Privacy policy

Effective as of October, 1st , 2019

EFA JOBS´s mission is to connect the world’s creative professionals with business partners and employers to allow them to be more productive and successful.  
The EFA JOBS website and services including (without limitation) www.efajobs.eu (the “Website”) and other all websites, mobile applications and other interactive properties through which the service is delivered (collectively, the “Services”) are owned, operated and distributed by E-F-A Associates s.r.o., with its registered office in Opletalova 1013/59, Prague 1, 110 00, Czech Republic, registered in the Commercial Register at City Court in Prague, Section C, under the reference number 312514 („EFA“ ).
We are a social network and online platform for creative professionals and companies who offers open jobs positions. People use our Services to find and be found for business opportunities and to connect with others and information. Our Privacy Policy applies to any Member or Visitor to our Services.
Our registered users (“Members”) share their professional identities, engage with their network, exchange knowledge and professional insights, post and view relevant content, learn and find business and career opportunities. Content and data on some of our Services is viewable to non-members (“Visitors”).

Services
This Privacy Policy applies to your use of our Services. This Privacy Policy applies to efajobs.eu, eu-fa.eu, EFA branded apps, and other EFA-related sites, apps, communications and services (“Services”), but excluding services that state that they are offered under a different privacy policy.
By accessing any part of the Services, you are agreeing to the terms and conditions described below (this “Privacy Policy”) and the terms and conditions of our terms of service (the “Terms of Service”). If you do not agree to any of these terms, you should not use the Services. This Privacy Policy applies to all users, including both users who are simply viewing content available via the Services and users who have registered as members of EFA JOBS.
General„Personal data“ are defined in the current 1995 Directive and in the GDPR as all information relating to an identified or identifiable natural person and „processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. EFA will be the controller of your Personal Data processed in connection with the Services.

1. What Personal Data Do We Collect From You? We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services.
1.1. Data You Provide To Us
Registration – to become a Member of the Creative CommunityTo create an account you need to provide data including your name, email address and/or mobile number, and a password. If you register for a premium Service, you will need to provide payment (e.g., payment card) and billing information.
You create your EFA JOBS profile (a complete profile helps you get the most from our Services).
ProfileYou have choices about the information on your profile, such as your education, work experience, skills, photo, gallery, city or area and endorsements.  You don’t have to provide additional information on your profile; however, profile information helps you to get more from our Services, including helping recruiters and business opportunities find you. It’s your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add personal data to your profile that you would not want to be publicly available. You give other data to us, such as by syncing your address book or calendar.
Information we collect directly from you
We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation the following:First and last nameEmail addressDate of birthGenderBiographical informationLocation information (limited to city, state, zip code, country, and time zone)Employment historyLinks to your social media accountsAny other information you choose to share publicly on the Services, for example, anything you post to a public part of your Profile on the Services

Posting and Uploading
We collect personal data from you when you provide, post or upload it to our Services, such as when you fill out a form, (e.g., with demographic data or salary), respond to a survey, or submit a resume. If you opt to import your address book, we receive your contacts (including contact information your service provider(s) or app automatically added to your address book when you communicated with addresses or numbers not already in your list).If you sync your contacts or calendars with our Services, we will collect your address book and calendar meeting information to keep growing your network by suggesting connections for you and others, and by providing information about them, e.g. times, places, attendees and contacts.You don’t have to post or upload personal data; though if you don’t, it may limit your ability to grow and engage with your network over our Services.
1.2. Data From Others
Others may post or write about you.
Content and News
You and others may post content that includes information about you (as part of articles, posts, comments, videos) on our Services. Unless you opt-out, we collect public information about you, such as professional-related news and accomplishments (e.g., patents granted, professional recognition, conference speakers, projects, etc.) and make it available as part of our Services (e.g. suggestions for your profile, or notifications of mentions in the news).Others may sync their contacts or calendar with our Services.
Contact and Calendar Information
We receive personal data (including contact information) about you when others import or sync their contacts or calendar with our Services, associate their contacts with Member profiles, or send messages using our Services (including invites or connection requests). If you or others opt-in to sync email accounts with our Services, we will also collect “email header” information that we can associate with Member profiles.
Partners
We receive personal data about you when you use the services of our customers and partners, such as employers, prospective employers and applicant tracking systems providing us job application data.Some third parties such as our business partners and service providers provide us with Personal Data about you, such as the following:
Account information for third party services: If you interact with a third party service when using our Services, such as if you use a third party service to log-in to our Services (e.g., Facebook Connect), or if you share content from our Services through a third party social media service, the third party service will send us information about you, such as information from your public profile, if the third party service and your account settings allow such sharing. The information we receive will depend on the policies and your account settings with the third party service.
Information from our advertising partners: We receive information about you from some of our service providers who assist us with marketing or promotional services related to how you interact with our websites, applications, products, services, advertisements or communications.
Information from third party service providers: Some of our third party service providers (such as Jobs.cz, Indeed) collect Personal Data about our employees and job candidates and share that information with us.1.3. Service UseWe process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.
First and last name
Email address
Location information
IP address
Your activity on the Services, including class usage information and community interaction data
Examples of these legitimate interests include:
Operation and improvement of our business,
products and services
Personalization of web content on the Service
Analyzing the use of the Services
Marketing of our products and services
Provision of customer support
Protection from fraud or security threats
Compliance with legal obligations
Completion of corporate transactions
Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.


