Last updated: May, 2018

1. Introduction

This Privacy Policy (“Privacy Policy”) applies when Happo Group AB, registration number 559042-7356, address Drottninggatan 23, 582 25 Linköping, Sweden, ("Happo") supplies an applicant tracking system via web or application that may be used for recruitment and candidate presentations (the “Service”). Happo is data controller for the processing of personal data described in this Privacy Policy.

2. Processed data

Happo collects and processes personal data about you when you create an account and use the Service, and through its own or third-parties’ cookies and other tracking technologies, as set out in this section. Happo is responsible for the processing of your personal data for the purpose of providing you with access, use, and support of the Service. The legal ground for the processing of your personal data for these purposes is to fulfil the agreement with you, according to the Terms of Service

2.1. Information Collected when Creating a User Account

We collect and use the following personal data from users when they create a user account for the Service: name, e-mail address, the name of the company, profile picture, and applicable team setup information. When a user creates a team, we collect an e-mail address, a team name, username, and password. 

For users that subscribe to the Business version of the Services, our corporate affiliates and our third-party payment processors may collect and store billing address and credit card information on our behalf, or we may do this ourselves. The privacy policy of that third-party service provider applies for the commercial transaction, the privacy policy of that third-party

2.2. Information Collected from Applicants 

Information from applicants is uploaded to the Service by the applicant himself or herself when applying for a position. Example of applicant information may be candidate name and contact information, profile picture, resume, cover letter, depending on what the hiring company asks for. 

Happo is a subcontractor to the user of the Service in recruiting purposes – whether that user is an employer, recruiter, organization or an individual. In such case that user determines the purpose and methods of processing the candidate personal data and is the data controller. Hence, such user determines its own policies regarding storage, access, modification, deletion, sharing and retention which may apply to your use of the Services. The user can attach their own company privacy policy when creating a position in Happo, for candidates to read. If not, please check with that user about the policies and settings it has in place.

Your personal data is retained only as long as there is a need to preserve it to fulfill the purposes for which the data was collected. Happo may save the data for longer if it is necessary to comply with legal requirements or to monitor Happo’s legal interests, e.g. if there is a legal dispute.

2.3. Information Collected from Your Usage of the Service

When using the Service, certain information attributable to the user about the Customers’ and Applicants’ usage of the Service may be collected automatically, including technical data such as the URL accessing the website, IP address, network, computer performance, web browser type, language settings, operating system.

We may also collect services usage information. i.e., information about how you are accessing and using the Services, which may include administrative and support communications with us and information about the teams, features and content (if any). 

We may also collect log data. I.e., when using the Services our servers automatically record information, including information that the browser sends whenever visiting a website or the mobile app sends when using it. This log data may include Internet Protocol address, the address of the web page visited prior to using the Services, browser type, and settings, the date and time of usage of the Services, information about browser configuration and plug-ins, language preferences, and cookie data.

We may collect information about the device that is running the Services, including what type of device it is, the operating system, device settings, application IDs, unique device identifiers, and crash data. Whether we collect some or all this information often depends on what type of device it is and its settings.

2.4. Cookies

You can read more about how we use cookies on our Cookie Policy.

3. Why we process information about you

3.1. To Provide, Understand and Improve our Services 

We carry out research and analyze trends to better understand how users are using the Service and improve it. In some cases, we may publicly display information that is not personally identifying in the aggregate, (e.g., by publishing a report on trends in the usage of our Services) or may provide the aggregate data to third parties (more information below). We also process information in order to develop and customize the Service and its functionalities to the needs of that specific user and to evaluate, analyze and grade certain types of user content.

3.2. To Communicate with You

Responding to requests. If contacted with a problem or question, we will use personal information to respond. Sending messages through the app. We may send service and administrative emails and messages. We may also use personal data for changes in our Services, our service offerings, and important Services related notices, such as security and fraud notices. These emails and messages are considered part of the Services and are not possible to opt-out. In addition, we sometimes send e-mails about new product features or other news about Happo. These are possible to opt-out of at any time.

