Data Privacy Policy

Last updated:

February 23, 2021

White Crow Research Private Limited (“WhiteCrow / We / Our”) situated at - 1002, B Wing, Supreme Business Park, 10th Floor, Hiranandani, Powai, Mumbai, Maharashtra - 400076, respects the data provided by the employer candidate and/or the designated employee of the employer candidate subscribing to its Services (defined as below) (“Employer Candidate / You / Your”) and is committed to protecting the personal information collected about or provided by You by using and accessing the website i.e., www.webbtree.com (“Website”). To that end, We have designed the WhiteCrow’s / Website’s Data Privacy Policy along with the Addendums (this “Policy”) to guide on how WhiteCrow / Website stores, collects, manages and uses the personal information obtained from You in connection with Our Services (defined below).

This Policy applies only to the information submitted to and collected directly by WhiteCrow / Website through the use of the Services (defined below) by the Employer Candidate.

It is to be noted that the Terms and Conditions along with this Policy [including addendum(s)], the Service Level Agreement and the Subscription Form, collectively form the “Agreement”. The capitalized terms unless defined herein shall have the same meaning assigned to them under the Terms and Conditions provided on the Website.

By using, accessing and subscribing to the Services provided on the Website, the Employer Candidate agrees to be bound by the terms of the Agreement and more specifically the collection, use and disclosure of information of the Employer Candidate, which is in accordance with this Policy.

WhiteCrow through the Website, provides services pursuant to a “software-as-a-service” (i.e., “SaaS”) delivery model, primarily in the nature of a ‘sourcing and talent pipelining tool in addition to an applicant tracking system’ under which You use the applicable software components (the “Software”) providing access to the database through the Website in addition to providing SaaS services via internet on a subscription service basis. For the purpose of availing the Services, the Employer Candidate will enter into and execute a subscription form, subscribing to the Services on the Website (“Subscription Form”). Accordingly, during the Term / Subscription Term / Trial Subscription Term, as the case may be, and subject to the compliance to the provisions of the Agreement, WhiteCrow grants You a non-exclusive, non-transferable, limited, time-bounded, license (non-sub licensable) to access and use the SaaS services and/or Services (defined as below) via internet. The access to the database through the Website and the use of the SaaS services may only be used in support of Your business operations.

‘Webbtree’s AI engine’ is a network of knowledge that stores data on jobs, skills, companies, industries, people, places and more. This enables WhiteCrow to provide a platform to identify the right talent and maximize the scope of search for talents through the Website. WhiteCrow’s Services grants access to the database through the Website which aid in sourcing, pipelining and tracking public profiles to identify and locate appropriate talent from across the internet. You shall select Your desired criteria and a list of options shall be available to You. To further ease the process, the Employer Candidate shall be free to filter the potential talents / candidates who are qualified to be a desired candidate for You. In addition to the ‘sourcing and talent pipelining tool’, the component of ‘applicant tracking system’ of the Service, will aid the Employer Candidate to better manage their internal hiring process with automation, collaboration and other tools upon gaining access to the database and use of SaaS (“Service(s)/ WhiteCrow’s Services”).

WhiteCrow through the Website may, from time to time, make changes to this Policy. If WhiteCrow through the Website makes any material change to this Policy, WhiteCrow shall notify the Employer Candidate of those changes by posting them on the Website and shall indicate the date of the last revision. Please note that, the Employer Candidate’s continued use of the Services after the changes pertaining to this Policy have been posted, will constitute Your acceptance of those changes.

This Policy describes the treatment of information provided, collected or retained by WhiteCrow / Website. This Policy applies to WhiteCrow’s Services displayed on the Website, but not to the website maintained by other companies or organizations to which WhiteCrow / Website may provide links to. WhiteCrow, therefore, is not responsible for the content or activities provided or created on such sites. Further, if the Employer Candidate has any questions about this Policy or Our data practices, the Employer Candidate shall not hesitate to contact Our team:

