iCIMS Privacy Notice
Effective Date: June 23 2022
TABLE OF CONTENTS
• How We Obtain Your Personal Data
• How We Use Your Personal Data
• How We Share Your Personal Data
• Legal Basis for Processing Personal Data
• International Transfers
• EU-U.S. and Swiss-U.S. Privacy Shield Framework
• Security and Breach Notification
• Data Retention
• Cookies and Similar Technologies
• Your Privacy Rights
• How We Treat Do Not Track Signals
• Third-Party Websites and Applications
• Changes to this Notice
• Contact Information
Please note, this Privacy Notice is available at www.candidateid.com and related domains and subdomains, (each the “Website” as applicable). iCIMS maintains other privacy notices to address specific use cases applicable to iCIMS, which are available at the following locations:
- If you are an iCIMS Subscriber, please refer to icims.com/legal/privacy-notice-services for the iCIMS Services Privacy Notice relating to the iCIMS Talent Cloud recruiting platform.
- If you are a California resident, please refer to https://www.icims.com/legal/ccpa-privacy-notice/ for the Privacy Notice for California Residents that contains additional disclosures and information about our privacy practices with respect to the collection, use, and disclosure of personal data of California residents.
- If you are an applicant for a job at iCIMS, please refer to https://www.icims.com/legal/job-app-privacy-notice/ for the iCIMS Job Applicant Privacy Notice relating to applying for a job at iCIMS and iCIMS’ recruitment process.
- If you are an iCIMS employee, please refer to https://www.icims.com/legal/employee-privacy-notice/ for the iCIMS Employee Privacy Notice relating to employment at iCIMS.
- If you are an authorized user of iCIMS Academy, please refer to https://academy.icims.com/partner/learn/policy/view;lng=en for the iCIMS Academy Privacy Notice relating to iCIMS’ training platform for Subscribers and partners. (Please note that this link is only available to current iCIMS Academy users who have valid login credentials.)
iCIMS, Inc. and its subsidiaries, iCIMS International, LLC, Jibe, Inc., TextRecruit, Inc., Opening HR Limited, EasyRecrue S.A.S., Candidate ID Ltd, and Altru Labs, Inc. (collectively, “iCIMS,” “we,” or “us”), respects the privacy of its Subscribers, prospects, business partners, event attendees, employees, job applicants, and website and mobile application users (collectively, “you”), and we are committed to protecting their respective personal data. To that end, we have put together this Privacy Notice (“Privacy Notice”) to give you a better understanding of who we are and our practices with respect to the collection, use, disclosure, and retention of personal data obtained in connection with the use of our Website and our marketing efforts.
For purposes of this Privacy Notice:
- The term “personal data” means any information which relates to an identified or identifiable, living individual that directly or indirectly references one or more factors specific to their physical, physiological, mental, economic, cultural, or social identity. Personal data excludes anonymous data.
Please take the time to read this Privacy Notice and the related statements in their entirety to ensure you are fully informed. If you have any questions or concerns about our processing of your personal data, please contact us by using the contact details under the “Contact Information” heading below.
Services Privacy Notice. Our Services Privacy Notice covers our privacy practices with respect to the collection, use, and disclosure of personal data obtained in connection with the use of our Subscription and related services, including professional services and trainings that we provide to Subscribers. It also describes our privacy practices with respect to Subscriber and partner contact information we process for Subscriber account, contract, and billing management purposes (e.g., the processing of Subscriber address and billing information) in connection with the use of our products and services, or technology provided by our partners to our Subscribers. For clarity, iCIMS collects personal data under the direction of its Subscribers and has no direct relationship with the Subscribers’ candidates. If you are a candidate of one of our Subscribers, please contact that Subscriber.
Job Applicant Privacy Notice. Our Job Applicant Privacy Notice covers our privacy practices in connection with an individual’s application for employment at iCIMS.
As further described below, we collect several types of personal data from and about you that broadly falls into the following three (3) categories:
- Personal data you voluntarily provide to us:
- When filling out forms on our Website.
- When you register for a demo of one of our products or services.
- When you enter a contest or promotion we sponsor.
- When you contact us.
- When you complete one of our surveys.
- When you register for or attend an event.
- When you visit our corporate offices.