3.3. Administration, Technical issues, and Safety

Billing and account management. We use account data to administer accounts and keep track of billing and payments. Investigation and safety. We require personal data to keep the Services secure and to prevent abuse and fraud. Technical issues. We need personal data in order to amend technical issues at a Customer’s request in connection with customer support matters, as set forth in our agreement with the Customer or as expressly permitted in writing by the Customer.

3.4. Marketing

We may also use personal data for our own marketing or advertising purposes. You have the possibility to opt-out at any time. For example, personal data may be used for market and customer analysis, market research, statistics, business monitoring and business and method development. We further process personal data for direct marketing purposes, so that Happo is able to send information about e.g. new services provided by Happo or its affiliates to your e-mail. In this case, the legal ground for the processing is Happo’s legitimate interest to market our product.

4. Sharing and disclosure

4.1. With your Consent

We may share your information at your direction or as described at the time of sharing, such as when you authorize a third-party application or website to access your account.

4.2. Sharing between Applicants and Customers

Happo may disclose or share information about the Applicant to the hiring customer for their recruiting purposes. There may be times when an applicant contacts Happo to help resolve an issue related to the process of which the applicant applies for in order to help resolve the issue and given our relationship with the Customer, we may share the user’s concern with our Customer.

4.3. Service Providers

We use a variety of third-party service providers to help us provide services related to the Service. Service providers may be located inside or outside of the European Economic Area (“EEA”). For example, service providers may help us: (i) verify or authenticate your identification, (ii) provide integrations to other services, (iii) check information against public databases, (iv) assist us with background checks, fraud prevention, and risk assessment, or (v) provide customer service, advertising, or payments services. These providers have limited access to your information to perform these tasks on our behalf and are contractually obligated to use it consistent with this Privacy Policy.

You can unsubscribe or opt-out from receiving such marketing communications by sending an email to support@happo.com.

4.4. Affiliates

Happo may receive information from affiliates in our corporate group, our partners, or others that we use to make our own information better or more useful. This might be aggregate level information, such as which IP addresses go with which zip codes, or it might be more specific information, such as about how well an online marketing or email campaign performed. 

4.5. Safety and Compliance with Law

Happo may under certain conditions disclose your information to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required to do so by law or if such disclosure is reasonably necessary: (i) to comply with legal process and to respond to claims asserted against Happo, (ii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iii) to enforce and administer our Terms of Service or other agreements with users, (iv) for fraud investigation and prevention, risk assessment, customer support, product development and debugging purposes, or (v) to protect the rights, property or personal safety of Happo, its employees, its users, or members of the public.

4.6. Business Transfers

If Happo undertakes or is involved in any merger, acquisition, reorganization, a sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information. In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

4.7. Aggregated Data

We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and non-personally identifiable information for industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

5. Third party partners & integrations

The Services may contain links to third party websites or services, such as third-party integrations, co-branded services, or third party-branded services (“Third-Party Partners”). Happo doesn’t own or control these Third-Party Partners and when you interact with them, you may be providing information directly to the Third-Party Partner, Happo, or both. These Third-Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.

6. Data processors

Happo can use a subcontractor in order to, on our behalf, perform the tasks in accordance with the above mentioned, e.g. IT suppliers, server suppliers, suppliers of digital data, analyzing tools (“Data Processors”). Such Data Processors will have the same obligations regarding the processing of personal data as Happo has towards you. Happo may share and disclose personal data to Data Processors that process personal data on behalf of Happo, for the above-stated purposes. 

Personal data may also be disclosed if it is necessary in order to comply with applicable legal requirements or requirements from authorities, to preserve our legal interests or to detect, prevent, or pay attention to fraud and other security or technical issues.

7. Security 

We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. However, the Internet is not a completely secure environment so we cannot guarantee the security of the transmission or storage of your information.