Privacy inquiries: support@webbtree.com
Security inquiries: support@webbtree.com

Information:
1. Personal Information is information that others can use to identify, locate or contact You, including but not limited to, Your name, email address, postal address and phone numbers (collectively “Personally Identifiable Information” or “PII”). Specifically, WhiteCrow / Website may collect the following list of PII in connection with Your use of the Services:
  1. ‘Identity Data’ such as name of the employer entity, name of the Employer Candidate, employer entity’s website, social media profiles, username, alias, postal address, unique personal identifier, online identifier, ‘Internet Protocol’ address (“IP Address”), email address, account name, and if provided by the Employer Candidate at its discretion, the information pertaining to (i) the social security number, (ii) driver’s license number, and (iii) passport number, or other similar identifiers.
  2. ‘Contact Data’ such as physical address, email address, social media address, telephone number and any other contact information You provide to WhiteCrow / Website.
  3. ‘Transaction Data’ such as details about payments to and from You and details regarding the subscribed Services through the Website.
  4. ‘Technical Data’ such as device IDs, Your login data, access dates and times, browser type and version, device information, ‘Cookie data’, time zone setting, browser plug-in types and versions, platform and other technology on the devices You use to access the Website.
  5. ‘Profile Data’ such as Your username and password, searches made by You, preferences, user-generated content, feedback and survey responses.
  6. ‘Usage Data’ such as information about how You use the Website and the Services.
  7. Similar networking activities such as Your browsing history, search history, information on Your interaction with a website, application or advertisement.
    In addition to the PII listed above, the WhiteCrow / Website may also collect:
    - Generic geographic location, such as the city in which You are located;
    - Operating System; and
    - IP Address.
    The above mentioned list of the PII to be collected by WhiteCrow / Website is non-exhaustive and may or may not include other information of similar nature as may be required by WhiteCrow / Website.
2. It is made expressly clear that the elements forming part of the compilation of the candidate’s data relating to age, ethnicity, gender etc., whether directly compiled or implied, is made with the purposes of inclusion and not to create any bias or discrimination of any nature whatsoever against a candidate. WhiteCrow proposes, recommends and anticipates that the Employer Candidate uses such data, employing the principles and fundamentals of the right to equal employment. WhiteCrow is not responsible for any consequential implications pertaining to the method and manner of use of such data by the Employer Candidate.
3. WhiteCrow / Website uses the geo-location services on the devices used to access or use the Services at any time, through Your device settings. WhiteCrow / Website collects geo-location and proximity of Your device, for which the location services will have to be enabled on Your device (e.g., GPS-based functionality on mobile devices used to access the Website) and WhiteCrow / Website may use that information to customize the interactions with location-based information and features.
4. In some cases, WhiteCrow / Website may assign an identification number to You (“ID Number”). ID Number may be linked with PII only for the purposes of providing the Services or for internal reporting purposes.
5. WhiteCrow / Website assures You that WhiteCrow / Website would never rent or sell Your PII, subject to the provisions of the CCPA Addendum. WhiteCrow / Website will solely retain its data sourced from the Services provided on the Website and not the information/data shared directly by the Employer Candidate with WhiteCrow / Website, provided to avail the Services. Please note that, as far as the data shared by the Employer Candidate with WhiteCrow / Website is concerned, WhiteCrow / Website will not be or act as the data owners or data controllers of such data.
6. WhiteCrow / Website may collect different types of personal and other information based on Your use of Our Services and Our business relationship with You, including contact information, billing information, equipment, performance, Website’s usage, viewing and other technical information about Your use of Our network, Services or Website. Such information may be collected when (i) You provide information to WhiteCrow / Website with the intent to subscribe or interact with WhiteCrow about its Services offered; (ii) collected automatically when You visit the Website or use Our Services; or (iii) WhiteCrow / Website obtains it from other sources, such as credit agencies. WhiteCrow / Website may collect/store Your calls and SMSs and content thereof, received or initiated using the Services, including but not limited to, details of the phone numbers that interact with Your account, IVR content and call recordings and information which it may automatically receive and record on its server logs from Your internet browser, including but not limited to, Your IP Address, Cookie information and details of the web pages You request. In order to register/subscribe on the Website and use the Services, You are required to share the information for the effective performance of the Services.
7. To continue to provide You with updates to the Services, WhiteCrow / Website collects and controls information about: (i) the way You use and interact with Our Services; and (ii) Your PII shared with WhiteCrow upon subscription. Such collection and controlling of the information aids to improve Our Services and further build and recommend new services and customized features. Subject to the permissible extent stipulated under this Policy, as stated in this Section 1.7, WhiteCrow / Website also engages in the collection of Your PII for the purpose of Our business development exercise. WhiteCrow / Website adheres to reasonable security measures when processing Your PII for such purposes.
8. WhiteCrow’s / Website’s intension in collecting Your PII is to provide You with the best customer experience possible by communicating with You regarding Service updates, offers and promotions, delivering advertising (subject to Section 6 of this Policy) that may be of interest to You, addressing network and security issues, investigating or taking action regarding illegal activities or violations of Our terms of use or other policies, as may be laid out on the Website from time to time.

