Privacy and Cookies policy
- the collection of information on Users of the Website;
- for what the information collected is used;
- how such information is processed and used;
- with whom the information collected is shared and on what basis is shared;
- rights of Users in relation to information collected on Users; and
- how the information collected is stored and secured.
|“CCPA”||California Consumer Privacy Act 2020|
|"Content"||Any and all images, text, information, data, audio, video, graphics, computer code, software, algorithms and other material provided on or through the Website and the Services.|
|“Cookie”||Cookies are tiny files which contain slivers of data and information, which may or may not include, an anonymous unique identifier in relation to whom the cookie is directed. It is a tiny file of text that a website transfers and stores on your device with the purpose of tracking your movements within the Website and your interaction with the various components and features of the Website. These files facilitate to improve and enhance the user’s Website experience and record their preferences. Cookies on the Website do not seek to control the devices on which they are stored and nor are they damaging, and nor do they extract your personal information from your device. The cookies will reside on your device(s) until they expire or are deleted by You.|
|“Employer”||Any person or business entity, whether incorporated or not, that registers an account on the Website as an Employer and posts details of a remote offsite job vacancy on the Website whether on their own behalf or on behalf of one or more third parties.|
|“GDPR”||Regulation (EU) 2016/679 General Data Protection Regulation|
|“Intellectual Property”||Intellectual Property of the SiteOwner as produced on the Website shall incorporate the entire content of the Website without exception and shall include, but is not limited to, all text, documents, information, data, articles, images, photographs, graphics, software, algorithms applications, video recordings, audio recordings, sounds, designs, features, trade name, service mark, trade dress, logo, custom graphics or icons and other materials that are or may become available on the Website after the effective date of this TAC and it is hereby declared that the entirety of the Intellectual Property is the sole and exclusive property of the SiteOwner.|
|“JobSeeker”||Any person who registers an account on the Website as a JobSeeker and who may apply for one or more job vacancies posted on the Website by Employers.|
|“Minor”||Any person below the age of 18.|
|“Offer”||The offer made by the Employer to purchase one or more services and/or items displayed by the SiteOwner for sale on the Website by clicking on a ‘Post Job’ button.|
|“License”||The License granted by the SiteOwner to the User pursuant to Clause 18 of the TAC.|
|“Purchased Item(s)”||The Services and/or other items purchased by the Employer on the Website.|
|“Purchaser”||Any Employer who makes an Offer to purchase services and/or items from the SiteOwner.|
|“Registered User” or “You”||The person or legal entity who creates a user account on the Website as an Employer or as a JobSeeker by following the prescribed registration process in order to be able to use of the Website and the Services.|
|“Services”||Through the Website, the SiteOwner provides Registered Users access to an online marketplace for Employers to advertise their job vacancies and provides JobSeekers the opportunity to apply for the vacant positions advertised by Employers. For utilisation of the Services, the SiteOwner provides Employers the option to buy plans on various tier plans offering different levels of services and these services are collectively referred to in this TAC as the Services. Use of the Services is only available only to Registered Users of the Website.|
|“SiteOwner” "or “Us” or “We”||www.recamov.com and the entirety of its content and related software, applications and services and all intellectual property therein are the sole and exclusive property of John Mallia, an individual resident in Malta.|
|“User” or “Users”||Any person and/or entity that use any part of the Website for any purpose no matter the duration or circumstances of use and shall include Registered Users.|
|“Website”||www.recamov.com and the entire contents thereof.|
|“Working Day”||Any day on which banks legally open for business in Malta.|
1. Who We Are And What We Do
Data is collected on Employers and Jobseekers for the purpose of facilitating the proper functioning of the online marketplace. Data is collected on Employers relating to their organization, its contact details, its requirements as concerns Jobseekers and its function and on the positions that Employers want to fill. Data is also collected on Jobseekers to create their profiles to allow Employers to assess their suitability for the positions to be filled. Data is also collected on Users for the purpose of analysing the usage of the Website and the effectiveness and efficiency of the SiteOwner’s activities for the marketing and promotion of the Website.