2. How Do We Use Your Personal Data?
2.1. Personal Data use
We process Personal Data to operate, improve, understand and personalize our Services. For example, we use Personal Data to:
Create and manage user accounts and profiles
Personalize content on the Services. This includes showing users their saved events, open positions, internships etc.  and providing open jobs recommendations.
Provide users  with community features
Provide Employers and Business Partners with recommended candidates´ list  Communicate with you about the ServicesContact you with announcements, updates or offers regarding the ServicesProcess ordersProvide support and assistance for the ServicesAnalyze and improve the ServicesMeet contract or legal obligationsRespond and fulfill user inquiries and requestsResolve disputesProtect against or deter fraudulent, illegal or harmful actionsEnforce our Terms of Service
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.
Contractual Necessity
We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Service with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
First and last name
Email address
Password
Team UP with other Members
Our Services allow you to stay in touch and up to date with colleagues, partners, clients, and other professional contacts. To do so, you will “connect” with the professionals who you choose, and who also wish to “connect” with you. Subject to your settings, when you connect with other Members, you will be able to search each others’ connections in order to exchange professional opportunities.We will use data about you (such as your profile, profiles you have viewed or data provided through address book uploads or partner integrations) to help others find your profile, suggest connections for you and others (e.g. Members who share your contacts or job experiences) and enable you to invite others to become a Member and connect with you. You can also opt-in to allow us to use your precise location or proximity to others for certain tasks (e.g. to suggest other nearby Members for you to connect with, calculate the commute to a new job, or notify your connections that you are at a professional event).It is your choice whether to invite someone to our Services, send a connection request, or allow another Member to become your connection. When you invite someone to connect with you, your invitation will include your name, photo, network and contact information. We will send invitation reminders to the person you invited. You can choose, whether or not to share your own list of connections with your connections.Visitors have choices about how we use their data.
News and other informationOur Services allow you to stay informed about news, events and ideas regarding professional topics you care about, and from professionals you respect. Our Services also allow you to improve your professional skills, or learn new ones. We use the data we have about you (e.g., data you provide, data we collect from your engagement with our Services and inferences we make from the data we have about you), to recommend relevant content and conversations on our Services, suggest skills you may have to add to your profile and skills that you might need to pursue your next opportunity. So, if you let us know that you are interested in a new skill (e.g., by watching a learning video), we will use this information to personalize content in your feed, suggest that you follow certain members on our site, or watch related learning content to help you towards that new skill. We use your content, activity and other data, including your name and picture, to provide notices to your network and others. For example, subject to your settings, we may notify others that you have updated your profile, posted a blog, took a social action, made new connections or were mentioned in the news.
CareerOur Services allow you to explore careers, evaluate educational opportunities, and seek out, and be found for, career opportunities. Your profile can be found by those looking to hire (for a job or a specific tasks) or be hired by you. We will use your data to recommend jobs or mentees, show you and others who work at a company, in an industry, function or location or have certain skills and connections. You can signal that you are interested in changing jobs and share information with job recruiters. We will use your data to recommend jobs to you and you to recruiters. We may use automated systems to profile and provide recommendations to help make our Services more relevant to our Members, Visitors and customers. Keeping your profile accurate and up-to-date may help you better connect to others and to opportunities through our Services.
2.2 Premium Services
Our premium Services allow paying users to search for and contact Members through our Services, such as searching for and contacting job candidates, sales leads and co-workers, manage talent and promote content through social media.We sell premium Services that provide our customers and subscribers customized-search functionality and tools (including messaging and activity alerts) as part of our talent, marketing and sales solutions. Customers can export limited information from your profile, such as name, headline, profile story and general location (e.g., Czech Republic), in order to manage sales leads or talent, unless you opt-out. We do not provide contact information to customers as part of these premium Services without your consent. A premium Services customer can store information he/she has about you in our premium Services, such as a resume or contact information or sales history. The data provided about you by these customers is subject to the policies of those customers.  
