Last revised: August 25, 2023
Huntly.ai Inc., together with its affiliates, associates, and partners (collectively "Huntly" or "we", "us") is a marketplace that unites tech product companies, IT recruiters, and specialists in the information technology field. With our help IT businesses accelerate their hiring process, recruiters generate income, while software developers make rewarding careers. During its business, Huntly collects some information that could be used to identify you. We call this information "personal data".
We control the collection and processing of personal data relating to individuals who interact with us ("data subjects" or "you"). The data subjects may include (without limitation): candidates for current or future positions at the employer's companies ("candidates"); users who provided their personal data while submitting information regarding the candidates on our platform ("recruiters"); and any other visitors and users of our website available at https://huntly.ai (collectively "users"); as well as our existing or potential clients (collectively "employers").
As we operate in many countries around the world, our privacy practices may vary among the regions to reflect local practices and laws. However, in no case will they be less strict than those provided in this Policy.
PERSONAL DATA THAT WE COLLECT
The personal data we receive during our business may include the following:
Please note that the specific range of personal data we collect varies on a case-by-case basis, and, among other things, depends on how you interact with us and for which purpose.
PERSONAL DATA THAT WE DO NOT INTENTIONALLY COLLECT
Of course, you are free to decide which information to share with us. However, we ask you to consider the following warnings:
HOW DO WE COLLECT THE PERSONAL DATA
We receive your personal data especially when:
In addition, we may receive your personal data when you register or update your account on our website. You can easily access, update or delete your personal data stored in such account, including amending or deleting specific information, through your user's electronic cabinet or contacting us (please see details in Section "Contacts" herein below).
In general, you are not obliged to provide your personal data to us. However, most probably we will not manage to fulfill your requests or provide you with the services (in whole or in part) unless you do so. If you ask so, we will advise you whether the provision of your personal data is mandatory in that particular case (and of possible consequences if you do not provide us with it). Please note that we may combine personal data about you collected from different sources.
SPECIAL RULES WHEN PERSONAL DATA IS NOT COLLECTED DIRECTLY BY HUNTLY
We may get your personal data indirectly (for example, when a recruiter submits information about you as a candidate filling out a position opened at the company of one of our clients, etc.).
You may be assured that when any portion of your personal data is not collected directly from you, we will always notify you at the point of collecting personal data in such a manner or, at the latest, within a month from the moment of collection of that data. We will process such personal data for the purpose for which it was gathered until you ask that we remove it. However, in such a case Huntly will have the right to keep some personal data to the extent required by the provisions of domestic and/or international law.
Moreover, we always oblige recruiters to share the candidates' data with us only based on the candidates' explicit consent to such transfer and further processing of the said data as described herein. Consequently, the recruiter who has provided us with your data is responsible for having received your consent. However, if you have not agreed to it, please inform us (please see details in the Section "Contacts" herein below).
HOW WE USE THE PERSONAL DATA
Huntly may use your personal data for the purposes described below.
This list is not exhaustive, and we may seek to process your personal data for any other purpose as disclosed to you, to which you specifically agreed, or as required or permitted by the provisions of domestic and/or international law.
LEGAL BASIS FOR PROCESSING OF YOUR PERSONAL DATA
The legal basis upon which we collect, use, store, and otherwise process your personal data will depend on the personal data concerned and the specific purpose for which it is needed.
In general, we rely on one of the following grounds:
You may be assured that we use your personal data in ways that you would reasonably expect, and our legitimate interest serves as a legal basis for the collection and processing of your personal data only if, and to, the extent it does not interfere with your rights and freedoms.
You have the right to object to these grounds of the processing of your personal data by contacting us (please see details in Section "Contacts" herein below), upon which we will delete your personal data without further delay (unless we have a separate legitimate ground for further processing).
NOTE: you are free to withdraw your consent at any time by contacting us (please see details in Section "Contacts" herein below), upon which we will delete your personal data without further delay (unless we have a separate legitimate ground for further processing). If you withdraw your consent, it will not affect the lawfulness of the prior processing of your personal data based on your consent before you withdrew it.
Please be assured we will handle your personal data only in line with the purpose for which it was collected. If at any moment we intend to process your personal data for any other purpose, we will not do this without sending you respective notification / your prior explicit consent (subject to the exclusions and limitations which may be provided in the provisions of domestic and/or international law).
If you have any questions or need more information concerning the legal basis on which we collect your personal data, please contact us to clarify further details (please see details in Section "Contacts" herein below).
