PRIVACY POLICY

Last Updated: May 11, 2022

By visiting our Site, you are agreeing to the terms of this Privacy Policy and the accompanying Terms of Use.

1. About this Privacy Policy

This Privacy Policy describes how taltop.com Inc. (“taltop.com”, “we”, “our” or “us”) and our affiliates handle the data collected and processed using our websites (the “Website”), our mobile applications and our products and services (together, the “Services”). If you do not accept this Privacy Policy or do not meet or comply with the provisions set forth herein, then you should not use our Services. 

2. Who Controls Your Data

taltop.com is a global company based in Israel. taltop.com controls the data collected and processed through our Services. In certain instances, taltop.com acts as a data processor to its clients and is provided Personal Data by such clients acting as the data controller. In such case, we process Personal Data under the direction of that client and have no direct relationship with the individuals whose Personal Data we process. taltop.com may also act as a data processor on behalf of its affiliates. For more information, see Section 4 of this Privacy Policy.

3. Types of Data We Collect

Depending on your interaction with us, meaning, if you are a visitor browsing our Website, or if you have registered as a user of our Services, either as a job seeker (“Job Seeker”) or as someone looking to hire or make available information regarding employment openings (“Job Advertisements”) on your behalf and/or other’s behalf (“Employer”), we collect and process two types of information about you:Personal Data: The is the type of data that identifies you as a natural person, or that may be used, either alone or in combination with other information, to personally identify you as a natural person. Such information may include:

• Your first name, last name, Social Media profile or similar identifier (“Identity Data”)
• Your physical address, email address, social media address, mobile or landline telephone number, location data and other contact information you may provide (“Contact Data”)
• Your username and password, user preferences, profile-linked user-generated content such as Job Advertisements, curriculum vitae (CV)/resume, job searches (keyword(s) and location typed in the search bar or displayed on the job posting), candidate searches, feedback and survey responses (“Profile Data”)
• Your applicant-linked user-generated content such as job applications, curriculum vitae (CV)/resume, cover letter and answers to employers screening questions (“Application Data”).
• Details about your subscription to our Service and payments for such Services (“Transaction Data”) and billing, banking and payment card information (“Financial Data”). However, please note that credit card numbers are not collected by us directly, but by secure payment service providers.
• Certain technical data about the equipment you use to access our Services (“Technical Data”) and the way you use our Services (“Usage Data”). This Technical and Usage Data may be considered Personal Data in certain jurisdictions. We refer you to Section 4 of this Privacy Policy for more information about Technical Data and Usage Data.

Non-Personal Data: This is the type of data that is non-personal and non-identifiable data that cannot personally identify or lead to identifying a natural person. For example, statistics or aggregated information, or any other type of data that can no longer be attributed to you. In the event we combine Personal Data with Non-Personal Data, the combined information will be treated as Personal Data for as long as it remains combined.

Sensitive Personal Data: To use our Services, you are not required to provide us with any Sensitive Personal Data. Sensitive Personal Data includes, for example, information about racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, genetic and biometric data, and data concerning health, sex life or sexual orientation. If you are a Job Seeker responding to a Job Advertisement, sharing your resume with a prospective Employer or answering questions from a prospective Employer while using our Services, please carefully consider the information that you share and ensure that you are not providing any Sensitive Personal Data or other information that is not necessary for your job application or job search.
You are not required by law to provide us with any information. You can always avoid providing us with certain Personal Data; however, you acknowledge that it may prevent us from providing you with certain Services. 