Collection of Information:

WhiteCrow / Website collects Your information/PII throughout the Term / Subscription Term / Trial Subscription Term, as the case may be.

Employer Candidate: WhiteCrow / Website collects information that You voluntarily provide WhiteCrow/ Website during Your interaction and subscription with the Services. For example, You may choose to provide WhiteCrow / Website with information upon registering on the Website, by submitting the Subscription Form and making payment of the subscription fees through the link provided on the Website.
WhiteCrow / Website may also collect certain types of information automatically, including through the use of Cookies (defined below), web beacons and other similar tracking technologies. These tracking technologies allow WhiteCrow to personalize Your experience with the Services and keep track of certain online behaviour in order to help WhiteCrow / Website determine the things that You find most interesting.

A ‘cookie’ is a small bit of record-keeping information that sites often store on the Employer Candidate’s computer or mobile device (“Cookie(s)”). Cookies are typically used to quickly identify the Employer Candidate’s device and to “remember” things about the Employer Candidate’s visit. For example, WhiteCrow / Website may use Cookies or a similar method to keep track of Your app session. Information contained in a Cookie may be linked to Your PII for this purpose. You can disable Cookies or set Your browser to alert You when Cookies are being sent by Your device or computer although this may affect Your ability to use many of the features of the Services.

WhiteCrow / Website uses Cookies to distinguish You from other users of the Website. This helps WhiteCrow / Website to provide You with a better experience when You browse the Website and also allows WhiteCrow / Website to improve.

WhiteCrow through the Website may use the following types of Cookies:

Strictly necessary Cookies: These are Cookies that are required for the operation of the Website. They include, for example, Cookies that enable You to log into secure areas of the Website.
Analytical/performance Cookies: They allow WhiteCrow /Website to recognise and count the number of visitors/Employer Candidate and to see how visitors/Employer Candidate move around the Website when they are using it. This helps WhiteCrow to improve the way the Website works, for example, by ensuring that Employer Candidate finds what they are looking for easily.
Functionality Cookies: These are used to recognise You when You return to the Website. This enables WhiteCrow /Website to personalise Website’s content for You and helps greet You by name and remember Your preferences.
Targeting Cookies: These Cookies record Your visit to the Website, the pages You have visited and the links You have followed.

You can find more information about the specific Cookies that WhiteCrow through the Website uses and the purposes for which it is used in the table below:

Name	Type	Description	Expiry By Type
Google Analytics	Analytical	This Cookie collects information about Your computer, including where available Your IP Address, operating system and browser type, and geographic location. WhiteCrow/ Website uses this information for Website optimisation and to monitor the Employer Candidate’s browsing activities and navigation through the Website. This information is anonymous and would not allow WhiteCrow to identify any individual user without the assistance of a third party such as an ISP. . You are able to opt out of Google Analytics by installing a browser add-in which is available at https://tools.google.com/dlpage/gaoptout. Please note that this add in is provided by Google and We offer no warranty, whether express or implied, as to its suitability or efficacy.	_ga 2 years _gid 24 hours _gat 1 minute

In addition, to analytical Cookies, WhiteCrow through the Website uses CleverTap from WizRocket Inc within WhiteCrow’s web-portal at: www.webbtree.com. This is a third-party application which permits WhiteCrow to: :

Integrate app analytics and marketing.
Track actions users are taking in the said portal to analyse how Employer Candidate uses Our product; and
Run marketing campaigns based on the user tracking.