HOW LONG WE KEEP YOUR PERSONAL DATA
To determine the appropriate retention period for your personal data, we consider (1) the amount, nature, and sensitivity of the personal data in question; (2) the potential risk of harm from unauthorized use or disclosure of your personal data; (3) the purposes for which we process your personal data; (4) whether we can achieve those purposes through any other means; and (5) the applicable legal requirements.
We do not keep your personal data for any longer than is necessary (a) to fulfill the purpose for which we collected it (you may find more details in Section "How we use the personal data" herein above); (b) to comply with domestic and/or international law, or other regulatory obligations (for instance, accounting or reporting requirements) that apply to our business and services we provide; or (c) to assert and/or defend against legal claims.
Normally, the retention period will not exceed 2 years. However, if it happens so that we are legally required to hold some types of personal data to fulfill our statutory obligations (for instance, taxation, accounting, or reporting purposes) – then we will hold your personal data in our systems for as long as necessary for the relevant activity. Moreover, in some cases, we may anonymize your personal data (in such a manner that you are not or no longer identifiable) for research or statistical purposes, in the event which we may use this information indefinitely without further notice to you.
We review our personal data retention periods on a regular basis. If you have any questions about how long we keep your personal data, you may contact us (please see details in Section "Contacts" herein below) to clarify all the questions you have.
YOUR RIGHTS WITH RESPECT TO PERSONAL DATA
As a data subject, you have certain rights under domestic and/or international law in relation to the personal data we hold about you. Where the processing of your personal data is subject to the European Union data protection legislation, including the General Data Protection Regulation (for instance, when you are physically located in one of the European Union/ European Economic Area countries) or to the United States data protection legislation, including privacy regulations of particular states (for instance, when you are physically located in the United States), at a minimum you have the set of data subject rights provided below.
Right of access
If you ask us, we will confirm whether we are processing your personal data and, if necessary, provide you with a copy of such personal data (along with other details). There are some limitations and exceptions concerning this right: for example, where information is legally privileged, or if providing you with the information would reveal any personal data of another person.
Right to data portability
In certain circumstances, you have the right to receive your personal data provided by you to us and reuse it elsewhere, or send such data to another organization (or ask us to do so if technically feasible); this is regarding where (1) our lawful basis for processing the personal data is consent or necessity for the performance of our contract with you, and (2) the processing is carried out by automated means.
Right to rectification
You may require us to update or correct any inaccurate personal data or complete any incomplete personal data concerning you. If you do, we will take reasonable steps to check the accuracy and correct your personal data. Please let us know if any of your personal data changes so that we can keep it accurate and up to date. If you are entitled to rectification and if we have shared your personal data with others, we will let them know about the rectification where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with, so that you can contact them directly. Also note that Huntly is not required to notify third parties to whom your personal data has been disclosed of any rectification when such notification involves an unreasonable burden or disproportionate effort. A large portion of recruiter’s personal data can be updated through your user’s electronic cabinet.
Withdrawal of consent (right to opt out)
If we rely on your explicit consent as our legal basis for processing your personal data, you have the right to withdraw that consent at any time by contacting us (please see details in Section "Contacts" herein below). Your withdrawal of consent does not affect the lawfulness of processing based on your consent before its withdrawal.
If it happens so that we process your personal data on a legal basis other than your explicit consent, you have the right to opt out (unless we have a separate legitimate ground for further processing) of data processing by contacting us (please see details in Section "Contacts" herein below). It will not affect the lawfulness of processing before you decided to opt out.
Right to object
You can ask us to stop processing your personal data and we will abide so if we are:
Right to erasure
You can ask us to delete your personal data in some circumstances, for instance, if you withdraw your consent or decide to opt out of data processing (where applicable). For situations where, in accordance with the provisions of domestic and/or international law, we fulfill your request and Huntly will delete your personal data without undue delay. If you are entitled to erasure and if we have shared your personal data with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you whom we have shared your personal data with, so that you can contact them directly. Also, note that Huntly is not required to notify third parties to whom your personal data has been disclosed of any deletion when such notification involves a disproportionate effort or unreasonable burden.
Right to restriction of processing
You can ask us to ‘block' or suppress the processing of your personal data in certain circumstances (such as where you contest the accuracy of that data or you object to us), so that we no longer process that personal data until that restriction is lifted. If you are entitled to restriction and if we have shared your personal data with others, we will let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we will also tell you whom we have shared your personal data with, so that you can contact them directly.
Rights in relation to automated individual decision-making, including profiling
You have the right to be free from decisions based solely on automated processing of your personal data, including profiling, unless these are necessary for entering into, or the performance of, a contract between you and us, or unless we do so based on your explicit consent (still such consent can be withdrawn as described in Subsection "Withdrawal of consent" herein above).