In each case, the personal data collected may include (but is not limited to):
- First name
- Last name
- Business mailing address
- Business email address
- Business telephone number
- Company or organization name
- Job title or role
If we ask you to provide any other personal data not described above, then the personal data we will ask you to provide, and the reasons why we ask you to provide it, will be made clear to you at the point we collect it. If we ask you to provide personal data that we consider to be mandatory for us to administer your relationship with us, we will inform you of such at the time of collection. In addition, we will also inform you of the consequences for not providing us with the mandatory personal data.
- Personal data from third parties.
From time to time, we may collect and use personal data we receive about you from third parties in connection with your use of the Website or attendance at an event. For instance, we may receive personal data about you from our business partners related to your registration information for events. We also use third parties for reporting and analytics to measure the effectiveness of our Website and marketing efforts, and to identify areas for improvement.
We may combine personal data we collect from third parties with personal data you provide us to update, expand, or provide you with tailored information regarding our products, services, and events.
- Data we collect as you navigate through the Website.
As is true of most websites, we gather certain data automatically. This data may include Internet protocol (“IP”) addresses, browser type, Internet service provider (“ISP”), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.
How We Use Your Personal Data
We may use personal data that we collect about you for the following purposes:
- To operate, maintain, and improve our Website.
- To communicate with you about events or register you for events you sign up for with us.
- To provide you access to our corporate offices.
- To provide you with information, products, or services that you request from us.
- To notify you about changes to our Website or obtain any required consent.
- To allow you to participate in interactive features of our Website, when you choose to do so.
- For industry analysis, benchmarking, analytics, marketing, and other business purposes.
- To track your browsing actions, such as the pages you visited over time, for analytics and advertising purposes.
- To contact you for marketing purposes, in accordance with your marketing preferences (e.g., we may use your personal data to contact you to further discuss your interests in our services and products or other events), including, but not limited to, promotional offers for our own or third parties’ products or services. If you do not wish to receive our email marketing communication for promotional purposes, you may opt out by clicking on the “unsubscribe” or “opt out” link in the marketing e mails we send you.
- To comply with applicable laws, judicial requests from courts of competent jurisdiction, or exercising or defending legal rights.
- To prevent and detect fraud or other types of wrongdoing.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us is among the assets transferred.
- To fulfill the purpose for which you provide it.
- For other lawful or legitimate purposes, which may be reasonably required for day-to-day operations.
We may also partner with third parties to either display advertising on our Website or to manage our advertising on other sites. Our third parties may use technologies such as cookies to gather data about your activities on the Website and other websites to provide you advertising based upon your browsing activities and interests. If you wish to not have this data used for the purpose of serving you interest-based ads, you may opt-out from many third parties through the Digital Advertising Alliance’s self-regulatory opt-out by clicking here or the Network Advertising Initiative’s self-regulatory opt-out by clicking here (or if you are located in the Economic European Area (“EEA”), the United Kingdom (“UK”), or Switzerland, through the European Interactive Digital Advertising Alliance’s self-regulatory opt-out by clicking here). Please note that you will continue to receive generic ads. If you do not want your data collected with Google Analytics, you can install the Google Analytics opt-out browser add-on. To opt-out of Google Analytics, visit the Google Analytics opt-out page (located at https://tools.google.com/dlpage/gaoptout) and install the add-on for your browser. For more details, visit the “Google Analytics opt-out browser add-on” page (located at https://support.google.com/analytics/answer/181881?hl=en). For more information about how you can manage cookies related to analytics and targeted advertising, please see our Cookie Notice.
If we need to process your personal data for an incompatible purpose not discussed in this Privacy Notice, we will provide notice to you and, if required by law, seek your consent. We may process your personal data without your knowledge or consent only where required by applicable law. Lastly, iCIMS does not subject you to automated decision-making.
Legal Basis for Processing Personal Data
If you are a resident of the EEA, the UK, or Switzerland, our legal basis for collecting and using the personal data described above will depend on the personal data concerned and the context in which we collect it. However, we will normally collect and/or process your personal data pursuant to one or more of the following legal bases:
- The processing is in our legitimate interests which do not override your data protection interests or fundamental rights and freedoms.
- The processing is necessary to perform a contract with you.
- The processing is necessary to comply with our legal obligations.
- We may also seek your consent to process or retain your personal data in certain, limited circumstances that we clearly identify to you.
