Privacy Policy

Last updated: September 2022

Welcome to Clu and thank you for taking the time to read our Privacy Policy. Clu is an inclusive recruitment platform purposefully designed to create equity of opportunity in the job market. We are passionate about social inclusion and are committed to providing job seekers and employers the opportunity to connect via our platform.

 

1. Overview

This Privacy Policy explains how Included.AI Ltd and its affiliates (collectively, "Clu", "we", and "us") may collect, process, share and/or utilise information relating to an identified or identifiable natural person's ("you" and "your") personal information ("Personal Data"), including information from:

  • Visitors to our website (a "Visitor"),

  • Individuals seeking employment at Clu (a "Job Seeker"),

  • Job Seekers who create a Clu account (a "Member"), either directly on the Clu website or after being referred to Clu,

  • People who choose to allow Clu to send them communications, including email subscriptions.

This Privacy Policy applies to the Personal Data that is provided to us through the use of our site www.getaclu.io (the "Site"), events and/or any communications including email subscriptions (collectively, our “Platform”).

This Privacy Policy does not apply to information that you may provide to one of our employer partners ("Employers"), other Clu Members, and applications or services that Clu does not own or maintain or to any entities that are integrated with Clu using the Clu Application Programming Interface ("API"). If you applied for a job with an Employer, the Employer may provide your information to Clu directly so they can use the Clu services for managing their recruiting activities. We will use the information in accordance with our agreement with that Employer. Your agreement with that Employer should explain how they share your information with Clu. Please contact the Employer if you have questions about this sharing. We are not responsible for the privacy practices of any third-party website operator that you may link to from our website.

Clu is dedicated to protecting the privacy and security of your Personal Data and to monitoring governance regulations. We are committed to performing our responsibilities regarding the collection, processing, utilisation and retention of in-scope data in accordance with applicable data privacy laws such as GDPR and CCPA. This data is only used for legitimate and lawful purposes.

 

2. Personal Data We Collect

You may choose to share different types of Personal Data with us when you use our Platform.

For example: You may also choose to submit information to us via other methods, including: (i) in response to marketing or other communications, (ii) through social media or online forums, (iii) through participation in an offer, program or promotion, (iv) in connection with an actual or potential business relationship with us, or (v) by giving us your business card or contact details at trade shows or other events.

Our websites use cookies and other technologies to function effectively. These technologies record information about your use of our websites, including:

We also collect information about your online activities on websites and connected devices over time and across third-party websites, devices, apps and other online features and services. We use Google Analytics on our websites to help us analyse your use of our websites and diagnose technical issues.

To learn more about the cookies that may be served through our sites and how you can control our use of cookies and third-party analytics, please see our Cookie Policy.

You may choose to enhance your Clu Member profile with information that could be categorised as “sensitive”, depending on where you live. For example, we ask you to self-identify your demographic profile when you create your Clu account. You do not have to provide this information in order to have a Member profile on Clu, but providing this information can help you to get more from our services, including helping Employers utilising our services to find you. It also significantly helps us develop our technology and insights to be adept at identifying bias and mitigating it. It's your choice whether to provide this sensitive information, and if you do, we request that you please be mindful that it will become a part of your Clu profile.

We contract with Employers who use the Clu services. These Employers may share Personal Data about individuals who have applied for an employment opportunity with their organisation (an "Applicant"). This Privacy Policy does not apply to Applicants. We encourage you to review the terms of service and privacy policy of that organisation in order to better understand your rights. If you are an Applicant, you may choose to become a Member by creating an account, which can include your Employer-provided personal information.

  • Personal Data that we collect about you.

    • We collect your full name, email address, and account log-in credentials when you create a Clu account.

    • We collect your full name, job title, company name, telephone number, and email address when you complete a form on our website to receive a product demo.

    • We collect your full name, email address and other application data such as your resume and right to work status when you apply for a job at Clu.

    • We collect your name and contact details and professional biographical details obtained from publicly available sources such as LinkedIn and social media sites when you are a prospective job seeker for a client. We may also obtain your personal data through another job seeker or an employer who recommends you as a contact or job seeker.

    • We collect information you add to your profile, such as: your resume, social media links, personal biographical details, references and your strengths profiling results.

    • When you respond to Clu emails or surveys we collect your email address, name and any other information you choose to include in the body of your email or responses. If you contact us by phone, we will collect the phone number you use to call us.

  • Information that we collect automatically on our Sites.

    • Browser and device data, such as IP address, location, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the language version of the Sites you are visiting.

    • Usage data, such as time spent on the websites, pages visited, links clicked, language preferences, and the pages that led or referred you to our websites.

  • Collection of Sensitive Personal Data.

  • Information Provided to us by Employers.

 

3. How We Use Personal Data

We use your Personal Data compliantly. We use Personal Data to facilitate the business relationships we have with Members and to pursue our legitimate business interests. For example:

We may send you email marketing communications about Clu products and services, invite you to participate in our events or surveys, or otherwise communicate with you for marketing purposes, provided that we do so in accordance with the consent requirements that are imposed by applicable law. For example, when we collect your business contact details through our participation at trade shows or other events, we may use the information to follow-up with you regarding an event, send you information that you have requested on our products and services and, with your permission, include you on our marketing information campaigns.

When you use our Sites, we (and our service providers) may use Personal Data collected from you and your device to target advertisements for Clu services to you on our Sites and other websites you visit (“interest-based advertising”), where allowed by applicable law. For example, when you visit our Site, we will use cookies to identify your device and direct ads for our services to you. You have choices and control over our cookies (or similar technologies) we use to advertise to you. Please see our Cookie Policy for more information. At present, there is no industry standard for recognising Do Not Track browser signals, so we do not respond to them.

We do not share, rent or sell Member Personal Data for interest-based advertising.

  • Our products and services.

    • We use Personal Data to provide the Clu services to you, including when we create and manage your Clu account or share your profile with an Employer who uses the Clu platform for recruiting activities.

    • We may use Personal Data to comply with a regulatory or other legal request.

    • We may use Personal Data for our business, such as when we respond to customer support inquiries, to improve our services, to develop new services, and to conduct general analysis related to activities such as security, decision making, administrative, and reporting.

  • Marketing and events-related communications.

  • Advertising.

No personal data capture or use will breach or joepardise the Clu Safeguarding Policy.

 

4. How We Disclose Personal Data

We train our staff on the importance of privacy and make them aware of the correct processes to follow in relation to privacy and the handling of personal data.

Clu does not sell or rent Personal Data to marketers or unaffiliated third parties. We share your Personal Data with trusted entities, as outlined below:

  • Service providers.

    We share Personal Data with a limited number of our service providers. We have service providers that provide services on our behalf, such as website hosting, data analysis, information technology and related infrastructure, customer service, email delivery, and auditing services. These service providers may need to access Personal Data to perform their services. We authorise such service providers to use or disclose the Personal Data only as necessary to perform services on our behalf or comply with legal requirements. We require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf.

  • Business partners.

    We share Personal Data with business partners when this is necessary to provide our services to you.

  • Employers.

    We share Personal Data with Employers who use the Clu services for recruiting activities.

  • Corporate transactions.

    In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganisation, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Data with third parties in connection with such transaction. Any other entity which buys us or part of our business will have the right to continue to use your Personal Data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

  • Legal compliance and harm prevention.

    We share Personal Data as we believe necessary: (i) to comply with applicable law; (ii) to enforce our contractual rights; (iii) to protect the rights, privacy, safety and property of Clu, you or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.

 

5. Your Rights and Choices

You have choices regarding our use and disclosure of your Personal Data:

  • You may opt out of receiving electronic communications from us.

    If you no longer want to receive marketing-related emails from us, you may opt-out via the unsubscribe link included in such emails. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages that are required to provide you with our services.

  • You may view or change your account Personal Data.

    If you would like to review, correct, or update Personal Data that you have previously disclosed to us, you may do so by signing in to your Clu account and accessing your profile dashboard, or by contacting us at dpo@getaclu.io.

  • Your data protection rights.

    Depending on your location and the law there, you may have the following rights with regard to your Personal Data:

    • The right to request confirmation of whether Clu processes Personal Data relating to you, and if so, to request a copy of that Personal Data;

    • The right to request that Clu rectifies or updates your Personal Data that is inaccurate, incomplete or outdated;

    • The right to request that Clu erase your Personal Data in certain circumstances provided by law;

    • The right to request that Clu restrict the use of your Personal Data in certain circumstances, such as while Clu considers another request that you have submitted (including a request that Clu make an update to your Personal Data);

    • The right to request that we export to another company, where technically feasible, your Personal Data that we hold in order to provide services to you; and

    • Where the processing of your Personal Data is based on your previously given consent, you have the right to withdraw your consent at any time. You may also have the right to object to the processing of your Personal Data on grounds relating to your particular situation.

    In general, you may contact Clu at any time to get a complete log of your stored Personal Data or to delete your account with us from our databases at any time. Please contact Clu as described in the Contact Us section below with other questions or for more information about your rights. If you are an Applicant of an Employer, please contact the Employer directly with questions about your rights with respect to your information.

 

6. Security and Retention

We take the security of your data very seriously. We have internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the performance of their duties.

We make reasonable efforts to ensure a level of security appropriate to the risk associated with the processing of Personal Data. We maintain organisational, technical and administrative measures designed to protect Personal Data within our organisation against unauthorised access, destruction, loss, alteration or misuse. Clu uses role-based access control to limit personnel access to your Personal Data to those requiring it to perform their duties as required to deliver the services. Please contact us immediately at dpo@getaclu.io if you have reason to believe that your account has been compromised.

In general, we retain your Personal Data as long as you remain a Member. We may retain Personal Data after we stop providing services to you, even if you close your Clu account, in order to comply with our legal obligations. We may also retain Personal Data to comply with our tax, accounting, and financial reporting obligations. Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.

 

7. International Data Transfers

Personal Data may be stored and processed in any country where we have operations or where we engage service providers. We may transfer Personal Data that we maintain about you to recipients in countries other than the country in which the Personal Data was originally collected, including to the United States. Those countries may have data protection rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Data remains protected to the standards described in this Privacy Policy.

We contractually require minimum standards of confidentiality and data protection from our clients and third-party service providers. The UK recognises that after Brexit, countries in the EEA provide adequate protection for personal data. If we need to send personal data outside the EEA, we will ensure that adequate safeguards are in place. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 

8. Use by Minors

The Platform is not intended for use by individuals under the age of seventeen (17), and we request that they not provide Personal Data through the Platform.

 

9. Updates To this Privacy Policy and Notifications

We are always finding ways to improve our Platform, which means we get new data and create new ways to use data. Our services are dynamic, and we often introduce new features, which may require the collection of new information. If we collect materially different personal data or materially change how we collect, use or share your data, we will notify you and may also modify this Privacy Policy. The “Last updated” designation at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are effective when we post the revised Privacy Policy on the Platform. We may also provide you with disclosures and alerts regarding the Privacy Policy or Personal Data collected by posting them on our website and, if you are a Member, by contacting you through the email address listed in your Clu account.

10. Contact Us

To exercise your rights, to withdraw your consent to the processing, to unsubscribe from receiving marketing communications from us, if you have any questions about our privacy policy or about our processing of your personal data or to make a complaint, you can email us at dpo@getaclu.io or write to us at our registered office address:

Included.AI Ltd
124 City Road
London
EC1V 2NX

If you have unresolved concerns, and you live or work in the UK or believe that a personal data breach happened in the UK, you have the right to complain to the UK Information Commissioner's Office who can be contacted at:

  • Telephone: 0303 123 11113

  • Website: https://ico.org.uk/concerns/

  • By post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.