Right to file a complaint
If you have a concern with respect to the way we process your personal data, you can report it to the relevant supervisory authority (please see details in Section “Complaints” herein below).
Please note that these rights are not absolute and in certain cases are subject to conditions as specified in the provisions of domestic and/or international law. For instance, it may happen if we have an overriding interest or legal obligation to continue to process your personal data.
You can exercise the above rights, where applicable, by contacting us directly (please see details in Section "Contacts" herein below). We will respond to your request within the statutory period and typically seek to resolve the matter within one month. We will require you to provide satisfactory proof of your identity in order to ensure that your personal data is disclosed only to you.
While we will make reasonable efforts to accommodate your request, we reserve the right to reject such access requests, or to impose restrictions or requirements upon such requests if required or permitted by provisions of domestic and/or international law but will explain "why" if we do so.
SHARING AND TRANSFERRING PERSONAL DATA
If you are physically located in one of the European Union/ European Economic Area countries, please note that your personal data may be transferred and processed in states which are not recognized as providing the appropriate level of data protection in the meaning of the General Data Protection Regulation, including, without limitation, in the US. You may be sure that at any given moment such processing will be subject to appropriate safeguards that are prescribed by the applicable legislation, in particular those specified in Article 46 of the General Data Protection Regulation (such as the application of the standard contractual clauses available on the European Commission website).
Huntly may exchange your personal data with its affiliates, associates and partners. Moreover, we may share your personal data with (where and to the extent necessary in connection with the purposes described in this Policy):
Anyway, you may be assured that we do not share personal data with third parties, except as (a) necessary for our legitimate professional and business needs; (b) necessary to carry out your requests; (c) necessary to provide our services to you; (d) pursuant to your explicit consent; (e) required or permitted by law; and/or (f) as otherwise described in this Policy. Huntly will only transfer personal data to such persons when they meet our strict standards on the processing of personal data and security and pass those same standards down to their sub-processors.
Where we believe that processing or other business activities on our behalf or in our interest are better performed by third parties ("third-party service providers"), we may outsource respective operations to them and, consequently, transfer your personal data to those persons, such as our IT systems providers, website hosting providers, data analysis, data backup, security and cloud storage services, consultants and other providers. We only share personal data that they reasonably need to provide their services and will not transfer your personal data to any third parties for their own direct marketing purposes. We ensure that third-party service providers are authorized to use your personal data only as necessary to provide services on our behalf or in our interest.
Please note that the storage of your personal data on servers and/or on software made available or hosted by third-party service providers shall not be considered a disclosure of your personal data to third parties as far as third-party service providers do not have direct access to it. In all events, we shall ensure by contract that our third-party service providers protect your personal data that is shared with them.
In an ongoing effort to better understand users of our website, we may analyze anonymous and aggregate information in order to operate, maintain, manage, and improve our website and/or the services that we render. This aggregate information does not identify you personally. We may share this aggregate data with our clients, third-party service providers and other persons. We may also disclose aggregated user statistics in order to describe the services of Huntly (or pursuing other lawful purposes) to current and prospective business partners, clients and other persons.
You may at any time decide to opt out of sharing and transferring (unless we have a legal necessity or obligation to do so, including to meet the requirements set forth by domestic and/or international law) of your personal data by contacting us (please see details in Section "Contacts" herein below). It will not affect the lawfulness of data sharing and transferring before you decided to opt out.
In certain situations, we may be required to disclose your personal data where we have a legal necessity or obligation to do so, including to meet the requirements set forth by domestic and/or international law. For instance, we may disclose your personal data to assert and/or defend against legal claims.
In the event of a sale, merger, receivership or transfer of all assets of Huntly, we reserve the right to assign or share your personal data with such third parties and their advisors. Please be assured that you will be sent notice of such an event should it occur with the ability to opt out of such a transfer unless Huntly and/or such third parties have a separate legitimate ground for such transfer and further processing of your personal data.
PERSONAL DATA SECURITY
Huntly has security measures in place to protect the information we process (including your personal data), which involve preventing, detecting, investigating, and resolving security threats, both during transmission and once we receive it.
We do our best to protect your personal data, whether in electronic or tangible form (e.g., hard copy), by sticking to appropriate internal policies and using state-of-the-art technical and organizational measures that follow the requirements present within the European Union/ European Economic Area and the United States for the safe and lawful processing of personal data.