4. How Personal Data and Non-Personal Data are Collected and Why

Personal Data communicated by Employers
When you are using our Services as an Employer, you may provide your Identity Data, Contact Data, Profile Data, Transaction Data, and Financial Data to us when you:

• create an employer account
• post or distribute Job Advertisements using our Services
• if you opt-in to receive newsletters or other communications about new or existing features or functionalities that might be of interest to you
• request information to be sent to you
• use our customer service or support, or make a technical request
• provide feedback to us or respond to a survey
• when you communicate with us on any transactional or other matters

In those circumstances, we use your Personal Data for our legitimate interest and to perform the Services you have requested or to respond to your inquiries and provide you with the support or information you have asked to receive. When you communicate with us over the phone, your calls may be recorded and analyzed for training, quality control, and for sales and marketing purposes. During such calls we will notify you of the recording via either voice prompt or script. When you participate in a survey, we collect information that you provide through the survey. If the survey is provided by a third-party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information. Participation in any such surveys is completely voluntary and you, therefore, have a choice whether to disclose such information. 

Personal Data communicated by Job Seekers
When you are using our Services as a Job Seeker, you may provide us with your Identity Data, Contact Data, Profile Data and Application Data when you:

• create an employer account
• sign up for job alerts
• apply to a Job Advertisement posted on our Website, mobile application or through sponsored advertisements that we have on third party sites
• use our customer service or support, or make a technical request
• provide feedback to us or respond to a survey

In those circumstances, we use your Personal Data for our legitimate interest and to perform the Services you have requested or to respond to your inquiries and provide you with the support or information you have asked to receive. When you subscribe to our email or SMS job alerts, we use your email or phone number, based on your consent, to send you personalized and relevant job listings related to your job search. You may manage your alerts or unsubscribe at any time from our job alerts Services. See Section 8 of this Privacy Policy for details on how to unsubscribe to our Services. When you apply for a job through our Website or mobile application, we collect and use your Application Data, based on your consent, to send to the Employer whose Job Advertisement you responded to. This data is then associated with your Job Seeker account, so you can easily apply for subsequent jobs without having to re-enter your application information every time. Sometimes, when applying for a job, you may be redirected to the Employer’s website or application tracking system. In such a case, we do not collect your Application Data. We process it on behalf of the Employer.

Personal and Non-Personal Data automatically collected from you:
As you interact with our Website or use our mobile application, we may automatically collect technical data about your computer and mobile device. This may include information such as Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used) and other device identifiers, your login data, access dates and times, browser type and version, device information, cookie data, time zone setting, and location data, browser plug-in types and versions, operating system and platform, mobile phone carrier identification, the language your system uses and other technology on the devices you use to access our Services. We refer to this as “Technical Data”. We may also collect information about how you use our Services, such as your browsing actions and patterns, which links you click on, or information that you type into pages or forms we present to you. If you receive email or other forms of electronic communication from us, we use certain tools to capture data related to when you open our messages, click on any links or banners it contains and subscribes to our Services. We refer to this as “Usage Data”. We collect this Technical and Usage Data by using cookies, pixels, server logs, and other similar technologies. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a website is viewed. We may also receive Technical Data and Usage Data about you if you visit other websites employing our cookies and other similar technologies, including on third-party websites where we publish Job Advertisements. See our Cookie Policy for further information. We have a legitimate interest in collecting Technical Data and Usage Data as this allows us to make our Website and mobile applications operate efficiently, to improve our Services, to monitor, detect and prevent fraudulent activities on our Website, to provide you with service offerings that you might find most useful and help us understand which of our Services is the most popular.

Personal Data we receive from third parties
We may receive Personal Data in the form of Technical Data and Usage Data about you from various third parties such as analytics providers. We may also participate in behavior-based advertising. This means that a third party uses technology (e.g., a cookie) to collect information about your use of our Website so that they can provide advertising about products and services tailored to your interests on our Website, or on other websites. However, these non-essential/third-party cookies will not be deployed until you specifically consent to their use through a separate opt-in consent mechanism. You may also create an account or log into your taltop.com account using third-party websites including, but not limited to LinkedIn, Facebook, or Google (“Social Media”). If you do not already have a taltop.com account but log into taltop.com using your Social Media account, this creates a taltop.com account using the same email address used in your Social Media account. If you agree to provide this information to taltop.com, your Social Media account will authenticate you and redirect you to taltop.com. Please note, when you log into taltop.com using your Social Media account, these Social Media will cookie you in order to authenticate you as a Social Media user. By accessing taltop.com through your Social Media account, you understand that these Social Media providers will share certain data detailed in the above paragraph for the purposes of authentication to permit you to access our Website in a secure manner. You may stop this at any point from your Social Media account. This information will be considered taltop.com account information for purposes of your use of our Services.