You may opt out of any sharing of Your PII with CleverTap by emailing us at:support@webbtree.com

WhiteCrow / Website also uses other tools like:

(i) Hotjar: https://www.hotjar.com

Any other tool that WhiteCrow / Website at its sole discretion decide to use with the intent to improve the functioning of the Website for its users/Employer Candidate.

Third Party Sites: WhiteCrow may obtain and collect information from third party websites including but not limited to, ‘www.whitecrowresearch.com’ and ‘WhiteCrow’ group entities (“Sites”), either contractually or otherwise. The Employer Candidate by subscribing to the Services grants its irrevocable consent to WhiteCrow / Website to obtain and collect the information from such Sites, in any manner whatsoever and also share the Employer Candidate’s PII with the third party websites. The websites: (i) ‘www.whitecrowresearch.com’ and (ii) ‘WhiteCrow’ group entities, will operate as a ‘helpdesk’ and provide services to the Employer Candidate, in any event the Employer Candidate encounters issues with respect to: (i) the Services provided on the Website; or (ii) the Agreement entered into upon subscription. The Sites can also be accessed by the Employer Candidate, at their discretion, to use other services provided on these Sites to aid and help in achieving their desired outcome. The Website may also contain links to other websites, with an intent to give access to the landing page of ‘LinkedIn’, ‘Indeed’ etc.
WhiteCrow / Website in no event is engaged in the activity of scrapping of the data from the other websites and is in compliance of any anti-scrapping policies or such similar terms of the other websites. The Services provided by WhiteCrow enables WhiteCrow / Website to grab and drop specific data for a specific instance, pertaining to a candidate/talent identified by the Employer Candidate, to ease and assist the Employer Candidate to analyse and identify potential talents from across the internet. The grab and drop feature is provided solely to ease the capture of information for an instance identified by the Employer Candidate from a particular website and is not provided or intended to be provided for ‘bulk scrapping’ of information by the Employer Candidate.
WhiteCrow / Website may share the Employer Candidate’s PII with Our service providers who perform functions necessary to providing the Services on Our behalf. Examples include analysing data and providing marketing assistance and customer service. These service providers are not authorized by WhiteCrow / Website to use or disclose PII except as needed to perform their functions or comply with legal requirements and they may not use it for any other purposes. WhiteCrow / Website does not disclose or transfer Your PII to third parties for any other purpose. However, WhiteCrow / Website does not represent that WhiteCrow / Website controls the treatment of Your PII by such third parties, as the privacy practices of third parties may differ from those described in this Policy.

How WhiteCrow / Website Uses Information:

WhiteCrow / Website uses Your information/PII throughout the Term / Subscription Term / Trial Subscription Term, as the case may be.
1. WhiteCrow / Website shares the Employer Candidate’s PII /data with:
  - a third party including but not limited to a managed service company, recruitment process outsourcing provider, Information Technology service provider engaged by WhiteCrow to assist in discharging its obligation under the Agreement;
  - third party service providers; and
  - WhiteCrow group entities.
2. WhiteCrow / Website processes Your PII and shares this information with third parties to the extent necessary to provide You with the Services. WhiteCrow / Website cannot provide You with the Services without processing Your PII. WhiteCrow / Website may also use information collected from third party software providers that You may choose to connect to WhiteCrow / Website to enable additional functionality in the platform of the Website.
3. When You subscribe to Our Services, WhiteCrow / Website will send You administrative or account-related information to You to keep You updated about Our Services, inform You of relevant security issues or updates or provide other transaction-related information to You. WhiteCrow / Website processes Your contact information to send You such communications. Service-related communications are not promotional in nature. You will not be able to unsubscribe from such communications, otherwise You may miss important developments relating to Your account or the Services that could affect Your use of the Services.
4. To respond to Your inquiries and provide customer service: WhiteCrow / Website processes Your PII when You contact WhiteCrow through the Website, such as with questions, concerns, feedback, disputes or issues. Without Your PII, WhiteCrow through the Website cannot respond to You or ensure Your continued use of the Services.
5. To enforce Our terms, agreements or policies: WhiteCrow / Website process Your PII to actively monitor, investigate, prevent and mitigate any alleged or actual prohibited, illicit or illegal activities on Our Services; investigate, prevent, or mitigate violations of Our terms, agreements or policies; enforce Our agreements with third parties and partners; and as applicable, collect fees based on Your subscription to Our Services. WhiteCrow / Website cannot perform Our service in accordance with Our terms, agreements or policies without processing Your ‘Personal Data’ for such purposes.
6. To ensure the security of the Service: We are committed to ensuring Your safety and continued use of Our Services. To do so, WhiteCrow / Website processes Your PII to: (i) combat spam, malware, malicious activities or security risks; (ii) improve and enforce Our security measures; and (iii) to monitor and verify Your identity so that unauthorized users do not access Your account with the Website. WhiteCrow / Website cannot ensure the security of Our Services if WhiteCrow / Website does not process Your PII for security purposes.
7. To maintain legal and regulatory compliance: Certain laws or regulations apply to Our Services that may require WhiteCrow / Website to process Your PII. For example, WhiteCrow / Website may process Your PII to fulfil Our business obligations as necessary to manage risk as required, under applicable laws. Without processing Your PII for such purposes, WhiteCrow / Website cannot perform the Services in accordance with Our legal and regulatory requirements.
8. To personalize Your experience on the Service, WhiteCrow / Website provides You with third-party services, plugins and many other options to personalize Your experience on Our Service. In addition, by personalizing the Service, You get to enjoy Our Services even more because WhiteCrow / Website keeps track of Your preferences (e.g., Your language selection, Your time zone, etc.) and connect all Your favorite third-party services to Our Service. Without processing Your PII for such purposes, You may not be able to access or personalize part or all of Our Service.
9. In addition to the above, WhiteCrow / Website may use Your PII for the following purposes also:
  - Operate, manage and improve the Services.
  - Communicate with You about Your Website’s account, Your interactions with the Services or Your contacts’ interactions with the Services.
  - Protect the rights or property of WhiteCrow or third parties.
  - To provide You with alerts and other notifications/notices concerning Our Services or events or news, that may be of interest to You.
  - To improve the Website and present its contents to You.
  - For testing, research, analysis and product/Service development.
  - As necessary or appropriate to protect the rights, property or safety of WhiteCrow / Website, the Employer Candidate/ customers or others.
  - To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by WhiteCrow / Website is among the assets transferred.
International Transfer of Collected Information:
1. To facilitate Our global operations, WhiteCrow / Website may transfer and access PII from around the world, including from countries other than those where WhiteCrow has operations.
2. If You are visiting the Website from the regions with laws governing data collection and use, please note that You are agreeing to the transfer of Your PII to India and other countries and jurisdictions. By providing Your PII, You consent to any transfer and processing in accordance with this Policy.
3. We have put in place appropriate safeguards to ensure that Your data is only transferred to jurisdictions with enforceable data subject to rights and effective legal remedies in respect of data privacy breaches.
4. For detailed information with respect to the safeguards and disclosures on behalf of WhiteCrow subject to Section 4.3 above, the Employer Candidate can refer to the CCPA and GDPR Addendums to this Policy, available on the Website.
5. Webbtree use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements.
  Note that apps distributed on Google Play are also subject to the Google Play Developer Distribution Agreement.
Disclosure:
1. Subject to the provisions of the CCPA Addendum, WhiteCrow / Website do not sell Your PII to anyone for any purpose and WhiteCrow / Website maintains information about You in Our business records while You remain an active subscriber to Our Services on the Website. WhiteCrow / Website have implemented encryption or other appropriate security controls to protect PII when stored or transmitted by WhiteCrow / Website. WhiteCrow / Website may provide PII to third parties to the extent and in the manner as stated in this Policy.
2. Please see below the disclosure focus:
  - Service Providers, Business Partners and Others: WhiteCrow / Website uses certain trusted third-parties (as stated in Section 3.1, above) to help WhiteCrow / Website provide, analyze and improve the Services (including but not limited to data storage, maintenance services, database management, web analytics, security, payment processing and improvement of the Service’s features).
  - Compliance with laws and law enforcement requests and protection of WhiteCrow’s rights: WhiteCrow / Website may disclose files stored in Your account and other information about You to third parties when We have a good faith belief that disclosure is reasonably necessary to: (a) comply with a law, regulation or legal requests including to meet national security or law enforcement requirements; (b) protect the safety of any person from death or serious bodily injury; (c) prevent fraud or abuse of WhiteCrow / Website or its subscribers; or (d) protect WhiteCrow’s property rights.
  - Business Transfers: If We are involved in a merger, acquisition or sale of all or a portion of Our assets, Your information may be transferred as part of that transaction, but WhiteCrow through the Website will notify You (in accordance with Section 14 (Miscellaneous) of the Terms and Conditions or by posting a prominent notice on the Website) of any change in control or use of Your PII.
Consent for receiving Promotional information:

If You opt/subscribe to receive marketing/promotional or informational announcements from WhiteCrow / Website, such emails will include the capability to opt-out of receiving such e-mails in the future. Marketing/promotional and informational announcements include any communications to You that are only based on advertising or promoting products and services of WhiteCrow. Transactional communications about Your account or the Services are not considered “marketing”, “promotional” or “informational” communications.
Compliance with Laws and Law Enforcement Requests:

In certain circumstances, WhiteCrow / Website may be required to disclose PII in response to lawful requests by public authorities, including to meet national security and law enforcement requirements. WhiteCrow / Website may disclose PII in response to subpoenas, court orders, or legal process, or to establish or exercise Our legal rights or defend against legal claims. WhiteCrow / Website may also share such information if We believe it is necessary in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Our Services or as otherwise required by law.
Your Controls:
1. You can review and correct Your PII collected by WhiteCrow / Website. WhiteCrow / Website reserves the right to correct the information found to be inaccurate. The Employer Candidate may verify that appropriate corrections have been made. However, it may be noted that the Website, WhiteCrow, its employees, subsidiaries, affiliates and third parties shall not be responsible for the accuracy and/or authenticity of the information supplied by You. WhiteCrow hereby disclaims any and all liability arising out of or in connection with the accuracy and/or authenticity of the information.
2. WhiteCrow / Website processes and stores service data on behalf of the Employer Candidate. WhiteCrow / Website has no direct relationship with the individuals with whom the Employer Candidate may interact using the Services. If you are an individual interacting with an Employer Candidate subscribing to the Services and would no longer like to be contacted by that Employer Candidate, please contact the respective Employer Candidate directly.
  
  Webbtree uses candidate Personal Identifiable Information (PII) in its capacity as a data processor for all ATS customers. For all Webbtree Talent Source customers, Webbtree also co-owns the data. In line with GDPR regulations, we anonymise data of all European citizens, known to us directly or through inference after a period of 6 months.
3. Consent: By using the Website and/or subscribing to the Services, You consent to this Policy. In the event that You do not agree with and/or consent to the terms and conditions specifically set out herein and/or to the terms of the Agreement, please do not use or access the Website and the Services. You hereby acknowledge and agree that by mere use of the Website and Services, You expressly consent to WhiteCrow’s / Website’s collection, receipt, storage, processing, disclosure, transfer, dealing with and handling of the Employer Candidate’s data in accordance with this Policy throughout the Term / Subscription Term / Trial Subscription Term, as the case may be. You understand that, while Your account is active to use the Website and Services, the Website, WhiteCrow, its subsidiaries, affiliates and third parties engaged by it, may retain Your PII and use it in any manner in order to comply with its contractual obligations and other obligations under applicable laws. In the event that You wish to withdraw Your consent to WhiteCrow’s / Website’s collection, receipt, storage, processing, disclosure, transfer, dealing with and handling of the information, You may contact WhiteCrow in the manner stipulated in Section 14 (Miscellaneous) of the Terms and Conditions, informing WhiteCrow of Your withdrawal of consent to its use of Your information. You hereby acknowledge and agree that, in case You withdraw Your consent to WhiteCrow’s / Website’s use and disclosure of Your PII as provided for in this Policy, such action on Your end will result in the termination of the Agreement and consequently effect in deactivation of Your subscription to the Services, restricting Your right to access the Website and the Services, subject to Section 5.1 of the Terms and Conditions, wherein the Employer Candidate will have access to the Website for a duration of 15 (fifteen) days, solely with the intent to enable the Employer Candidate to access and retrieve its data.
Changes to this policy:

If WhiteCrow / Website is going to use Your previously collected PII in a manner materially different from that as stated in this Policy at the time of collection, such change will be notified by posting it on the Website and shall indicate the date of the last revision.
Children’s Privacy:

WhiteCrow / Website does not use the Services to knowingly solicit data from or market to children under the age of 18 (eighteen) years. WhiteCrow / Website requests that such individuals do not provide PII through the Services. If a parent or guardian becomes aware that his or her child has provided WhiteCrow / Website with information without their consent, he or she should promptly contact WhiteCrow and WhiteCrow will take reasonable steps to ensure that such information is deleted from WhiteCrow’s / Website’s files.
Data Security, Integrity and Retention:
1. Security: WhiteCrow / Website will protect the Employer Candidate’s PII from unauthorized access, use or disclosure. Whenever the Employer Candidate changes or accesses its account information, WhiteCrow / Website offers the use of a secure server. Once Your information is in WhiteCrow’s / Website’s possession, WhiteCrow / Website adheres to strict security guidelines, protecting it against unauthorized access. WhiteCrow / Website have implemented physical, technical and administrative security measures for the Services that comply with applicable laws and industry standards. For example, WhiteCrow / Website uses firewalls, encryption technology and other automated software designed to protect against fraud and identity theft.
2. Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. All decisions which are made in the course of Our business processes involve human intervention. We do not therefore, expect to make any decisions about You using automated means.
3. WhiteCrow / Website will ensure, to the best of its ability, the security of the Employer Candidate’s Sensitive Personal Data or Information (“SPDI”), provided by the Employer Candidate during the Term / Subscription Term / Trial Subscription Term, as the case may be.
4. When an Employer Candidate downloads and uses an app or website that requests WhiteCrow to provide the Services, WhiteCrow / Website may collect and process information locally on the Employer Candidate’s mobile or desktop device. This allows WhiteCrow / Website to identify the sensitivity level of certain device information prior to transferring it to Our servers for storage. Rather than sending sensitive device information as raw data that can be easily associated with the relevant Employer Candidate, WhiteCrow / Website only transfer representations of certain types of information back to WhiteCrow / Website. Our servers then associate the representations with a unique identifier assigned to each Employer Candidate by the Website. When an Employer Candidate subsequently interacts with the Services, this process allows WhiteCrow through the Website to provide the Services without storing the sensitive information in a form that would be easily readable to unauthorized third parties.
5. The Website also protects Employer Candidate’s privacy by seeking to minimize the amount of sensitive data that WhiteCrow / Website stores on Our servers in the first place. You may also contact WhiteCrow anytime with Your questions or concerns.
6. Upon expiry or pre-determination of the Agreement, WhiteCrow / Website will: (i) retain WhiteCrow’s data sourced from the Services provided on the Website for reasonable time or as per the internal policy; and (ii) within 7 (seven) working days of such expiry or pre-determination, provide to the Employer Candidate, with a copy of the information directly shared by the Employer Candidate in accordance with Section 5.4 of the Terms and Conditions.
7. You acknowledge that all information, data, text, software, documents, music, sound, photographs, graphics, videos, messages, tags or other materials (“Content”), whether publicly posted or privately transmitted, are the sole responsibility of the person from whom such Content originated and that You, and not WhiteCrow / Website, is entirely responsible for all Content that You upload, post, email, transmit or otherwise make available via the Services. You understand that by using the Services, You may be exposed to Content that is offensive, indecent or objectionable. Under no circumstances will WhiteCrow or its parent, holding, subsidiary or related companies, affiliates, officers, agents or employees, as the case may be, be liable in any way for any Content or any loss or damage, no matter the cause of the loss or damage, of any kind incurred as a result of the use of the Services.