1. Career Ear Limited, trading as Earlybird, (We/Us) is committed to protecting and respecting your privacy.
2.1 Career Ear website application software (CareerEar App) whether available on our site or hosted on any server or any mobile application platform (App Site) and Earlybird application software (Earlybird App) on any App Site. The CareerEar App and Earlybird App will be together referred to as "App".
2.2. Any of the services (Services) accessible through the App that are available on the App Site or other sites of ours (Services Sites) including but not limited to our newsletters.
3. This policy sets out the basis on which any personal data we collect from you, or that you provide 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.
4. Career Ear Limited (trading as Earlybird) is registered for data protection with the UK Information Commissioner’s Office under registration number ZA692231 and observes the rules of the Data Protection Act 1998.
5. We are the Controller in respect of your personal data for the purposes of applicable data protection laws (including the EU General Data Protection Regulation 2016/679 – “GDPR”).
6. Our full name: Career Ear Limited (registered in England and Wales under company number 11479497).
7. Our contact details: firstname.lastname@example.org
8. This Privacy Notice was last updated on 10 March 2023.
9. We are collecting your personal data for the following purpose(s):
9.1 To communicate with you on anything related to the App and to ensure that you can use the App;
9.2 To better understand your experience of the App and how it can be improved;
9.3 To communicate with you on anything related to Us (this is usually in the form of our newsletter but from time to time will involve other e-mail communications (e.g. if we want to reach out for your support to vote for us in an award or if we have a fantastic opportunity to share with you that cannot wait until our newsletter comes out));
9.4 To invite you to events and provide you with other opportunities and information relating to us and our associated services through the CareerEar App;
9.5 To provide you with relevant curated content in line with our purpose to help our users to achieve their career aspirations through the CareerEar App;
9.6 Direct Marketing - We may make use of the personal data We have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience through the CareerEar App;
9.7 To share your personal data with the organisation that is supporting you and referred you to use our App.
10. We do not disclose information about identifiable individuals to our advertisers, but We may provide them with anonymous aggregate information about our users (for example, We may inform them that 200 men aged under 25 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW4).
11. We may collect and process the following data about you:
11.1 Information you give us (Submitted information): You may give us information about you by filling in forms on the App, App Site and the Services Sites (together Our Sites) whether by text or voice, or by corresponding with us (for example, by e-mail or chat). This includes information you provide when you register to use the App or App Site, subscribe to any of our Services, use the App, search for an App or Service, share data via an App's social media functions, enter a competition, promotion or survey, and/or when you report a problem with an App, our Services, or any of our Sites. The information you give us may include your name, address, e-mail address and phone number, the Device's phone number, age, username, password and other registration information, financial and credit card information, personal description and photographs.
11.2 Information we collect about you and your device. Each time you visit one of our Sites or use one of our Apps we may automatically collect the following information:
11.2.1 technical information, including the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use and time zone setting (Device Information);
11.2.2 details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access (Log Information).
11.3 Information we receive from other sources (Third Party Information). We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
11.4 If you contact us, we may keep a record of that correspondence.
12. The legal basis for processing your personal data:
12.1 by signing up to any of the Services, you give us your explicit consent to the processing of your personal data for one or more specific purposes;
12.2 processing may be necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract; and/or
12.3 processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data.
12.4 if you are referred to our platform by a third party organisation with whom we are partnered with, whether now or in the future, you explicitly consent to us providing that third party organisation with information about you and your usage of the App and this consent can be withdrawn by you at any time subject to any agreement you have in place with that third party organisation and any legal obligations we owe to that third party organisation.
13. The legitimate interest referred to in paragraph 12.3 above is to ensure that you can use the App and other Services, that we are able to operate in accordance with our purpose (i.e. supporting people with career aspirations, particularly those from underrepresented groups), and that we understand you so that we can provide you with opportunities, personalise your experience and measure our impact.
14. The recipients or categories of recipients of your personal data may include:
14.1 any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.
14.2 disclosure of your personal information to third parties:
14.2.1 In the event that We sell or buy any business or assets, in which case We may disclose your personal data to the prospective seller or buyer of such business or assets.
14.2.2 If Career Ear Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
14.2.3 If We are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
14.2.4 If you have been referred to use our App or Services by a third party then you accept that we will provide that third party with your personal information and data so far as it is relevant to our agreement with that third party.
14.2.5 In order to:
b) protect the rights, property or safety of Career Ear Limited our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
14.3 We may collect and store personal data on your Device using application data caches and browser web storage (including HTML 5) and other technology.
15. Where We have given you (or where you have chosen) a password or code that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share your password or code with anyone.
16. Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to Our Sites; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.
16.1 When using the CareerEar App and interacting with other users, please ensure that you do not submit any personal data that you do not want to be seen, collected or used by other users of the App or App Site.
17. If we intend to transfer your personal data outside of the European Economic Area, it is to the US (where we may use cloud services) which is subject to a finding of adequacy by the European Commission and standard data protection clauses have been put in place.
18. The personal data will be stored for as long as you retain your account or until such time as you opt out of our newsletter (CareerEar App only) whichever is the later. If either of those steps are taken (as the last step of your relationship with Us), we will endeavour to delete all information that we hold within 90 days of that step being taken.
19. You have the right to request from us access to and rectification or erasure of personal data or to restriction of processing concerning you or to object to our processing of the data as well as the right to data portability.
20. If we are relying on your consent to process data, you may withdraw your consent at any time by notice to us.
22. For more information on the usage of cookies by Google Analytics please see the Google website. A link to the privacy advice for this product is provided here for your convenience - http://www.google.com/analytics/learn/privacy.html
23. You have the right to complain to the Information Commissioner's Office about the manner in which or otherwise in respect of the manner in which we process your personal data.
24. Your provision of personal data to us is required to use our Services through our Apps. If you do not supply your personal data to us, we will be unable to service you through any of our Apps.
25. We use automated decision-making processes, including profiling, by selecting you based on information that you have provided to us, to be invited to events or be provided with details of specific opportunities from us or our partners (without sharing your data with those specific partners).