- In some limited cases, we may need the personal data to protect your vital interests or those of another person; for example, we may need to share your personal data with third parties for security reasons (when we believe in good faith that disclosure is necessary to protect our rights, protect your or others’ safety, to investigate fraud, or respond to a related government request).
If we ask you to provide personal data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and let you know whether the provision of your personal data is mandatory or not (as well as the possible consequences if you do not provide it). Similarly, if we collect and use your personal data in reliance on our legitimate interests (or those of a third party) that are not listed above, we will make clear to you at the relevant time what those legitimate interests are. If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us using the contact details provided in the “Contact Information” section below.
iCIMS or its appointed service providers may collect, use, process, store and disclose your personal data outside of your home jurisdiction, including in the U.S., and in some cases, other countries, for the purposes described in this Privacy Notice. These countries may have data protection and privacy laws that are different than the laws of your home country. iCIMS only transfers personal data to another country in accordance with applicable data protection and privacy laws, provided there are legally adequate protections in place for the personal data. A list of iCIMS’ global offices is available here.
If your personal data is processed within the EEA, the UK, or Switzerland, and for onward transfers of personal data to iCIMS’ appointed service providers, iCIMS and its appointed services providers, will protect your personal data (as defined in the European Union’s (“EU”) General Data Protection Regulation (“GDPR”)) when it is transferred outside of the EEA, UK, or Switzerland by:
- Processing it in a territory which the European Commission (or other relevant governmental authority) has determined provides an adequate level of protection for personal data; or
- Otherwise implementing appropriate safeguards to protect your personal data, including through the use of Standard Contractual Clauses or another lawful transfer mechanism approved by the European Commission (or other relevant governmental authority).
Although iCIMS does not rely on the Privacy Shield Frameworks to protect personal data when it is transferred from the EEA, UK, or Switzerland to the U.S., iCIMS, Inc. and certain of its subsidiaries continue to participate in and certify their compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework and subject all personal data received from the EEA, the UK, and Switzerland to the Privacy Shield Principles. To learn more about the Privacy Shield Frameworks and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List.
If you require further information about our international transfers of personal data, please contact us by using the contact details under the “Contact Information” heading below.
EU-U.S. and Swiss-U.S. Privacy Shield Framework
iCIMS, Inc. and certain of its subsidiaries participate in and have certified their compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. iCIMS is committed to subjecting all personal data received from the EEA, the UK, and Switzerland in reliance on each Privacy Shield Framework to the Privacy Shield Principles. To learn more about the Privacy Shield Frameworks and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List.
iCIMS is responsible for the processing of personal data it receives, under GDPR and each Privacy Shield Framework, and subsequent transfers to a third party acting as an agent on its behalf. iCIMS complies with GDPR and the Privacy Shield Principles for all onward transfers of personal data from the EEA, the UK, and Switzerland, including the onward transfer liability provisions.
iCIMS recognizes that the Court of Justice of the European Union ruled in July 2020 that a certification under the EU-U.S. Privacy Shield Framework no longer can serve as the basis by which entities subject to the GDPR transfer personal data to jurisdictions outside the EEA. iCIMS also recognizes Switzerland’s announcement that the Swiss-US Privacy Shield Framework does not provide an adequate level of protection to transfer personal data from Switzerland to the U.S. Although iCIMS now relies on Standard Contractual Clauses or other lawful transfer mechanisms approved by the European Commission (or other relevant governmental authority) to transfer personal data from the EEA, the UK, and Switzerland, iCIMS will continue to maintain its Privacy Shield certification and will continue to honor its obligation to comply with the Privacy Shield Principles with respect to data that was previously transferred pursuant to the EU-U.S. Privacy Shield Framework and/or the Swiss-U.S. Privacy Shield Framework.
With respect to personal data received or transferred pursuant to GDPR, iCIMS is subject to the regulatory enforcement powers of the EU in conjunction with the U.S. Federal Trade Commission. For each Privacy Shield Framework, iCIMS is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain circumstances, iCIMS may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
In compliance with GDPR and the Privacy Shield Principles, iCIMS commits to resolve complaints about our collection and use of your personal data. EEA, UK, and Swiss individuals with inquiries or complaints regarding our privacy practices should first contact iCIMS as provided in the “Contact Information” section below. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
Security and Breach Notification
iCIMS maintains appropriate technical and organizational measures, including, but not limited to, reasonably designed administrative, physical, and technical safeguards, designed to protect the personal data obtained as discussed in this Privacy Notice from accidental or unlawful destruction, loss, alteration, unauthorized disclosure and access. iCIMS personnel and service providers with access to personal data collected as discussed in this Privacy Notice are required to keep such personal data confidential and secure. iCIMS has a dedicated team responsible for monitoring and responding to security events, and it notifies applicable parties of security or privacy incidents and data breaches in accordance with its Incident Response Procedures and applicable law.
Unless a longer retention period is required by law, we will retain your personal data for as long as is needed to fulfill the purposes outlined in this Privacy Notice, or for as long as we have a legitimate business interest that is not outweighed by your data protection interests or fundamental rights and freedoms. When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymize it or, if this is not possible (e.g., because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible. As such, we reserve the right to use such anonymous data for any legitimate business purpose without further notice to you or your consent.
Cookies and Similar Technologies
For information about the cookies and other tracking technologies used by our Website and how to manage your settings for these cookies and technologies, please see our Cookie Notice.
Your Privacy Rights
Certain jurisdictions may provide you with privacy rights under applicable data protection or privacy law regarding your personal data. In particular, you may have the right to:
- be informed about your personal data;
- access your personal data;
- correct any personal data that is inaccurate;
- have your personal data erased;
- restrict or suppress the processing of your personal data;
- obtain and reuse your personal data;
- object to the processing of your personal data;
- object to how your personal data is used in automated decision making, if applicable;
- lodge a complaint with a supervisory authority; and
- obtain a copy of Standard Contractual Clauses (if applicable).
These rights may be limited, for example, if fulfilling your request would reveal personal data about another individual, or if you ask us to delete personal data which we are required by law to keep or which we need to defend claims against us.
If you are a California resident, please see our Privacy Notice for California Residents for additional disclosures and information about the personal data we have collected about you over the last 12 months and rights you may have regarding your personal data.
If you do not wish to receive our email marketing communication for promotional purposes, you may opt‑out by clicking on the “unsubscribe” or “opt‑out” link in the marketing e‑mails we send you.
If we process your personal data in reliance upon your consent, you can contact us at any time to withdraw your consent.
To exercise any of these rights, please contact us by using the contact details under the “Contact Information” heading below.
We will respond to such requests in accordance with the requirements of applicable data protection laws. Please note that in order to fulfil your request, we may need you to provide certain personal data to verify your identity. Depending upon applicable data protection and privacy law, individuals may also designate an authorized agent to exercise these rights on their behalf.
How We Treat Do Not Track Signals
Various browsers (i.e., Internet Explorer, Chrome, Firefox, Edge, etc.) may allow a “do not track” (DNT) setting, which sends a signal to websites visited by an individual about their browser DNT setting. At this time, there is no general agreement on how companies, like iCIMS, should interpret DNT signals. Therefore, we do not currently commit to respond to DNT signals. We will continue to monitor developments around DNT browser technology and the implementation of a standard.
Third-Party Websites and Applications
This Website may link to websites that are not owned or controlled by iCIMS. As such, this Privacy Notice does not apply to personal data collected on any third‑party site or by any third‑party application that may link to or be accessible from the Website. This Privacy Notice does not apply to personal data collected by Subscribers, our business partners, and other third parties or third‑party applications or services, even if this personal data is collected using our Website or at events.
The Website is not directed to or intended to be used by anyone under the age of 13. We do not knowingly collect personal data from anyone under the age of 13. If you are under 13, please do not attempt to fill out our forms or send any personal data about yourself to us. If we learn that we have collected personal data from a child under age 13, we will delete that data promptly.
Changes to this Notice
iCIMS reserves the right to update or change this Privacy Notice from time to time. If we make material changes to this Privacy Notice, we will post it to our Website home page prior to or at the time of the change becoming effective. We ask that you review the Privacy Notice periodically to stay informed about any updates or changes that we may have made.
You can see when this Privacy Notice was last updated by checking the “Effective Date” displayed at the top of this Privacy Notice.
To ask questions or comment about this Privacy Notice and our privacy practices or if you need to update, change, or remove your personal data or exercise any other rights,