When taltop.com acts as a data processor
Where taltop.com processes your Personal Data in the capacity of a data processor, and you seek access, or want to correct, amend, or delete your Personal Data, or have other requests, we will provide you with the data controller’s contact information, so you can contact them directly. In rare instances, however, circumstances may necessitate taltop.com to assist you with your question or request. Personal Data that we process as a data processor is retained by us only for the duration required to service the data controller client, and/or in accordance with the instructions from such client, and/or as necessary to comply with our legal obligations.

5. Sharing of Personal and Non-Personal Data

In addition to the specific situations discussed elsewhere in this Privacy Policy, we may share Personal Data in the following situations: 

• Job Seekers and Employers. When a Job Seeker applies for a job through our Website or mobile application, we share their Application Data with the Employer. This may include sharing the Application Data with the employer looking to hire, the agency recruiting on behalf of the employer and/or the external system such as an applicant tracking system used by the employer and/or the agency to manage the hiring of employees. Employer account holders agree to comply with all their responsibilities under applicable data protection laws 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 laws. When an Employer uses our Services, we will share Employer-related information with Job Seekers. This may include publishing Job Advertisements, company pages, and salary information on our Website and mobile applications. We may also share this information on third-party websites.
• Service providers. We share your information with service providers that we use to support our business or help provide our Services to you, including, but not limited to, third parties that host our Website, assist us to verify your identity, perform website and platform maintenance, risk assessments, and security, perform data and web analytics, provide databases, IT services, customer service, payment platforms, and credit card processing, communication services, and email services. Our service providers will be given access to your Personal Data as is reasonably necessary to provide the Website and related Services. Our service providers are contractually obligated to use your Personal Data only at our direction, to handle your Personal Data in confidence, and to not disclose your Personal Data to unauthorized third parties. However, certain of those service providers provide 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.
• Affiliates and acquisitions. We may share information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage.
• Other disclosures with your consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this Privacy Policy.
• Other disclosures without your consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, the safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third-party intermediary.
• Public information. Some of our pages and posts may provide the opportunity to post comments, or reviews, in a public forum. If you decide to submit information on these pages, that information may be publicly available.  see additional information regarding comments in section 14 below.

Except as otherwise stated in this Privacy Notice, we do not sell, trade, rent or otherwise share for marketing purposes your Personal Data with third parties without your consent. We may use or share Non-Personal Data in any of the above circumstances, as well as for the purpose of providing and improving our Service and for commercial use.

6. Retention of your Personal Data

The length of time for which we retain Personal Data depends on the purposes for which we collected and use it and/or as required to comply with applicable laws. Where there are technical limitations that prevent deletion or anonymization, we safeguard Personal Data and limit active use of it. See Section 8 about the storage of your Personal Data.

7. How We Protect your Personal Data

We implement security measures designed to protect your Personal Data from unauthorized access. We apply these tools based on the sensitivity of the Personal Data we collect, use, and store, and the current state of technology. We protect your Personal Data through technical and organizational security measures to minimize risks associated with data loss, misuse, unauthorized access and unauthorized disclosure and alteration. We periodically review our information collection, storage, and processing practices, including technical and organizational measures, to guard against unauthorized access to systems.  Your account is protected by your account password and we urge you to take steps to keep your Personal Data safe by not disclosing your password and by logging out of your account after each use.  Because the internet is not a completely secure environment, we cannot warrant the security of any information you transmit to us or guarantee that information on the Website may not be accessed, disclosed, altered and/or destroyed by breach of any of our physical, technical and/or managerial safeguards. In addition, while we take reasonable measures to ensure that service providers keep your information confidential and secure, such service provider’s practices are ultimately beyond our control. We are not responsible for the functionality, privacy and/or security measures of any other organization. By using our Website, you acknowledge that you understand and agree to assume these risks. You may ask for a list of technical and organizational measures taken to protect your Personal Data by emailing us at:  support@taltop.com.