2.3 CommunicationsWe contact you and enable communications between Members. We offer settings to control what messages you receive and how often you receive some types of messages.We will contact you through email, mobile phone, notices posted on our websites or apps, messages to your EFA JOBS inbox, and other ways through our Services, including text messages and push notifications. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use the Services, network updates, reminders, job suggestions and promotional messages from us and our partners. You may change your communication preference at any time. Please be aware that you cannot opt-out of receiving service messages from us, including security and legal notices.We also enable communications between you and others through our Services, including for example invitations, groups and messages between connections.
2.4 Advertising
We serve you tailored ads both on and off our Services. We offer you choices regarding personalized ads, but you cannot opt-out of seeing other ads.We target (and measure the performance of) ads to Members, Visitors and others both on and off our Services directly or through a variety of partners, using the following data, whether separately or combined:
Data from advertising technologies on and off our Services, like web beacons, pixels, ad tags, cookies, and device identifiers;Member-provided information (e.g., profile, contact information, title and creative sector);Data from your use of our Services (e.g., search history, feed, content you read, who you follow or is following you, connections, groups participation, page visits, videos you watch, clicking on an ad, etc.), including as described in Section 1.3;Information from advertising partners and publishers [Learn More]; andInformation inferred from data described above (e.g., using job titles from a profile to infer industry, seniority, and compensation bracket; using graduation dates to infer age or using first names or pronoun usage to infer gender).
We will show you ads called „sponsored“ which look similar to non-sponsored content, except that they are labeled “ads” or “sponsored.” If you take an action (such as like, comment or share) on these ads, your action is associated with your name and viewable by others, including the advertiser. Subject to your settings, if you take a social action on the EFA JOBS Services, that action may be mentioned with related ads.
Ad Choices
We adhere to self-regulatory principles for interest-based advertising and participate in industry opt-out from such ads. This does not opt you out of receiving advertising; you will continue to get other ads by advertisers not listed with these self regulatory tools. You can also opt-out specifically from our uses of certain categories of data to show you more relevant ads.  
Info to Ad ProvidersWe do not share your personal data with any third-party advertisers or ad networks for their advertising except for: hashed or device identifiers (to the extent they are personal data in some countries);with your separate permission (e.g., lead generation form) or data already visible to any users of the Services (e.g. profile). However, if you view or click on an ad on or off our site or apps, the ad provider will get a signal that someone visited the page that displayed the ad, and they may through the use of mechanisms such as cookies determine it is you. Advertising partners can associate personal data collected by the advertiser directly from you with our cookies and similar technologies. In such instances, we seek to contractually require such advertising partners to obtain your explicit, opt-in consent before doing so.
2.5 Marketing
We promote our Services to you and others.We use data and content about Members for invitations and communications promoting membership and network growth, engagement and our Services.
2.6 Developing Services and Research
We develop our Services and conduct research.Service DevelopmentWe use data, including public feedback, to conduct research and development for the further development of our Services in order to provide you and others with a better, more intuitive and personalized experience, drive membership growth and engagement on our Services, and help connect professionals to each other and to economic opportunity.Other ResearchWe seek to create economic opportunity for Members of the global workforce and to help them be more productive and successful. We use the personal data available to us to research social, economic and workplace trends such as jobs availability and skills needed for these jobs and policies that help bridge the gap in various industries and geographic areas. In some cases, we work with trusted third parties to perform this research, under controls that are designed to protect your privacy. We publish or allow others to publish economic insights, presented as aggregated data rather than personal data.SurveysPolls and surveys are conducted by us and others through our Services. You are not obligated to respond to polls or surveys, and you have choices about the information you provide. You may opt-out of survey invitations.
2.7 Customer Support
We use data to help you and fix problems.We use the data (which can include your communications) to investigate, respond to and resolve complaints and Service issues (e.g., bugs).Security and InvestigationsWe use data for security, fraud prevention and investigations.We use your data (including your communications) if we think it’s necessary for security purposes or to investigate possible fraud or other violations of our User Agreement or this Privacy Policy and/or attempts to harm our Members or Visitors.

