Last updated: May 21, 2018
1.1 The ALFC Entities Responsible for Your Information
All references to Candidate and Employer are defined as provided for in the ALFC Terms of Service
Employer Families will be referred to us “Employer”.
1.2 Personal Data and Non-Personal Data
2. Information Collected
You provide different types of information in order for ALFC to provide our services, products and features to you.
2.1 Information You Provide to ALFC
2.1.1 From Your Account
We collect data from you when you create an ALFC account, request information, subscribe for a service, participate in a survey, post a rating or review, post a question or answer, post a CV, complete an ALFC Assessment, upload content or otherwise actively send us data on our Site. This may include, but is not limited to, your user name, password, first and last name, email address, telephone number (including mobile phone number), street address, gender, occupation, interests, messages you send to users, and any other data included in a submitted profile or CV, including but not limited to application materials and answers to screener questions submitted to Employers through ALFC and answers you give to any questionnaires sent to you, which you answer.
2.1.2 Through Your Activity on ALFC
In addition, as part of the standard operation of the Site, ALFC may collect and analyse information from your computer or mobile device and actions taken on the Site, including, but not limited to, your CV, your searches on ALFC, the titles of jobs you search, click on or apply to, where those jobs are located, salary or the experience level of the jobs you view (where indicated), your activity time on the Site and each page, page views, clicks, taps, session activity, browser type, operating system, type of device, MAC address, IP address and the domain name from which you accessed the Site.
2.1.3 When Using Automated Phone Screening
2.1.4 When Providing Employer Information
If you are an Employer, ALFC may request that you provide certain Personal Data to ALFC in order to verify your account. This information may include but may not be limited to, forms of Identification such as a utility bill or ID number. Other details may include and not limited to telephone numbers and email addresses.
This information will be used for internal purposes only, subject to any request by law enforcement or a court order. In connection with chargeable services, we will also collect payment information (e.g., the last four digits of credit card numbers and related verification information). Please note that ALFC only has access to the last four digits of Employer credit card numbers, and does not store full credit card numbers.
2.2 Information Collected When You Apply for Jobs or Access ALFC from Some Third-Party Websites
2.2.1 When You Apply to Jobs on Some Third-Party Sites
ALFC may also collect information about websites and web pages you visit through our mobile software or while using ALFC for Chrome and this may include third-party sites and web pages. We only do this in order to allow a Candidate to keep a record of particular Job Listings of interest, to detect a job application form on a third-party website to give a Candidate the option to auto-fill parts of the form using ALFC CV.
2.2.2 When You Log In or Use ALFC from Some Third-Party Sites
You may also create an account or log in to your ALFC account using third-party websites including, but not limited to, Facebook or Google. If you do not already have an ALFC account but log in to ALFC using your Facebook or Google account, this creates an ALFC account using the same email address used in your Facebook or Google account. If you agree to provide this information to ALFC, Facebook or Google will authenticate you and redirect you to ALFC’s Site. Please note, when you log in to ALFC using your Facebook or Google account, Facebook or Google will cookie you in order to authenticate you as a Facebook or Google user.
By accessing ALFC through your Facebook or Google account, you understand that Facebook or Google will share certain data detailed above in this paragraph for the purposes of authentication to permit you to access our Site in a secure manner. You may stop this at any point from your Facebook or Google account. This information will be considered ALFC account information for purposes of your use of the Site.
You have the ability to disable the connection between your Facebook or Google account and your ALFC account at any time by accessing your privacy settings on your Facebook or Google account. Facebook may also ask for your permission to share certain other details with ALFC, including but not limited to your name, profile picture, public profile information, and email address. For those users that avail of ALFC Family specifically, Facebook may ask for permission to share your friends list, and ALFC may use some of this data to connect you with other users of ALFC Family.
PLEASE NOTE THAT YOUR RELATIONSHIP WITH FACEBOOK OR GOOGLE OR ANY OTHER THIRD-PARTY WEBSITE IS GOVERNED SOLELY BY YOUR AGREEMENT WITH SUCH THIRD-PARTY WEBSITE.
2.3 Any Other Personal Data ALFC May Receive from Third Parties
2.4 Storage of Your Information
2.5 What Personal Data is required
ALFC will indicate to you at the point of provision as to whether or not particular Personal Data provided by you is required in order to provide particular ALFC services or features to you. Where Personal Data that is required is not provided by you then the particular feature or service may not be available to you.