8. You may take the below actions to change or limit the collection or use of your Personal Data.

• Unsubscribe to Job Alerts. If you wish to unsubscribe to job alerts, you may do so by clicking on the “Unsubscribe from Job Alert” link located at the bottom of any email alert. You can then click on the “Delete” button next to the alert you wish to remove. In the case of SMS or WhatsApp Job Alerts, if offered in your region, you can unsubscribe by replying “STOP” to the messages you received or clicking on the unsubscribe link you received via your mobile device, as the case may be. You may also edit or unsubscribe to job alerts in your account profile, under the “My notifications” tab.
• Unsubscribe to promotional/marketing emails. You may choose to provide us with your email address for the purpose of allowing us to send offers and other promotional/marketing materials to you, as well as targeted offers from third parties. You can stop receiving promotional/marketing emails by following the unsubscribe instructions in e-mails that you receive and also adjust your email preferences in the “My notifications” tab in your account profile. If you decline to receive promotional and/or marketing emails, we may still send you transactional and Service-related messages.
• Purge your account. If you wish to delete all information associated with your account, you may do so by logging into your account, clicking on the “Settings” section, and then on “Purge my account information”. You will no longer have access to any of the data we make available under that account, including but not limited to, search history, job search preferences, saved jobs, jobs that you have applied to, Job Alerts, resume, and any other data associated with the account. You should note that we reserve the right to keep any materials in a closed account as necessary to preserve and protect our rights to the extent permitted by law (for example, to preserve records of a dispute) or to comply with our 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 our systems, although it will not be readily available under your original account. You should also realize that when you apply for a job through our Website or mobile application and you purge your account thereafter, the job application may still be accessible to the Employer who received it, as well as any messages sent to or received from you. If you are a Job Seeker and want to delete a job application performed from our Website, please note that your applications and materials may be controlled by an Employer and we may direct you to that Employer for Personal Data deletion requests where that Personal Data is held by that Employer.
• Device and usage information. If you do not want us to see your device location, you can turn off location sharing on your device, change your device privacy settings, or decline to share location on your browser.

9. Your Privacy rights

Under the European Union (“EU”) General Data Protection Regulation (“GDPR”), EU residents have certain rights with respect to their Personal Data. We provide GDPR-type rights to all our users globally. You can make the following choices regarding your Personal Data:

• Access to your Personal Data. You may request access to your personal information by contacting us at the address described below. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you.
• Changes to your Personal Data. We rely on you to update and correct your Personal Data. Our Website allows you to modify or delete your account profile. If our Website does not permit you to update or correct certain information, you may contact us at the address described below in order to request that your information be modified. Note that we may keep historical information in our backup files as permitted by law.
• Objections/restrictions to your Personal Data. You have the right to object to how Personal Data is processed in relation to public interest/official authority and our legitimate interests as well as direct marketing purposes – including profiling under both. You also have the right to request that processing of your Personal Data be restricted where its accuracy or lawfulness is contested, you need it in response to legal claims or in relation to verification as to whether legitimate interests for processing exist.
• Deletion of your Personal Data. Typically, we retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Where certain grounds apply, the law authorizes you to make a request that your personal information be deleted and triggers our corresponding obligation to comply, unless exceptions apply. Note, however, that we may not always be able to comply with your request for erasure and in such circumstances, will notify our reasons to you.
• Move, copy or export Personal Data. This is known as the Right to Portability. You have the right to request that your Personal Data be forwarded to a third party.
• Provision/revocation of consent. You have the right to provide or decline consent to the processing of Personal Data. If you’ve already provided consent, you also have the right to revoke it. This will not impact the legality of processing prior to revocation. If you revoke your consent for the processing of Personal Data, then we may no longer be able to provide you Services. In some cases, we may deny your request to revoke consent if the law permits or requires us to do so – such as when we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described below.

