July 28, 2020
Breezy HR, Inc., and its group companies within the Learning Technologies Group (“we” or “us”) are committed to protecting and respecting your privacy and want you to know how we handle the information we receive via our website and through our online services.
This policy sets out the basis on which any of your personal data we collect from you, that you or our customer provides to us, either through our website at www.breezyhr.com (“our site”) or our Breezy HR Recruitment System (“the Subscription Services”), or as otherwise provided by you to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. For the avoidance of doubt, the Subscription Services are solely subject to our Terms of Service, as accessible at https://breezy.hr/terms, as may be updated from time to time, unless otherwise agreed by the parties in writing.
We are responsible for the operation of our site and the Subscription Services. Our corporate details are: Breezy HR, Inc., 1534 Oak St #301, Jacksonville, FL 32204, Tel. +1 844-927-3399. We are part of the Learning Technologies Group (www.ltgplc.com).
With regard to our site, the main data controller within the Learning Technologies Group (https://ltgplc.com/), which we are a part of, and which shall have access to any of your personal data processed by us, is LEO Learning Limited (company number 02371375), whose registered office address is: 52 Old Steine, Brighton, East Sussex, BN1 1NH, United Kingdom, +44 1273 728 686.
We collect and/or process the personal data of different categories of people across our site and the Subscription Services. The categories are:
Visitor – a person who is visiting our site and who may fill out forms at our site.
Administrator – a person who is a staff member of our customer and uses the administrative functions of our Subscription Services.
Applicant – means an individual who submits an application for a vacancy posted by one of our customers, which is processed in the Subscription Services.
If you are a Visitor, we will only collect the information that you provide to us by filling in forms on our site, providing us with your contact details, or by corresponding with us by phone, email, or otherwise. We maintain records of our correspondence for such period of time as we believe is reasonably required, except where you tell us otherwise.
When you are an Administrator for the Subscription Services, we will collect relevant information to set up your account, such as your name, company name, and email address to be able to provide the Subscription Services. We may also collect user data on the web pages and Subscription Services functionality that you access or visit as part of the Subscription Services to the extent required for the proper operation and functioning of the Subscription Services. This data is collected to deliver and improve our services.
If you sign up for a free Breezy HR trial account, you are not required to enter a credit card until you upgrade to a paid plan. Users of paid plans may be required to enter their credit card number. We use a third-party intermediary to manage credit card processing. This intermediary is not permitted to store, retain or use your billing information except for the sole purpose of credit card processing on our behalf.
When you submit a job application to one of our customers, some of your personal information may be collected by the Subscription Services. This information may include your name, email address, phone number, job history, CV and such other data as determined by our customer. We will not use this information for our own purposes, but our customer has access to this data for his or her own purposes and determines and controls how such information is used.
Where you require information on what information of yours is collected by account owners and customers of ours and for what purposes such data is used and processed, please contact the relevant account owner and customer of the Subscription Services.
Our site may use session and persistent cookies. The cookies placed by our servers are readable only by us, and cookies cannot access, read or modify any other data on your computer. We may use web beacons alone or in conjunction with cookies to compile information about your usage of our site and interaction with emails from us. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to our site, in order to improve our site and email communications.
Our site and the Subscription Services may contain links to other website including share and/or “like” buttons. These other website and services may set their own cookies on users’ computers, collect data or solicit personal information. You should refer to their cookie and privacy policies to understand how your information may be collected and/or used.
We use preference cookies to collect information about your choices and preferences, and to allow us to remember preferred settings and customize our site accordingly.
We also use analytics cookies to collect information about your use of our site, and to enable us to improve the way our site works. For example, analytics cookies show us which are the most frequently visited pages on our site, help us record any difficulties you have with our site, and show us whether our advertising is effective or not. This allows us to see the overall patterns of usage on our site, rather than the usage of a single person. We use the information to analyze the site traffic, but we do not use information to identify individuals.
We use Remarketing with Google Analytics to advertise online. Third party vendors, including Google, may show our ads on site across the internet.
We, and third party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on someone’s past visits to our website. Remarketing cookies used by us expire after 30 days. To opt out of Remarketing or to control your ad preferences, please click here.
Most web browsers have a “help” menu where you can review how to prevent your browser from accepting new cookies, how to have your browser alert you when you receive a new cookie or how to fully disable cookies on your browser. You can learn more about cookies at sites like www.aboutcookies.org. If you use your browser settings to block all cookies, you may not be able to access all or parts of our site.
Below are a list of cookies we use on our site:
We may use your information for the following general purposes:
We will keep a copy of your personal data for as long as you remain registered with our site, or, in case of the Subscription Services, for as long as determined by our customer, and thereafter for such period as may be required for our legitimate purposes and in compliance with any legal, audit and compliance requirements, provided that in certain cases as outlined below under “Your rights” we may delete such data on your request, and further provided that in regard to the Subscription Services, our specific Terms of Service with the relevant customer organization may include relevant specific provisions.
We use third-party vendors and hosting partners to provide the necessary hardware, software, networking, storage and other technology and services required to operate and maintain our site and the Subscription Services. As part of this, we may be required to transfer (some of) your personal information to these vendors and partners. A full list of the third party vendors used in the Subscription Services can be found at https://breezy.hr/third-party-vendors
Except as described in this policy, we will not share, give, sell, rent or loan any personal information to any third party, unless:
Our site may, from time to time, contain links to and from the website of our group companies, partner networks, clients, and/or affiliates. If you follow a link to any of these website, please note that these website are subject to their own privacy policies and that we do not accept any responsibility or liability for these site and policies. Please check those policies before you submit any personal data to these website.