2.6 The Legal Basis on Which ALFC Collects Your Personal Data
ALFC collects and processes your Personal Data on the basis of different legal grounds, depending on the nature of the Personal Data being provided and the type of processing involved. More information is provided on this here.
– Performance of
Most of the Personal Data processed by ALFC is performed on the basis that it is necessary for the performance of our agreement with you, or in order to take steps at the request of the user prior to entering such an agreement. An example of this would be where ALFC matches Candidates with Employers.
– Legitimate Interest
A second ground relied upon by ALFC for other types of processing of your Personal Data is that it is necessary for the purposes of legitimate interests pursued by ALFC. Such legitimate interests will include where ALFC sends you marketing about our products and services, where we believe you have a reasonable expectation that we will perform a particular type of processing on your behalf, or where such processing is strictly necessary for fraud detection and prevention. ALFC will only rely on such a ground where an assessment has been performed balancing the interests and rights involved and the necessity of the processing in order to provide our services, products and features to you.
– Compliance with a Legal Obligation
A third ground relied upon for certain type of processing is that it is necessary in order to allow ALFC comply with a legal obligation. An example of this would be where ALFC is required to retain business records for fixed periods of time in order to comply with local legal requirements.
Finally, in certain limited situations, ALFC relies on your consent in order to process your Personal Data. Where ALFC requires your consent in order to collect and process certain Personal Data, we seek your consent at the time of provision, and such processing will only be performed where consent is secured.
3. Limitation of Use or Disclosure of Personal Data
3.1 Where a Candidate Wants to Close an Account
When a Candidate closes an account, the Candidate will no longer have access to any of the data we make available under that account name, including but not limited to, search history, job search preferences, saved jobs, jobs the Candidate has applied to, job alerts, CV, and any other data associated with the account. If the Candidate uses the same email address to set up a new account, this data from a previous account will not become available to the Candidate again. Please also note that closing your Candidate account may result in you losing access to all ALFC products and the ability to utilise the “Log in with ALFC” feature found on certain third party sites.
ALFC reserves the right to keep any materials in a closed account as necessary to preserve and protect its rights to the extent permitted by law (for example, to preserve records of a dispute) or to comply with its obligations under local law (for example, if requested to retain by law enforcement). A closed account does not mean that all of the data is expunged from the ALFC systems, although it will not be readily available under the Candidate’s original account name. When the Candidate presses the close account button on the dashboard, ALFC will begin to process that instruction within 24 hours and will have completed the operation within 40 days.
3.2 Where an Employer Wants to Close an Employer Account
Employers may close an account at any time by contacting ALFC helpline. Please note that ALFC must preserve business records pertaining to that account to comply with its obligations under law.
3.3 Where a Candidate Wants to Delete a Job Application
For job applications which you, the Candidate submit through ALFC to an Employer, (with related materials submitted), please note:
1) that your applications and materials will be controlled by an ALFC;
2) we may direct you to that Employer for Personal Data deletion requests where that Personal Data is held by that Employer;
3) ALFC depends on the Employer to provide ALFC with the correct destination for all applications.
3.4 Where the Employer Contact Details Provided to ALFC Are Incorrect
In the event that the electronic destination provided to ALFC is incorrect, your application materials will not be sent to the intended recipient of the application. ALFC has no liability for such applications. If you do not wish to send your application materials in this manner, you should send them directly to the Employer.
3.5 Minimum Age of our Users
ALFC limits its processing of Personal Data to users that are of a legal working age, and adopts a range of measures to try to ensure that we do not accept such users. Legal working age levels vary in different countries. Consequently, ALFC may vary this minimum age, as required, to comply with any applicable local laws.
4. Purposes, Uses and Disclosures of Information
1) Provide our services, products and features to you, to help Candidates find jobs and Employers find candidates;
2) To measure and improve those services, products and features; and
3) To protect our users and provide them with customer support.
More detail on these purposes, uses and disclosures of your information is set out below.
4.1 Creating an Account, Sending You Job Alerts and Other Promotional Materials
If and to the extent permitted by applicable law, ALFC may use your contact information to (i) create an account; (ii) send you job alerts; and (iii) send you information about ALFC, including promotional materials. ALFC may use third-party partners to perform these activities on ALFC’s behalf.