2. Our Basis For Collecting Your Information
GDPR regulations require that we have a legal basis for collection and processing personal information on anyone. In this particular instance, we must have a demonstratable legal basis for collection personal information on anyone who makes use of the Website and/or the Services.
As regards to Users, the SiteOwner collects various information ranging from the site from which they arrived or were referred from, the pages visited, the functions used, how long was spent on each page or function, how long Users were on the Website, from which page Users exited the Website. All this information and data is collected on an anonymous basis and Users cannot be personally identified using this information and data.
We will also collect names, addresses, contact details and email addresses when Employers and JobSeekers register an account on the Website in order to access the Services. In this instance the information collected can identify Users and such information is only collected with the consent of Users through the affirmative action of filling in the requisite form and submitting it.
The SiteOwner’s legal basis for collecting information is based on the following criteria:
- User’s consent to the collection of their personal information through an affirmative action (note that Users are entitled to withdraw their consent at any time by giving the SiteOwner a written notice);
- It requires the information in order to be able to provide Users with the products and services they have requested and/or purchased from the SiteOwner;
- It has a legitimate business interest for collection Users’ personal information – e.g improving the performance of the Website; and
- In providing the Services, it is legally required to collect it.
3. Why Personal Data And Information Is Collected
The SiteOwner only collects identifying and personal data and information on Registered Users and their use of the Services and the Website. The SiteOwner also collects non-identifying information on every User who visits the Website but does not register an account. The information collected may be used as follows:
- To allow the SiteOwner to analyze the use of the Services and the Website to enable the SiteOwner to improve the breath and quality of the Services, the Website and User experience offered to all Users;
- To allow the SiteOwner to analyze which parts of its marketing efforts are working best to attract new users to the Services and the Website and allow the SiteOwner to more efficiently use its resources;
- To allow the SiteOwner to learn about the preferences of Users so as to be able to offer better directed services to them;
- In some instances, the SiteOwner may be required by law to collect Users’ personal information.
Except insofar as working with third parties to analyze data and develop marketing and business strategies, the SiteOwner does not share, lease, sell or otherwise deal in Users’ personal data or information and the SiteOwner does not disclose the identity, address or financial details of Users to any third party. All information, if any, that may be shared in the future with third party vendors will be on an anonymous basis or pseudonymized basis.
The SiteOwner will use its best efforts to preserve and protect the privacy of Users. The SiteOwner’s systems are designed to ensure the best possible protection against unauthorised use of the Services and the Website and all content and information and data that reside thereon, including that of all Users.
4. Information Sources
The SiteOwner is able to collect personal data of Users in various ways, including the following methods:
4.1Information Provided by Users to the SiteOwner
This type of information collection falls into the following categories:
- Pre-Registration Questionnaire;
- Submissions of forms;
- Interactions of Users with the Website and the SiteOwner.
4.2Information We Collect
This type of information collection falls into the following categories:
- Information from browsers, devices and servers;
- Cookies and other tracking technologies;
- Application logs;
- Identifying and personal data and information (only on Registered Users).
4.3Information Secured From Third Parties
We may in exceptional circumstances secure personal information from third party sources:
- Users’ registration using external authentication services;
- Reselling partners and service providers, if any;
- Social media sites;
- Publicly available sources.
5. Types Of Data Collected
Users’ personal information can be collected by us at various stages of their interaction with the Services and the Website. For examples cookies can start to track interaction of Users with the Website as soon as Users land on the Website. Also, when Users register an account with us to become a Registered User additional information is collected.
To assist the SiteOwner in providing Users an efficient and high-quality service and user experience and to enable the SiteOwner to better develop its business and the services it offers, the SiteOwner collects the following types of data:
a.Personal And Financial Data
For the purpose of processing orders and payments and for security verification purposes, the SiteOwner may collect the following personal data:
- First, Middle and Last Names and Titles or Name of Organization;
- Address – including City, Province State, and Postal/Zip Code;
- Email address;
- Phone number;
- Users’ geographic location and IP address;
- Other information relevant to providing the Services;
- Payment information, where relevant.
- The User’s Internet Protocol address;
- Browser type and version;
- The page from which Users landed on the Website and the page of the Website on which Users landed;
- The pages of the Website Users visited and the services accessed;
- The times of entry into and exit out of the Website and the duration spent on the Website;
- The type of device used by Users to access the Website;
- Users’ unique mobile device ID, if any;
- Unique device identifiers and other diagnostic data;
- To ensure continuous availability of Services, analysis of crash logs allow the SiteOwner to debug in its systems.
To assist us in our marketing and advertising campaigns, the SiteOwner maintains a mailing list. We may make offers to Users on the Website through the use of popups. These offers will usually offer Users an item or service in exchange for Users’ information and request that Users opt into our mailing list to be able to receive future offers by way of emails. In this process, we may collect:
- Name and contact details.
- Other information, such as job title and the company Users work for.
- Areas or topics that interest Users.
- Additional information related to the Services we provide.
d.Tracking And Cookies Data
To track and trace the use of the Services and the Website by the Users, we utilise cookies and similar tracking and tracing technologies and some of the information collected is stored in cookie files, which reside on their device(s). Cookies are sent by our server based Website software to their browser and the cookies will reside on their device(s) until they expire or are deleted.
There are two categories of cookies, session or persistent. Session cookies are deleted as soon as Users close their browser or turnoff their device. Persistent cookies will remain on their device until such time that they expire or are deleted. The principal types of cookies we use are:
- Essential Cookies – are session cookies used to serve Users the Services available on the Website and features on the Website. They can help to prevent fraud by assisting in authenticating the Users accessing the Website. These cookies are essential for the Website to be functional.
- Preference Cookies – are persistent cookies that are used to remember Users’ preferences and settings so that Users do not have to reset them each time Users utilize our Services and/or the Website. They are intended to enhance Users’ user experience when using the Services and/or the Website;
- Security Cookies – are persistent cookies used to maintain the security of our Service to allow all users a safe and rewarding user experience;
- Performance and Tracking Cookies – are persistent cookies that can track information about traffic that comes to the Website and the manner in which Users utilise the Website. The information gathered by these cookies has the potential to, directly or indirectly, identify Users. These cookies can also be used, individually or in conjunction with other types of cookies, to test marketing materials, website functionality and new features.
- Advertising Cookies – are persistent cookies that keep track of Users’ browsing habits and patterns, and they assist out third party vendors to work out what marketing materials and advertising are likely to be off interest to Users. They allow categories of Users to be formed according to defined criteria and targeted marketing materials and advertising to be severed to particular categories of Users. They can also be used to influence what advertisement Users will view when visiting third party websites.
Due to the level of expertise required, Performance and Tracking and Advertising cookies, if any, are operated on our behalf by third party vendors.
Examples of tracking and tracing technologies used are beacons, tags and scripts designed to track and collect usage information to enable us to develop and improve the Service.
The following are details of the specific cookies used by the SiteOwner on the Website:
COOKIE NAME PURPOSE VALIDITY LAWFUL BASIS
We do not collect any data of a discriminatory nature about you, including any details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, health information and genetic or biometric data).
5. Use Of Users Personal Data
The SiteOwner uses data collected for various purposes that are justified by a legal basis and these include:
- Maintaining and providing the Services, the Website;
- To perform and/or enforce our Agreement with Users;
- Notifying users about changes and improvement(s) to the Services, the Website;
- Enabling users to access interactive features of the Services, the Website;
- Providing access to customer and technical support;
- In compliance with legal obligations beyond GDPR, including court orders, law enforcement requests and government agency regulations and directions;
- Monitoring usage of the Services, the Website to maintain a stable and safe usage environment;
- Marketing and promotional purposes, including new product and service development of;
- For analytical purposes to study and analyze how Users use the Services, the Website and to measure and analyze the effectiveness of our marketing and promotion efforts.
- Detecting preventing and solving technical issues; and
- To use as is otherwise required or permitted by law or consistent with the provisions of GDPR.
7. Sharing Users Personal Data
The SiteOwner may share Users’ personal information/data in the following situations:
- With our B2B partners;
- With our third party service providers for monitoring and analysing the use of the Services, the Website, to contact Users on our behalf and to advertise to Users whether on the Website or on a third party site after their visit to the Website;
- In the event the business, including the Website, of the SiteOwner is subject to a takeover, merger or acquisition, the SiteOwner make disclose their personal information to the purchaser as part of its due diligence or as part of the SiteOwner’s transfer of assets and/or liabilities to the new owner;
- With our business partners, with the purpose of offering to Users certain products and services;
- With other Users – when Users share their personal information/data or otherwise interact with the Website Users, such information may be viewed by other parties;
- With our third party advisers should we need to enforce our rights in any way;
- With any third party deemed necessary in order to avoid a crime of any type being committed or to ensure the safety of the User, our employees, agents and third party contractors;
- We include social media access buttons on the Website so that Users can share our content with their family, friends and associates. The functionality of these buttons is controlled by the respective social media organizations and they may collect information on Users and their utilisation of the Website and they may set a cookie on their device. These buttons are governed by the privacy policies of the respective social media organisations and Users should inform themselves accordingly’
- With duly authorized regulators, tax authorities and other government authorities;
- With duly authorized law enforcement agencies;
- Compliance with a valid court order or warrant;
- To protect itself from incurring legal liability in any respect;
- To protect and preserve the property, rights, goodwill and reputation of the SiteOwner, its shareholder, employees and agents;
- To prevent wrongful and/or illegal use of the Services, the Website; and
- To protect the personal safety of Users, employees, agents, and the public at large.
8. Data Retention Period
9. Users’ Choices Regarding Interaction With Us
With certain exceptions, the level of interaction Users have with us is within Users’ control, particularly, but not limited to the following areas:
- Users may opt out of non-essential communications with us by using the unsubscribe option included in such messages. However, Users will continue to receive essential messages from time to time.
- Users may disable the acceptance of cookies on their browser at any time. However, Users should be aware that the Website may not function as intended and Users will probably experience a negative experience in using the Website; and
- Users may elect not to complete any non-mandatory information in any forms, surveys etc. on the Website.
10. Data Transfer
Data servers of the SiteOwner are located in the Federal Republic of Germany and its operational offices are located in Malta and the personal and other data of all Users will be located and accessed only from these locations. Users may be located in multiple other jurisdictions and the laws and regulations regarding personal and other data may be different in such jurisdiction. By accessing and continuing to use the Services and the Website, Users expressly consent to the transfer of Users’ personal and other data and information to the indicated jurisdictions and subjected to the laws and regulations of such jurisdictions.
The SiteOwner has put in place measures that are necessary to ensure that the personal and other data of all Users is securely maintained and no data will be transferred to any third party in any jurisdiction who does not maintain and operate security protocols equivalent to those maintained and operated by the SiteOwner.
11. Web Forms
12. Information Users Share On Third Parties
In certain circumstances the Website may allow Users to submit information on third parties. For example, if Users use the Website to share Users’ personal information with their friends and family Users will need to enter some personal details about themselves, including but not limited to their email address. In instances where Users provide information on third parties, the information submitted will be retained on our servers only in so far as it relates to Users’ account and such information will not, except as otherwise disclosed herein, be shared or otherwise dealt in.
13. Information Received From Third Parties
In some instances, the SiteOwner may receive information about Users from third parties either through the Website or independently. For example, our payment gateways will submit information relating to Users’ transaction to us for the purpose of identifying their transactions and processing them to have their orders processed, prepared and delivered to Users and/or to maintain our accounting records for audit and taxation purposes. We may also in certain instances develop and maintain information about Users independently. For example, if we have reason to believe that Users have provided false or incorrect information in the registration of their account, we reserve the absolute right to verify such information and to establish the correctness of their identity. All information received and/or gathered on Users from third parties will be maintained on our servers in the same manner and to the same standard as information provided by Users or gathered directly by us. In terms of sharing such information, we will apply the same rules and standards as any other information we maintain on Users.
14. How We Protect User Information
The security of Users’ data and information is of primary importance to us and we shall take all reasonable measures that comply to industry standards to keep their personal and other data safe and private. However, we cannot give Users a guarantee that Users’ personal and other data will be 100% safe and secure and we make no such guarantee and/or undertaking, express or implied.
The Website and our servers are routinely scanned by high grade anti-virus and malware scanning software. All operating software is kept up to date so that all known vulnerabilities are dealt with at the earliest possible opportunity. Users’ personal information/data is stored behind secure firewalls on secure networks and is accessible only by a limited group of people in a limited set of circumstances. All such personnel are required to sign non-disclosure agreements as part of their engagement terms. All passwords used are highly sophisticated and encrypted.
All sensitive personal and other information Users supply to us is encrypted via Secure Socket Layer (SSL) technology. All financial transactions are processed by independent payment gateways and Users’ financial information is never stored in our databases or on our servers nor do we make a request to Users for such information.
If Users feel that their account has been abused or hacked in any way, please contact us by way of our contact form on the Website at https://www.recamov.com /contact. Please include full details of the relevant events and the time at which they occurred.
15. Termination Of Account And Data Protection
Users have a right to request that Users’ information be removed from the Website, our database and our servers. We will comply with such requests within thirty (30) days of receiving a written request from Users. However, please be aware that we will retain certain information relating to individual transactions Users may have conducted through the Website. We are required to retain such information for accounting, legal and taxation reasons.
Registered Users may terminate their account at any time. Once Users elect to terminate their account, the action is irrevocable. Users’ account will be permanently suspended and cannot be reactivated. In terminating Users’ account, most of the personal information and data associated with it will be permanently deleted. However some information and data will be retained for accounting, taxation and auditing purposes and also as required by laws and regulations in England and Wales where our servers and operations office are located respectively.
16. Link To Other Websites
From time to time, we may display advertisements by third parties on the Website. To assist the third parties in assessing the performance of their advertisements, they may set cookies that allow their servers to identify Users and their activity on the Website. These cookies allow the third parties to direct more relevant advertisements taking into consideration their activities on the Website and Users’ preferences.
18. Privacy Of Children And Minors
Our Service is restricted to persons over the age of 18. The SiteOwner does not knowingly collect data and information relating to persons under the age of 18. Any parent who is aware that their child has provided us with misleading and/or false information in order to access the Services should inform us immediately in writing by way of our contact form on the Website at https://www.recamov.com /contact. Once we are aware the information on a person under the age of 18 has been collected without parental consent, we will take all actions necessary to remove such information from our records and our servers.
19. Third Party Vendors
We do not sell, trade or otherwise deal in Users’ personal information/data which has potential to identify Users as an individual person or entity not do we disclose such information to any third party with the exceptions of third party vendors who assist us in the operation and provision of the Services, the Website and our business as a whole. Third party vendors are contractually required to keep all information shared with them absolutely private and confidential.
From time to time, the SiteOwner uses third party vendors who specialize in providing specialist data analytic services that assist us in improving and developing the Service and increasing the efficiency of our marketing efforts. As part of the process, we need and do disclose some Users’ personal and other data to our third party vendors. However, such disclosure is made on an anonymous basis and no credit card details are made available other than the name of the issuer and/or payment gateway. All third party vendors are required to maintain and operate security protocols at least equivalent to those operated by the SiteOwner and all third party vendors are required to sign and observe a strict Non-Disclosure Agreement.
20. Users’ Specific Data Protection Rights Under GDPR
For the purposes of GDPR, we are defined as a Data Controller of Users’ personal information. All residents of the European Economic Area (EEA) are bestowed certain rights by GDPR in relation to their personal information/data as regards:
- how it is collects;
- under what circumstances it can be collected;
- how it must be stored;
- how it can be used; and
- with whom and under what circumstances it can be shared.
- We need to perform a contract with Users, for example when Users create a User Account with us and later Users’ Profile;
- Users give us permission to do so, as they do when Users authorize us to process their payments;
- The processing and use of the information are in our legitimate business interests and such use does to breach and/or circumvent their rights; and
- To comply with the law or regulations prescribed by a statutory or regulatory body.
As a resident of EEA, GDPR confers on Users certain rights for the protection of their personal information and/or data:
- to access, update or to delete certain personal information we have on Users;
- to rectify the correctness of any information we have on Users;
- right to object to our holding any information on Users;
- to request us to restrict the information collected on Users and how we make use of it;
- right to data portability for Users’ reuse elsewhere;
- Users have a right not to be the subject of decisions based on automatic procession or profiling; and
- right to withdraw the consent Users have previously given to use and request the erasure of any information we hold.
Before acting to any written request from Users in relation to the above, we may request for verification of their identity.
Please keep in mind that we may be under legal or contractual obligations which are in conflict with User GDPR rights. These conflicts may prevent us from responding to some of User requests. Users are entitled to complain to a Data Protection Authority about our conduct in the collection and use of Users’ personal information. For more information, please contact your local data protection authority in the EEA.
21. CCPA Compliance
Since 1st January, 2020, the California Consumer Privacy Act (“CCPA”) afforded specific rights to consumers to ensure that their privacy and their personal data is protected. While our business does not fall within the ambit of the CCPA, we are choosing to comply with its requirements on a purely voluntary basis.
The rights conveyed by CCPA include the right to require businesses to disclose information about the collection and use of their personal information over the past 12 months. You may also ask us to delete any personal information that we collect from you. In the event that we decide to sell the personal information of our Users, which will never happen, you have the right to opt out of such sale. In the event that you exercise any of your rights conferred by CCPA, we are not allowed to discriminate against you for exercising your rights.
For the purposes of CCPA, Recamov would be classified as a ‘Service Provider’. We operate a marketplace that allows Employers and Jobseekers to come together to fulfil a mutual need. In doing so, we collect information on our Users to facilitate the efficient functioning of our marketplace. We effectively collect the job vacancy information from would be employers and disseminate it to Jobseekers. At the same time, we collect information from our Jobseekers and disseminate it to Employers to allow them to effectively make an assessment on the suitability of Jobseekers applying for jobs.
For your personal information (defined as “PI”), CCPA grants California residents the right to request the following types of items:
- categories of any PI that Recamov may collect, use, disclose, sell or otherwise deal in;
- the purpose for which the various categories of PI is collected and used;
- any PI specifically collected on You;
- the sources from which we collect PI;
CCPA also grants California residents the right to opt out of:
- any sale, use or disclosure of your PI (your information will never be sold or otherwise dealt in);
- receiving any marketing material from us. However, we will still send you important account information regarding Recamov’s products and services;
- some financial programs such as loyalty and discount programs that we may run;
- having your PI in our database
Our information disclosure to you is limited in some instances. For example, if the disclosure of the information would create an unreasonable risk to the PI of our other Users or to our digital security systems.
Should You wish to delete any of your information we have collected, please send us a written request to email@example.com. We will assess your request and comply with it if the request does not fall within our exceptions to meet User CCPA requests. These exceptions mainly relate to legal and statutory regulations which require us to maintain certain User information. These usually relate to accounting and tax matters.
23. Data Protection Personnel
24. Contact Us