Moreover, we restrict access to your personal data to authorized individuals among internal personnel, agents, or contractors of Huntly who need to access your personal data to perform specific tasks. Your personal data is contained behind secured networks and is only accessible by a limited number of persons who are required to keep the information confidential.
Although we use industry-standard precautions to safeguard your personal data, the transmission of data over the Internet (including by e-mail) is never completely secure. We endeavor to protect personal data, but 100% complete security does not presently exist anywhere online or offline. For this reason, you should take care in deciding what information you send to us, especially when you do so at your own initiative.
If you have any questions about security, you may direct them to us (please see details in Section "Contacts" herein below).
This Section explains how and why cookies and any other tracking technologies may be stored on and accessed from your device when you visit or use our website.
Please read this Section carefully before using our website.
What are "cookies"? Cookies (or similar technologies) are tiny text files containing small amounts of data about you and your interaction with our website. Cookies work by assigning users with unique reference codes (identifiers) that are placed on their devices when they access the website. Later (if they last longer than a web session) they are sent back to the originating website on each subsequent visit, or to another website that recognizes them.
Please note that our website may also contain other tracking technologies such as "pixels" (or "web beacons"). These are typically small transparent images that provide us with website statistics. They are often used in conjunction with cookies, though they are not stored on your device in the same way. As a result, if you disable cookies, pixels may still load, but their functionality will be restricted. For simplicity, all such technologies are further collectively referred to as "cookies".
Some cookies are critical for the proper functioning of our website ("Necessary Cookies"), whereas others help us personalize and improve your experience while using the website (such as "Preference Cookies", "Statistic Cookies", and "Marketing Cookies"). A list of cookies employed by us and third parties through our website is described in the Subsection "What cookies are used on this website" herein below.
Cookies can remain on your device for different periods of time. Some of them are "Session Cookies" – they are only stored on the device during your browser session. In other words, they are automatically erased when you close your browser. Other ones like "Persistent Cookies" will remain on your device even after your browser session has ended until you manually erase them, or as they expire. They are used, for example, to remember you when you return to the website.
Our website uses both 'first' and 'third' party cookies depending on the domain placing/providing them. First-Party Cookies are those set directly by this website, whereas Third-Party Cookies are placed or provided by other domains (please see the list of such third parties herein in Subsection "Third parties"). Please note that we have no (or limited) control over Third-Party Cookies.
If you are accessing our website from the United States or other non- European Union/ European Economic Area countries, you have the right to restrict us from of storing and accessing any cookies, pixels and other tracking technologies which do not refer to Necessary Cookies by contacting us (please see details in Section "Contacts" herein below).
If you are accessing our website from the European Union/ European Economic Area, you will see a cookie banner on your first visit.
By clicking 'Accept' on the cookie banner, you give us your consent to store and access cookies as described in this Section.
By clicking 'Reject' on the cookie banner, you do not allow us to store and access any cookies, pixels and other tracking technologies which do not refer to Necessary Cookies. However, it may disrupt the normal functioning of our website (and have an adverse impact on your user experience).
We use the information that we gather in order to evaluate the website's usage, content, navigability, and composition. This statistical analysis allows us to improve our website, make your user experience more enjoyable, and provide value-added services.
What we don't do with cookies. We never share or sell any information about you (including your personal data) except as and to the extent expressly stated in our policies and/or communications with you. Please also be assured that cookies cannot be used to run programs or deliver viruses to your devices.
Third parties. As mentioned above, if you visit a website and another entity sets a cookie through that website, this would be a Third-Party Cookie. Some of the cookies we place on our website could be provided by trusted third parties. As a result, such other entities may obtain and process some data about you as set out in their policies – you may find more details in this regard in the table below.
Data Transfer Frameworks
|Purpose. We have integrated Google Analytics, a website analysis tool provided by Google LLC and its affiliates into our website, to collect and analyze user activity data.|
Where the data is processed. The information collected may be transmitted and stored in data centers located all over the world (listed on the following webpage), in particular in the United States, by Google LLC, its affiliates, and/or third-party service providers acting on their behalf.
How to opt out. You may opt-out of Google Analytics features by following the link. Moreover, the cookies placed and processed as a result of the integration of this and other services provided by the same supplier could be disabled through your device settings (as described in Section "Disabling cookies").
|Meta (Facebook)||Meta Data Policy|
Meta FAQs on GDPR
Facebook business tools terms
Facebook Data Processing Terms
|Purpose. We've integrated Facebook Pixel, a tool provided by Meta Platforms, Inc., to help us track conversions from Facebook ads, optimize ads based on collected data, create target audiences for future ads, and remarket for prospective customers.|
Data processed. The information includes contact data and information about the actions of users on the website, which is described in more detail in Section 1(a) of Facebook business tools terms.