A job alert is defined as an email sent to you that you sign up for containing Job Listings in response to a search query you have run (“Job Alert”). Job Alerts may also include jobs that ALFC recommends for you, ALFC Targeted Ads or other actions you may want to take on the Site.
ALFC may also share your information with third parties (including operators of third-party websites and/or social networking sites) in order to show you targeted advertisements and other content that has been customised for you. Such advertisements will only relate to ALFC’s services, products, and features, all of which focus on helping Candidates find jobs and Employers find candidates. If you wish to opt out of receiving any marketing messages from ALFC please contact ALFC.
4.2 Giving You Relevant Search Results and Recommended Jobs
In order to optimize our services, products and features for you, ALFC may use your previous search and browsing history (e.g. the jobs you click on), or application materials and answers to screener questions, to identify you and determine relevant search results and provide you with recommended jobs or reach out to you about jobs you may be interested in. We may also use demographic and/or profile data to tailor your experience on the Site, to show you content that ALFC thinks you may be interested in, and display content according to your preferences.
4.3 Your Contact Information
When you give ALFC contact information (such as your name and email address) and other forms of Personal and Non-Personal Data, you agree that ALFC may utilize this information for the purposes outlined in sections 4, 5 and 9, to the extent applicable. In particular, you agree that ALFC may, as part of its services to you, communicate with you, or initiate communication with you on behalf of a third party, through your ALFC account or through other means such as email, telephone (including mobile phone), or postal mail, including through the use of contact information that you may provide to ALFC or that ALFC may otherwise obtain from third-party resources.
4.4 Your CV Information
Your information, including Personal Data, gets placed on the Site when you upload or edit a CV. ALFC reserves the right to charge third parties a fee for accessing your information, including Personal Data, strictly as part of ALFC’s services. At your direction, ALFC may also send your CV to third parties if you choose to apply for a job listing. The extent to which your information is made available to third parties depends on the privacy settings you choose on ALFC. When a Candidate creates a CV on ALFC, they automatically consent to ALFC sharing their information with the Employer. CVs posted to ALFC are considered to be private. This is detailed below.
– Private CVs
Private CVs are only made available to those to whom the Candidate has initiated an application or provided their CV. Where this occurs, you make your CV, your name and other Personal Data that you place on your CV available to third parties. Those third parties may be interested in you as an employee, and may forward your CV to other third parties. The option to post publicly accessible CVs to help with finding you a job will be available in due time and appropriate communication will be made and an option provided to Candidates to opt in or out.
– Public CVs
Public CVs are available to anyone with access to ALFC’s CV search application, in order to increase the visibility of that CV and help ALFC find you a job. Where this occurs, you make your CV, your name and other Personal Data that you place on your CV available to third parties. Those third parties may be interested in you as an employee, and may forward your CV to other third parties.
If you post a public CV, this may be crawled by, and displayed through search engines when someone searches for your name. This means that third parties can view the Personal Data contained in your CV and you may receive unsolicited contact from parties unaffiliated with ALFC and for whom ALFC has no responsibility. If you post a public CV on ALFC, please note that although ALFC expressly prohibits the scraping of its Site any CV you post publicly is public information and the content may be copied by a third party in violation of these terms.
For public CVs, you also authorise ALFC to remove your name from your public CV, in certain instances.
– Changing Your CV Privacy Settings
You will be given the option to make your CV private or public when you place your CV on ALFC. You may adjust this at any point by editing your privacy settings on ALFC. Where you adjust your CV from public to private, ALFC does not warrant how often third-party search engines will update their caches, which may continue to contain your CV information.
4.5 Matching Candidates With Employers
You acknowledge that ALFC may determine whether the words of your CV or any other individuals’ CV match the words of certain job descriptions, and vice versa, in order to improve the Site or any other ALFC product or service (including by displaying or otherwise making available potentially relevant job descriptions and CVs to Candidates and Employers).
If you have an ALFC account or an ALFC-hosted CV, you agree that ALFC may contact you or suggest you or your public CV to Employers that might be interested in a person who matches your behaviour on ALFC.
In addition, if you are located in the United Kingdom and you set your CV to public, this means that ALFC may share all of the aforementioned information about yourself with any other recruiters working for or on behalf of Employers. If you do not wish to share such information, you may set your CV to private.