If you make a purchase for the Application, you normally will be required to provide your payment details. These details will be made available in part to both the payment gateway and merchant bank involved. We ourselves will not receive and/or store your credit card details. More details can be found below.
We understand that the security of any data we process as part of you visiting our site and/or the use of our Subscription Services is of great importance to you and our customers. We therefore make sure it is well protected.
Although we (or our respective licensors) own the code, databases and rights in regard to the Subscription Services, you retain all rights to the data you provide to us. We maintain reasonable and appropriate security measures to protect your information from loss, destruction, misuse, unauthorized access or disclosure. These measures help ensure that your data is safe, secure, and only available to you and to those you provided authorized access. However, no data transmission over the internet or information storage technology can be guaranteed to be 100% secure. Although we will do our utmost best to protect your personal data, we cannot guarantee the complete security of your data transmitted to our site or otherwise gathered by us; any transmission and supply of personal data to us is therefore at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
We make sure that we only collect and process your data when we have a lawful basis to do so.
Where we operate our site and perform our marketing efforts, we determine and control the way in which we process your personal data. We in such case normally process your data on the basis of your consent and/or on the basis of our legitimate interests of promoting growing, and developing our business.
In other situations we normally act on behalf of a customer of ours and perform any related data processing on the basis of our legitimate interests of promoting, growing and developing our business and/or in order to perform our obligations under a contract between us and such customer. In such situations, the relevant customer and account owner is the controller of your data and determines its use.
We acknowledge and respect your rights as an individual. If you wish to exercise any of your lawful rights or have questions in this regard, please reach out to us via the contact details provided below.
You have the right to ask us not to process your personal data for marketing purposes. You may also choose not to receive publications or certain other communications from us by explicitly indicating so in the appropriate section of the Registration Form or by opting-out by phone, email or via direct marketing emails sent to you.
You may also have the right to ask us to provide you with data held on you, amend any inaccurate personal data held on you, and/or to delete such data. However you should be aware that if you request your details to be deleted, this will mean we will have no record of any opting out that you may have requested and that you therefore may receive unsolicited communications in the future. Where we are processing your information on behalf of our customer, you are generally required to exercise any such rights directly with our customer, being the organization or individual that determines the processing. To request, make changes to, or delete your data, email us at email@example.com
Under California Civil Code sections 1798.83 – 1798.84, California residents who have an established business relationship with us are entitled to ask us for a notice describing what categories of personal customer information we share with third parties for those third parties’ direct marketing purposes and to opt-out of sharing your personal information with third parties for direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties with which it was shared, along with their names and addresses. If you choose to opt-out or would like a copy of this notice, please submit a written request to firstname.lastname@example.org. Please allow 30 business days for a response.
In accordance with the Children’s Online Privacy Protection Act (“COPPA”) and the GDPR, our site and the Subscription Services are not intended for use by children and we do not knowingly request, solicit, access or receive personally information (as defined in the COPPA and GDPR Respectively) from anyone under the age of 13 and 16 respectively.
Whilst this is not our intention, the Subscription Services could be used to collect personal information from children under the age of 13 or 16. Where you make use of the Subscription Services to collect such personal information, you become an “operator” under COPPA and it becomes your obligation as our customer to comply with the relevant requirements of the COPPA and/or the GDPR, as applicable (and any other applicable laws and regulations).
While it is your responsibility, not ours, to ensure compliance with COPPA and the GDPR where you act as our customer and determine the data collection and processing, in the event we have actual notice that you have collected personal information in violation of COPPA and/or the GDPR, we will require you to comply with COPPA and/or the GDPR, and we may delete any violating personal information you are processing without notice.
We have appointed Leo Learning Limited (“LEO”), one of our group companies, to act as our designated representative within the EEA for the purposes of Art. 27 of the GDPR.
The corporate details of LEO are: Leo Learning Limited, 52 Old Steine, Brighton, East Sussex, BN1 1NH, United Kingdom. Its corporate website is www.leolearning.com.
To ensure our compliance, LEO is mandated to be addressed in addition to, or instead of us, by supervisory authorities and data subjects with any issues related to our processing of personal data. This designation is without prejudice to legal actions which could be initiated against us. You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.
When you access and use the Subscription Services as a user, you are subject to the Breezy HR, Inc. Terms of Service, or such other Subscription Services agreement we have entered into with your relevant customer organization.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Breezy HR, Inc. is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.
Pursuant to the Privacy Shield Frameworks, EU, UK and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information it holds about you. You may also correct or amend incorrect data, or request deletion of personal information that has been processed in violation of the Privacy Shield Principles. However you should be aware that if you request your details to be deleted, this will mean we will have no record of any opting out that you may have requested and that you therefore may receive unsolicited communications in the future. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to email@example.com. If requested to remove data, we will respond within a reasonable timeframe.
We will obtain your consent before we share your data with third parties other than our above listed Third Parties, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to firstname.lastname@example.org.
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Breezy HR, Inc.’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Breezy HR, Inc. remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless Breezy HR, Inc. proves that it is not responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, BreezyHR, Inc. commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union, UK or Swiss individuals with Privacy Shield inquiries or complaints should first contact us by email at email@example.com.
Breezy HR, Inc. has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/privacy-shield-complaints/ for more information and to file a complaint. This service is provided free of charge to you.
BreezyHR, Inc. has further committed to cooperate with EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EEA and the UK in the context of the employment relationship. EU and UK individuals with HR complaints should refer to https://edpb.europa.eu/about-edpb/board/members_en for the list of Data Protection Authorities. Complaints related to human resources data should not be addressed to the BBB EU PRIVACY SHIELD.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction
We disclaim all liability related to your collection and use of personal information through the Subscription Services.