legitimate business interests are. However, due to the nature of the Services we furnish, you should be advised that collecting PII and, if you applied to any specific position, sharing PII with Employers, is required.
If you have questions about or need further information concerning the legal basis on which we collect and use your PII, please contact us using the contact details provided under the “How To Contact Us” heading below.
Last Updated: February 27, 2019