4.6 Sending You Text Messages about Employer Appointments
ALFC may offer you the opportunity to receive a text message from ALFC when an Employer has scheduled an interview or event with you or responded to your application. By entering your phone number you are representing and confirming it is your number and you have the right to accept text messages at the number. ALFC will only send you a text message reminder for such interviews or messages through ALFC’s official numbers, and you agree to accept such text messages on your mobile phone. To unsubscribe at any time, please contact ALFC
4.7 Preventing Fraud and Spam
For example, in any unlikely event that ALFC is subject to the investigatory, enforcement and regulatory bodies such as Data Protection Commissions.
We may use a variety of methods to detect and address anomalous activity and screen content to prevent abuse such as spam or fraud. However, such detection methods are not perfect and false positives may occur. These efforts may on occasion result in a temporary or permanent suspension or termination of some functions for some users.
– Preventing Fraud and Spam in Messages
ALFC reserves the right to conduct investigations to determine whether you are perpetrating a scam, spamming ALFC or its users, or otherwise conducting fraudulent activity on ALFC by various means, including but not limited to investigating your functionality by setting up profiles and names that belong to ALFC. ALFC also reserves the right to turn over any information gathered via such investigations to the police or other third party if ALFC has a good faith belief that you are using the Site in violation of these terms.
4.8 Facilitating Payment
If you provide credit, debit or other payment card and related details to us in order to make a payment, ALFC will use such information only for the purpose of processing the payment (e.g., the last four digits of credit card numbers and related verification information).
4.9 Automated Processing of Your Personal Data
In order to optimise the performance of the ALFC Site and services for users, ALFC performs automated processing of Personal Data evaluating certain specific aspects relating to a user, in particular to analyse or predict aspects concerning a user’s personal preferences or interests in terms of ALFC’s Site and services. Where it occurs, such processing is carried if it is necessary for the performance of our agreement with our users, to allow ALFC to provide its services to Candidates and Employers, or in other cases on the basis of a user’s consent.
4.10 Transfer of Information to ALFC Affiliated Entities
Any information shared by you with ALFC may be shared with or transferred to any ALFC affiliated entity (including our Haggios shop site.), no matter where located, for the purpose of providing you relevant services and improving the Site.
Such transfers are performed in full compliance with applicable data protection rules and subject to appropriate safeguards, primarily through the use of extensive data protection agreements, in order to ensure adequate protection of users’ Personal Data. The services provided to you and the functionality of the Site could not be provided without such a transfer. If you do not wish your information to be transferred in this way you should contact ALFC.
4.11 Transfer of Information to Third Parties
– Transfers to Employers
Employers agree to comply with all their responsibilities under applicable data protection rules with respect to the collection, processing and storage of Personal Data, as well as providing adequate protection of all data subject rights provided for under all applicable data protection rules.
– Transfers to Service Providers and Vendors
We may use third parties to perform services in connection with our operations, to improve the Site and our services, products and features, and to protect our users. These third parties may include (but are not limited to) service providers and vendors.
ALFC may also transfer your Personal Data in limited situations to certain third-party vendors that assist ALFC with protecting our users and maintaining the quality of our services, products and features provided to those users. An example would be vendors ALFC uses for fraud detection purposes.
– Transfers to Cloud Service Providers
Please also be aware that we may also use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that may be nonnegotiable; these service providers have informed us or the general public that they apply security measures they consider adequate for the protection of information within their system, or they have a general reputation for applying such measures. However, we will not be liable (to the fullest extent permitted by law) for any damages that may result from the misuse of any information, including Personal Data, by these companies.
– Transfers of Publicly Available Information
When users post content on ALFC in a manner that is intended to make that content publicly available and searchable by individuals, ALFC reserves the right to aggregate and share that information with third parties. For example, if a job is posted on ALFC, ALFC may share that job posting or information contained within that job posting with third parties, at ALFC’s discretion and subject to agreement between ALFC and any such third parties. ALFC also reserves the right to share information aggregated from public sources in this capacity.
– Third-Party Sites You Link to from ALFC
– Transfers of Personal Data for individuals in the EU
5. Additional Uses and Disclosures of Non-Personal Data
ALFC seeks to use reasonable security measures to help protect against the loss, misuse and alteration of the Personal Data under ALFC’s control. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. In addition, please note that emails, messages sent via your web browser, and other similar means of communication with other users, are not encrypted. Therefore, while we strive to protect your information, we cannot guarantee its security.
8. Links to Third-Party Sites
The Site may make available links to other websites. When you click on such links, you may leave our Site. The Site may also make available Company Pages, which may contain information provided by third-party Employers.
WE ARE NOT RESPONSIBLE FOR THE INFORMATION COLLECTION, USE, DISCLOSURE OR OTHER PRIVACY PRACTICES OF ANY THIRD PARTY, INCLUDING OUR AFFILIATES, THIRD-PARTY SERVICE PROVIDERS, ANY EMPLOYERS (INCLUDING ANY EMPLOYER THAT PROVIDES A COMPANY PAGE), ANY THIRD-PARTY SOCIAL MEDIA PLATFORM, ANY THIRD PARTY MAKING AVAILABLE THE DEVICES OR OPERATING SYSTEMS FOR WHICH THE SITE IS AVAILABLE, AND ANY THIRD PARTY OPERATING ANY WEBSITE TO WHICH THE SITE CONTAINS A LINK. YOU MAY HAVE RIGHTS DIRECTLY ENFORCEABLE AGAINST THESE THIRD PARTIES SO YOU SHOULD CONSIDER THEIR PRIVACY POLICIES TO LEARN MORE.
9. Acquisitions and Other Reorganisations
10. Exercising Your Rights With Respect to Your Personal Data
ALFC users that provide their Personal Data in the EU, and those that provide their Personal Data in any other jurisdictions that adopt laws affording equivalent protections to those in the EU, may avail of the rights detailed below.
10.1 The Right to Rectify Your Personal Data
ALFC users are able to edit and update most of their Personal Data held by ALFC on the Site, and if you have any queries or complaints we encourage you to contact us.
10.2 The Right to Object to or Restrict the Processing of Your Personal Data
If you have any queries or complaints about how we process your Personal Data we encourage you to contact us contact us. Alternatively, if you do not wish to do this you may make a formal request to object to, or restrict, processing of your Personal Data by ALFC. In order to do so please send an email to firstname.lastname@example.org
10.3 The Rights of Access to and Portability of Your Personal Data
ALFC users are able to access most of their Personal Data held by ALFC on the Site, and if you have any queries or complaints we encourage you to contact us.
Alternatively, if you do not wish to do this you may make a formal request to access your Personal Data held by ALFC. In order to do so, please send an email to email@example.com stating that “I am requesting to access my personal data.” ALFC will provide your Personal Data to you in a portable format to allow it to be transmitted to third parties.
10.4 The Right to Delete Your Personal Data
ALFC users are able to edit and update most of their Personal Data held by ALFC on the Site, and if you have any queries or complaints we encourage you to contact us.
Alternatively, if you do not wish to do this, you may make a formal request delete your Personal Data held by ALFC. In order to do so, please email firstname.lastname@example.org the following sentence: “I am requesting to delete my personal data.” Once your request has been confirmed, ALFC will initiate the necessary steps to execute this exercise, including the deletion of your ALFC account. Where the deletion request relates to Personal Data that you previously requested be made public on ALFC (e.g. a Candidate posting a public CV), we will make reasonable efforts to inform any other controllers of this request.
PLEASE NOTE: by requesting the deletion of your Personal Data, you will no longer be able to create an account with ALFC using the same email address. If you simply wish to close your account, please click the “close my account” button in your account page.
10.5 Some Limitations
Such rights of rectification, objection, restriction, access, portability and deletion are subject to certain limitations, as provided for by applicable laws. Individual requests will be completed within the time allotted by relevant regulations, which starts to run from the point of ALFC confirming your request. Where permitted, please note there may be a charge for subsequent requests from the same individual, which will be determined by ALFC and only imposed to the extent permitted by applicable law.
11. Opting Out
If you no longer want to receive marketing materials from us based upon your Personal Data, going forward, you may opt out of receiving such marketing related messages by sending an email to email@example.com. Please note that we may still send other messages to you, such as administrative messages. We will comply with your request as soon as reasonably practicable, and in accordance with applicable laws.
12. General Inquiries and Complaints
12.1 Contacting ALFC
You may contact ALFC Ltd via our Site contact form. If you would like to contact ALFC’s Data Protection Officer, please send an email to firstname.lastname@example.org.
If you believe your data protection rights have been infringed by ALFC please contact the data officer by emailing email@example.com. You also have the right to complain to the Information Commissioners' office.