8. Your rights and choices

8.1. Rights

Applicable privacy regulations provide you with a number of rights when your personal data is processed. Below you will find a short description of those rights. What rights you have may vary, depending upon the purposes for which we are processing your data.

Right to withdraw consent - When our right to process your personal data is based on your consent, you always have the right to withdraw your consent. The easiest way for you to do this is by contacting support@happo.com.

Right to access – If Happo is processing your personal data, you have the right to request a confirmation of this fact and to receive information about the processing. You also have the right to ask for a copy of the personal data we process about you without cost.

Right to rectification – In some cases, you have the right to ask Happo to rectify your data that you consider to be incorrect or incomplete. Nonetheless, you always have the possibility to change information that you have added to your candidate profile.

Right to object – In some cases, you have the right to object to Happo’s processing of your personal data, such as when it concerns direct marketing. In all cases where we process your personal data based on our legitimate interest, you have the possibility to object to the processing. If you should so object, we will stop processing your personal data.

Right to restriction – In some cases, you have the right to ask that Happo restrict the processing of your personal data, for example, in cases where you contest that the data we process about you is correct. You can in such cases ask us to restrict the processing of your personal data during the time it takes for us to verify the correctness of your data. In those cases, we are only allowed to process your data with your approval, with the exception of Happo determining, claiming or defending legal claims in order to protect someone else’s right or to protect an important public interest.

Right to erasure – In some cases, you have the right to ask Happo to delete your personal data. This right is applicable in the following cases:

  • If the data is no longer necessary for the purposes it was collected for.
  • If you withdraw your consent and we do not need to keep your data for other purposes, such as due to legal obligations.
  • If you object to processing based on legitimate interest and your reason for objection weighs heavier than our interest.
  • If you object to our processing of your data for direct marketing purposes and we do not need to process your data for other purposes.
  • If your personal data is processed in an illegal manner.
  • If your personal data must be deleted due to legal obligations.

Please note that there might be an obligation for us to save your personal data anyway, for example due to an agreement with you or due to legal obligations. In those cases, we will only process your personal data for this purpose.

Right to data portability – In cases where we process your personal data with your consent, or to fulfil and agreement with you, you have the right to receive your personal data that you have provided us with in a structured format.

If you would like to exercise your rights, you are always welcome to contact us via the contact information found below. If you are not pleased with how Happo processes your personal data, you always have the right to file a complaint with the supervisory authority, in Sweden it is the Swedish Data Protection Authority (Datainspektionen, that will change its name to Integritetsskyddsmyndigheten during year 2018).

8.2. Access and Update

You may review or update the information in your Happo account by logging into your Happo account and reviewing your account settings and profile. 

8.3. Account Cancellation

To delete your account, go to Settings/Delete My Account. 

9. Operating globally

As described in this Privacy Policy, we may sometimes share your information with third parties. When you use the Services, you authorize us to transfer, store and process your information in the United States and possibly other countries. Laws in these countries may differ from the laws applicable to the place where you live. For example, information collected within the EEA may be transferred, stored, and processed outside of the EEA for the purposes described in this Privacy Policy. 

10. Changes to the Privacy Policy

Happo is entitled to change this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will notify users by publication on our website, https://app.happo.com, and update the “Last Updated” date at the top of this Privacy Policy. We will also provide you with notice of any material modifications by e-mail at least thirty (30) days before the date they become effective, and, where required under applicable law, ask for consent. 

If you disagree with the revised Privacy Policy, you may cancel your account. If you have not cancelled your account before the date of the revised Privacy Policy becomes effective, your continued access or use of the Services will constitute acceptance of the revised Privacy Policy.

11. Contact

If you have any questions or complaints about this Privacy Policy or Happo’s information handling practices, you may contact us at:

Happo Group AB, Drottninggatan 23, 582 25 Linköping, Sweden. 

You may also e-mail us at support@happo.com. 

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