Where the data is processed. The information collected may be transmitted and stored in data centers located all over the world (listed at the following webpage), in particular in the United States, Europe, and Singapore, by Meta Platforms, Inc. and/or third-party service providers acting on its behalf (you may see the list of Facebook ads data sub-processors via the following link).
How to opt out. You may delete and prevent usage of Facebook Pixel through your device settings (as described in the Section "Disabling cookies").
LinkedIn Cookie Table
LinkedIn Insight Tag: FAQ
LinkedIn Ads Agreement
European Union, European Economic Area, and Swiss Data Transfers
|Purpose. We have integrated LinkedIn conversion tracking (LinkedIn Insight Tag) which is an analytics and behavioral targeting service provided by LinkedIn Ireland Unlimited Company or LinkedIn Corporation (depending on the location where you access our website from) that connects data from the LinkedIn advertising network with actions performed on this website. The LinkedIn Insight Tag tracks conversions that can be attributed to LinkedIn Ads and enables targeting groups of users on the basis of their past use of our website (you may find more information about the LinkedIn Insight Tag via the link).|
Moreover, the website may employ LinkedIn Ads – an advertising service provided by LinkedIn Ireland Unlimited Company or by LinkedIn Corporation (depending on the location this website is accessed from). It offers access to LinkedIn social networks through various sponsored posts and other methods.
Data processed. The information includes device information, as well as tracker and usage data, which is described in more detail in LinkedIn Cookie Table.
Where the data is processed. The information collected is transmitted and stored in data centers located in the United States, by LinkedIn Ireland Unlimited Company or LinkedIn Corporation (depending on the location this website is accessed from) and/or third-party service providers acting on their behalf (please see the list of LinkedIn sub-processors on the following webpage).
How to opt out. You may opt-out of behavioral targeting features through your LinkedIn account settings. Moreover, you may disable LinkedIn cookies by managing your device settings (as described in the Section "Disabling cookies").
Cookies Set by the Hotjar Tracking Code
|Purpose. We use Hotjar services (via the official Google Tag Manager integration) rendered by Hotjar Ltd. in order to better understand the behavior of our website users, in particular: (1) to determine if the user has visited the website before, or if it is a new user of the website; (2) to count how many times a website has been visited by the visitor; (3) to define average time spent by the user on our website; (4) to identify what pages have been read by the user.|
Data processed. The information may include the following: (1) the time the user visits our website; (2) the quantity of visits of our website; (3) URL & title of webpages viewed by the user; (4) user ID unique to our website, etc.
Where the data is processed. The information collected may be transmitted and stored in data centers located all over the world, including in countries outside the Europe, by Hotjar Ltd. and/or by third party service providers acting on its behalf (you may find more information in this regard on Data Storage page).
How to opt out. You may opt out of processing of your data by Hotjar Ltd. following the link. Moreover, the cookies placed and processed as a result of integration of this and other services provided by the same supplier could be disabled through your device settings (as described in Section "Disabling cookies").
What cookies are used on this website. You can find the details of cookies used on this website below:
Disabling cookies. Most internet browsers are initially set up to automatically accept cookies. You can manage cookies by adjusting the appropriate settings on your browser, although some of our website features may not function as a result.
You can follow the links provided below to manage the cookie settings on your device depending on the browser you use:
Moreover, you can find useful information about managing cookie preferences on the All About Cookies website – it is a free resource which explains:
LINKS TO OTHER WEBSITES
Our website (including this Policy) may contain links to other websites, and you should review the privacy policies on those sites. We take no responsibility for the policies and practices of those websites.
CHANGES TO THIS POLICY
We may from time to time modify this Policy, upon which we will also update the ‘Last revised' date stated herein above. You are still advised to visit this page regularly for the latest information on our privacy practices.
If you consider that your personal data is processed in contradiction with applicable legal regulations, you have the right to file a complaint directly with the respective personal data protection authority. If you are physically located in one of the European Union/ European Economic Area countries, you can access the contacts of the European Union national data protection authorities at the website of the European Data Protection Board. If you are physically located in the United States, you can either contact the Federal Trade Commission or the General Attorney of your state (or California Privacy Protection Agency if you are within California).
If you (a) have any questions or complaints regarding this Policy or the way your personal data is processed; (b) would like to report any suspicious activity, including automated messages or calls from parties you cannot identify; or (c) would like to exercise a legal right in relation to your personal data, please contact us by one of the following means: