Last updated: [24th Oct 2018]
Part A: General Overview
[KigoSpaces] (“us”, “we”, or “our”) operates the [KigoSpaces.Com] website (the “Service” or “Site”). KigoSpaces is owned by Ken Martin who operates as a sole trader in the UK. Any queries please send any correspondence to 62 Chatham Rd, Birmingham B32 2PJ or email: firstname.lastname@example.org.
This page informs you of our policies regarding the collection, use and disclosure of Personal Information when you use our Service.
Information Collection And Use
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information (“Personal Information”) may include, but is not limited to:
- Email address
- Telephone number
We collect information that your browser sends whenever you visit our Service (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages and other statistics.
Google AdSense & DoubleClick Cookie
Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer’s hard drive.
We use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
Links To Other Sites
We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Our Service does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from children under 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Information, please contact us. If we discover that a child under 18 has provided us with Personal Information, we will delete such information from our servers immediately.
Compliance With Laws
We will disclose your Personal Information where required to do so by law.
Part 2: Detailed Overview
1.1 The KigoSpaces Entities Responsible for Your Information
1.2 Personal Data and Non-Personal Data
1.5 KigoSpaces’s approach to privacy and the General Data Protection Regulation (GDPR)
- Information Collected
You provide different types of information in order for KigoSpaces to provide our services, products and features to you.
2.1 Information You Provide to KigoSpaces
From Your Account
We collect data from you when you create a KigoSpaces 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 KigoSpaces 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 KigoSpaces and answers you give to any questionnaires sent to you, which you answer.
Through Your Activity on KigoSpaces
In addition, as part of the standard operation of the Site, KigoSpaces 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 KigoSpaces, the titles of jobs you search, click on or apply to, where those jobs are located, salary interest or experience, the general salary range or 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. When you submit a photo as part of your profile, this may include the provision of the location data of where the photo was taken. KigoSpaces seeks your consent at the time of such provision, and such processing will only be performed where consent is secured.
When Providing Employer Information
If you are an Employer, KigoSpaces may request that you provide certain Personal Data to KigoSpaces in order to verify your account. This information may include, but may not be limited to, your Business Registration information, or a utility bill, the name and email address of an Employer representative.
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 KigoSpaces only has access to the last four digits of Employer credit card numbers, and does not store full credit card numbers.
Information Collected When You Apply for Jobs or Access KigoSpaces from Some Third-Party Websites we can provide you with improved job listing searches, job listing recommendations and product features.
When You Log In or Use KigoSpaces from Some Third-Party Sites
You may also create an account or log in to your KigoSpaces account using third-party websites including, but not limited to, Facebook or Google. If you do not already have a KigoSpaces account but log in to KigoSpaces using your Facebook or Google account, this creates an KigoSpaces account using the same email address used in your Facebook or Google account. If you agree to provide this information to KigoSpaces, Facebook or Google will authenticate you and redirect you to KigoSpaces’s Site.
Please note, when you log in to KigoSpaces 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 KigoSpaces 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 KigoSpaces 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 KigoSpaces 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 KigoSpaces, including but not limited to your name, profile picture, public profile information, and email address. For those users that avail of KigoSpaces Family specifically, Facebook may ask for permission to share your friends list, and KigoSpaces may use some of this data to connect you with other users of KigoSpaces 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 KigoSpaces May Receive from Third Parties
2.4 Storage of Your Information
2.5 What Personal Data is Required
KigoSpaces 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 KigoSpaces 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 KigoSpaces Collects Your Personal Data
KigoSpaces 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 a Contract
Most of the Personal Data processed by KigoSpaces 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 KigoSpaces matches Job Seekers with Employers.
A second ground relied upon by KigoSpaces for other types of processing of your Personal Data is that it is necessary for the purposes of legitimate interests pursued by KigoSpaces. Such legitimate interests will include where KigoSpaces 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. KigoSpaces 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 types of processing is that it is necessary in order to allow KigoSpaces comply with a legal obligation. An example of this would be where KigoSpaces is required to retain business records for fixed periods of time in order to comply with local legal requirements.
- Limitation of Use or Disclosure of Personal Data
3.1 Where a Job Seeker Wants to Close a Job Seeker Account
When a Job Seeker closes an account, the Job Seeker 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 Job Seeker has applied to, job alerts, CV, and any other data associated with the account. If the Job Seeker uses the same email address to set up a new account, this data from a previous account will not become available to the Job Seeker again. Please also note that closing your Job Seeker account may result in you losing access to all KigoSpaces products and the ability to utilize the “Log in with KigoSpaces” feature found on certain third party sites.
KigoSpaces 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 KigoSpaces systems, although it will not be readily available under the Job Seeker’s original account name. When the Job Seeker presses the close account button on the dashboard, KigoSpaces 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
3.3 Where a Job Seeker Wants to Delete a Job Application
If a Job Seeker wants to delete a job application performed on KigoSpaces’s Site, they are advised to contact the prospective Employer directly to request deletion of their application. For job applications which you, the Job Seeker submit through KigoSpaces (including the use of an KigoSpaces Apply button) to an Employer, (with related materials submitted), please note:
1) that your applications and materials may be controlled by an Employer;
2) we may direct you to that Employer for Personal Data deletion requests where that Personal Data is held by that Employer;
and 3) KigoSpaces depends on the Employer or the Employer’s agent to provide KigoSpaces with the correct destination for all applications.
3.4 Where the Employer Contact Details Provided to KigoSpaces Are Incorrect
In the event that the electronic destination provided to KigoSpaces is incorrect, your application materials will not be sent to the intended recipient of the application. KigoSpaces 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
The Site is not for use by anyone under the age of 18. To use the Site you agree that you must be the minimum age (described in this paragraph below) or older.
The minimum age for these purposes shall be 18, however if local laws require that you must be older in order for KigoSpaces to lawfully provide the services in the Site to you then that older age shall apply as the applicable minimum age. In all jurisdictions outside the European Union, if you are under the age of 18 or the age of majority in your jurisdiction, you must use KigoSpaces under the supervision of your parent, legal guardian or responsible adult. KigoSpaces adopts a range of measures to try to ensure that we do not accept individuals who do not meet the minimum age and any other applicable age requirements. If you do not satisfy these age requirements, please email admin @ KigoSpaces.com
- Purposes, Uses and Disclosures of Information
1) provide our services, products and features to you, to help Job Seekers 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, KigoSpaces may use your contact information to (i) create an account; (ii) send you job alerts; and (iii) send you information about KigoSpaces, including promotional materials. KigoSpaces may use third-party partners to perform these activities on KigoSpaces’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 KigoSpaces recommends for you, KigoSpaces Targeted Ads, companies you may be interested in following, or other actions you may want to take on the Site.
4.2 Giving You Relevant Search Results and Recommended Jobs
In order to optimize our services, products and features for you, KigoSpaces 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 KigoSpaces thinks you may be interested in, and display content according to your preferences. KigoSpaces may return different results for the same search query and has full discretion with respect to the job listings it presents in response to any particular search.
4.3 Your Contact Information
When you give KigoSpaces contact information (such as your name and email address) and other forms of Personal and Non-Personal Data, you agree that KigoSpaces may utilize this information for the purposes outlined in sections 4, 5 and 9, to the extent applicable. In particular, you agree that KigoSpaces may, as part of its services to you, communicate with you, or initiate communication with you on behalf of a third party, through your KigoSpaces 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 KigoSpaces or that KigoSpaces may otherwise obtain from third-party resources.
4.4 Your CV Information
Private CVs are only made available to those to whom the Job Seeker 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.
Public CVs are available to anyone with access to KigoSpaces’s CV search application, in order to increase the visibility of that CV and help KigoSpaces 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 KigoSpaces and for whom KigoSpaces has no responsibility. If you post a public CV on KigoSpaces, please note that although KigoSpaces 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 authorize KigoSpaces to remove your name from your public CV, in certain instances. KigoSpaces may also change the display of your CV from public to private in certain instances to maintain the quality of the CV database.
Changing Your CV Privacy Settings
You will be given the option to make your CV private or public when you place your CV on KigoSpaces. You may adjust this at any point by editing your privacy settings on KigoSpaces. Where you adjust your CV from public to private, KigoSpaces does not warrant how often third-party search engines will update their caches, which may continue to contain your CV information.
4.5 Matching Job Seekers With Employers
You acknowledge that KigoSpaces 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 KigoSpaces product or service (including by displaying or otherwise making available potentially relevant job descriptions and CVs to Job Seekers and Employers.
If you have a KigoSpaces account or aKigoSpaces-hosted CV, you agree that KigoSpaces may contact you or suggest you or your public CV to Employers that might be interested in a person who matches your behaviour on KigoSpaces.
4.6 Preventing Fraud and Spam
For example, KigoSpaces is subject to the investigatory and enforcement powers of the Information Commissioner’s Office,UK.
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
KigoSpaces further reserves the right to conduct investigations to determine whether you are perpetrating a scam, spamming KigoSpaces or its users, or otherwise conducting fraudulent activity on KigoSpaces by various means, including but not limited to investigating your functionality by setting up profiles and names that belong to KigoSpaces. KigoSpaces also reserves the right to turn over any information gathered via such investigations to the police or other third party if KigoSpaces has a good faith belief that you are using the Site in violation of these terms.
KigoSpaces reserves the right to verify and confirm the identity of any party associated with an email relay. This includes but is not limited to verifying the identity of the sender of an email with the Employer agents associated with that email address on the relevant Job Listing.\
4.7 Facilitating Payment
If you provide credit, debit or other payment card and related details to us in order to make a payment, KigoSpaces will use such information only for the purpose of processing the payment . Any credit card and related billing and payment information that you provide to KigoSpaces may be shared by KigoSpaces with companies who work on KigoSpaces’s behalf, such as payment processors and/or credit agencies, solely for the purposes of checking credit, effecting payment to KigoSpaces and servicing your account.
4.8 Automated Processing of Your Personal Data
In order to optimize the performance of the KigoSpaces Site and services for users, KigoSpaces 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 KigoSpaces’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 KigoSpaces to provide its services to Job Seekers and Employers, or in other cases on the basis of a user’s consent.
4.9 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, to protect our users and better understand their needs, and to optimize the services and the users’ experiences. These third parties may include (but are not limited to) service providers and vendors.
KigoSpaces may transfer your Personal Data in limited situations to certain third-party vendors that assist KigoSpaces with protecting our users and maintaining the quality of our services, products and features provided to those users.
KigoSpaces may also share any credit card and related billing and payment information that you provide to KigoSpaces with companies who work on KigoSpaces’s behalf, such as payment processors and/or credit agencies, solely for the purposes of checking credit, effecting payment to KigoSpaces and servicing your account.
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 non-negotiable; 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 KigoSpaces in a manner that is intended to make that content publicly available and searchable by individuals, KigoSpaces reserves the right to aggregate and share that information with third parties. For example, if an Employer posts a job on KigoSpaces, KigoSpaces may share that job posting or information contained within that job posting with third parties, at KigoSpaces’s discretion and subject to agreement between KigoSpaces and any such third parties. KigoSpaces also reserves the right to share information aggregated from public sources in this capacity.
Third-Party Sites You Link to from KigoSpaces
If you apply to a job using a unique referral link provided to you by an individual from the Employer company to which you are applying, the individual at the Employer company who is associated with that referral link will be notified once you apply. This allows that individual to add details as part of your referral process in regards to a given job application.
Transfers of Personal Data for individuals in the EU and Switzerland
- Additional Uses and Disclosures of Non-Personal Data
KigoSpaces seeks to use reasonable security measures to help protect against the loss, misuse and alteration of the Personal Data under KigoSpaces’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.
“Cookies” are small pieces of information that are stored by your browser on your computer’s hard drive.
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.
kigospaces 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.
- Acquisitions and Other Reorganizations
Exercising Rights With Respect to Personal Data
KigoSpaces 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
KigoSpaces users are able to edit and update most of their Personal Data held by KigoSpaces on the Site, and if you have any queries or complaints we encourage you to contact us here.
Alternatively, if you do not wish to do this you may make a formal request to have KigoSpaces rectify any inaccurate Personal Data on your behalf by sending an email to email@example.com email address associated with your account.
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 admin @ KigoSpaces.com.
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 KigoSpaces. In order to do so please send an email to firstname.lastname@example.org the email address associated with your account.
10.3 The Rights of Access to and Portability of Your Personal Data
KigoSpaces users are able to access most of their Personal Data held by KigoSpaces on the Site, and if you have any queries we encourage you to contact us at email@example.com
Alternatively, if you do not wish to do this you may make a formal request to access your Personal Data held by KigoSpaces. In order to do so, please send an email to firstname.lastname@example.org the email address associated with your account, and paste the following sentence in your email: “I am requesting to access my personal data.” KigoSpaces 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
KigoSpaces users are able to edit and update most of their Personal Data held by KigoSpaces on the Site, and if you have any queries we encourage you to contact us email@example.com.
Alternatively, if you do not wish to do this, you may make a formal request delete your Personal Data held by KigoSpaces. In order to do so, please email to firstname.lastname@example.org email address associated with your account, and paste the following sentence in your email: “I am requesting to delete my personal data.” Once your request has been confirmed, KigoSpaces will initiate the necessary steps to execute this exercise, including the deletion of your KigoSpaces account. Where the deletion request relates to Personal Data that you previously requested be made public on KigoSpaces (e.g. a Job Seeker 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 KigoSpaces 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 KigoSpaces confirming your request. Where permitted, please note there may be a charge for subsequent requests from the same individual, which will be determined by KigoSpaces and only imposed to the extent permitted by applicable law.
Data from Individuals in the EU and Switzerland
- Independent Dispute Resolution For Individuals in the EU and Switzerland
If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.
There may be a possibility, under certain limited conditions, for EU and Swiss individuals to invoke binding arbitration before the Privacy Shield Panel.
Opting Out of Receiving Marketing Communications
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 clicking unsubscribe (or an equivalent action) where applicable, or 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.
General Inquiries and Complaints
15.1 Contacting KigoSpaces
To contact KigoSpaces, you may contact either company via our site contact form or by sending an email to firstname.lastname@example.org
If you believe your data protection rights have been infringed by KigoSpaces, you have the right to complain to the appropriate data protection supervisory authority in your jurisdiction. For example if you are in the EU, KigoSpaces’s main establishment in the EU is KigoSpaces UK, and it is regulated by the Information Commissioner’s Office, in which case you should consult with for these purposes.
KigoSpaces Terms of Service Introduction
Any references to “KigoSpaces” or “we” in this Agreement shall mean the applicable entity as set forth above.
The Site is made available for use only by individuals searching for employment openings (“Job Seekers”), by individuals and/or organizations seeking to make available information regarding employment openings, on their behalf or other’s behalf, including but not limited to agencies purchasing for multiple parties (“Employers”), and by individuals and/or organizations seeking to participate in the KigoSpaces Publisher Program (“Publishers”). You acknowledge and agree that your license to use the Site is automatically revoked upon your attempt to use the Site for any other purpose. If you are accessing or using the Site in your capacity as an employee or other representative of an Employer or Publisher, you are agreeing to this Agreement on behalf of yourself and such Employer or Publisher, as applicable, and you represent and warrant that you have the authority to bind such Employer or Publisher, as applicable, to this Agreement.
We may change this Agreement by notifying you of such changes by any reasonable means, including by posting a revised Agreement through the Site. Any such changes will not apply to any claim brought prior to the date on which we posted the revised Agreement incorporating such changes, or otherwise notified you of such changes. Your access to or use of the Site following any changes to this Agreement will constitute your acceptance of such changes. The “Last Updated” legends in each section of the terms and conditions indicate when this Agreement was last changed. We may, at any time and without liability, modify or discontinue all or part of the Site (including access to the Site via any third-party links); charge, modify or waive any fees required to use the Site; or offer opportunities to some or all Site users.
This Agreement hereby incorporates by this reference any additional terms and conditions posted by KigoSpaces through the Site. See our Terms of Service.