3. How and with whom do we share your data?
Any data that you include on your profile and any content you post or social action (e.g. likes, follows, comments, shares) you take on our Services will be seen by others.
Profile
Your profile is fully visible to all Members and customers of our Services. Subject to your settings, it can also be visible to others on or off of our Services (e.g., Visitors to our Services or users of third- party search engines).  
Posts, Likes, Follows, Comments, MessagesOur Services for Premium members allow viewing and sharing information including through posts, likes, follows and comments.When you share an article or a post (e.g., an update, image, video or article) publicly it can be viewed by everyone and re-shared anywhere (subject to your settings).  

We share Personal Data with vendors, third party service providers and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or our Terms of Service. These parties include:
Payment processors
Fraud prevention service providers
Third party providers of advertising services
Ad networks and marketing tools
Analytics service providers
Engineering and development tools
Staff augmentation and contract personnel
Hosting service providers
We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services), such as when users   interact through the ServicesSocial media services (if you interact with them through your use of the Services)Third party business partners who you access through the Services
We also share Personal Data when we believe it is necessary to:
Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
Protect us, our business or our users, for example to enforce our terms of service, prevent spam or other unwanted communications and investigate or protect against fraud
Maintain the security of our products and services
We also share information with third parties when you give us consent to do so. Furthermore, you acknowledge that we may transfer your Personal Data, and that any acquirer of us or our assets may continue to use your Personal Data, as set forth in the “Business Transfers” section above.

4. How long do we retain your personal data?
We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.What Security Measures Do We Use? We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity.Personal Data of Children: As noted above, we do not knowingly collect or solicit Personal Data from anyone under the age of 16.

5. What rights do you have regarding your personal data?
We keep most of your personal data for as long as your account is open.We retain your personal data while your account is in existence or as needed to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of our Services. Even if you only use our Services when looking for a new job every few years, we will retain your information and keep your profile open until you decide to close your account. In some cases we choose to retain certain information (e.g., visits to sites carrying our “share with EFA JOBS” or “apply with EFA JOBS” plugins without clicking on the plugin) in a depersonalized or aggregated form.

5.1 Rights to Access and Control Your Personal DataYou can access or delete your personal data. You have many choices about how your data is collected, used and shared.We provide many choices about the collection, use and sharing of your data, from deleting or correcting data you include in your profile and controlling the visibility of your posts to advertising opt-outs and communication controls. We offer you settings to control and manage the personal data we have about you  
Delete Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).
Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
Right to Access and/or Take Your
Data:
You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.You may also contact us using the contact information below, and we will consider your request in accordance with applicable laws.

5.2 Account Closure
We keep some of your data even after you close your account.
If you choose to close your EFA JOBS account, your personal data will generally stop being visible to others on our Services within 24 hours. We generally delete closed account information within 30 days of account closure, except as noted below.We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our User Agreement, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed.Information you have shared with others will remain visible after you closed your account or deleted the information from your own profile or mailbox, and we do not control data that other Members copied out of our Services. Groups content and ratings or review content associated with closed accounts will show an unknown user as the source. Your profile may continue to be displayed in the services of others (e.g., search engine results) until they refresh their cache.
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email efa@unique-one.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

Access
: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by emailing efa@unique-one.com
Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by making changes to your Profile. You can request that we correct or supplement such data by emailing efa@enique-one.com.
Erasure: You can request that we erase some or all of your Personal Data from our systems by emailing efa@unique-one.com
Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
Right to File Complaint: You have the right to lodge a complaint about EFA JOBS’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.

Change
Changes to the Privacy Policy apply to your use of our Services after the “effective date.”EFA („we“ or „us“) can modify this Privacy Policy, and if we make material changes to it, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective. If you object to any changes, you may close your account.You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy.
Cross-Border Data Transfers
We may store and use your data outside your country.We process data outside of the United States and rely on legally-provided mechanisms to lawfully transfer data across borders. Countries where we process data may have laws which are different, and potentially not as protective, as the laws of your own country.
Our statements regarding direct marketing  
We currently do not share personal data with third parties for their direct marketing purposes without your permission.  

6. Do you have questions about your Personal Data?
If you have any questions about this Privacy Notice or our data practices generally, please contact us using the following information:
Name: E-F-A Association s.r.o.
Email address for contact: efa@unique-one.com
Physical address: Opletalova 1013/59, Prague 1 – Nové Město, 110 00, Czech Republic
Designated representative and contact information: DPO EFA Jobs (Data Protection Officer)                                                           efa@unique-one.com