10. Complaints

We are committed to resolving valid complaints about your privacy and our collection or use of your Personal Data. For questions or complaints regarding our data use practices or this Privacy Notice, please contact us as provided below. Should you remain unsatisfied with our response to your complaint, you have the right to contact your local data protection authority. Please note that your rights are not absolute, meaning that in some circumstances, exceptions exist under applicable law. The law may provide exemptions from requests involving your Personal Data. For example, in order to provide our Services to you, deleting your Personal Data may prevent you from accessing or using such Services. You may exercise these rights by contacting us at  support@taltop.com. We will respond to any such request in a timely manner as specified by the GDPR. If we need more time to fulfill your request, we will let you know in advance. We will not exceed the legally specified time limit under any circumstance. Note that, as required by law, we will require you to prove your identity. We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name or other account information. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files. In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. We will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us.

11. International Data Transfers

Our company operates globally and has a global infrastructure. We may store or process your Personal Data in various countries, including the United States, Canada, and the European Economic Area (“EEA”), depending on the type of Personal Data processed. If you visit our Websites or use our Services from locations outside of the United States, please note that any information you provide to us through your use of our Websites or Service may be transferred to and processed in countries other than the country from which you accessed our Websites or Services. We will take the necessary steps to ensure that international transfers of Personal Data meet all requirements under applicable data protection laws. When Personal Data collected within the EEA is transferred outside the EEA, we will take the steps necessary to ensure that the transfer of such data provides sufficient safeguards. We will do so by transferring Personal Data to jurisdictions that, according to the European Commission and the Court of Justice of the European Union, offer an adequate level of protection to Personal Data or pursuant to standard contractual clauses approved by the European Union. Personal Data transferred outside the EEA for processing by AWS on its servers in the United States, and among the Company’s affiliates, in both cases is accomplished pursuant to standard contractual clauses approved by the European Union. If you would like to understand more about these arrangements and your rights in connection therewith, please contact our Data Protection Officer at: support@taltop.com.

12. Children and Minors

taltop.com does not knowingly collect Personal Data from children under the age of thirteen (13). If we learn that we have collected personal information from a child under age thirteen (13), we will delete such information as quickly as possible. If you believe that a child under the age of thirteen (13) may have provided us with personal information, please contact us at: support@taltop.com. By using the Website, you represent that you are at least eighteen (18) years old and understand that you must be at least eighteen (18) years old in order to create an account and/or purchase the goods and/or services through the Website.

13. Third Party Websites and Services

We have no control over the privacy practices of websites or applications that we do not own. We are not responsible for the practices employed by any websites and/or services linked to and/or from our Website, including the information and/or content contained therein. Please remember that when you use a link to go from our Website to another website and/or service, our Privacy Notice does not apply to such third-party websites and/or services. Your browsing and interaction on any third-party website and/or service, including those that have a link on our Website, are subject to such third party’s own rules and policies. In addition, you agree that we are not responsible and do not have control over any third parties that you authorize to access your Personal Data. If you are using a third-party website and/or service and you allow them to access your Personal Data, you do so at your own risk.

14. Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profiles. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

Visitor comments may be checked through an automated spam detection service.

15. Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

16. Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

17. Changes to our Privacy Notice

In general, changes will be made to this Privacy Notice to address new or modified laws and/or new or modified business procedures. However, we may update this Privacy Notice at any time, with or without advance notice, so please review it periodically. We may provide you additional forms of notice of modifications and/or updates as appropriate under the circumstances. Your continued use of the Website after any modification to this Privacy Notice will constitute your acceptance of such modifications and/or updates. You can determine when this Privacy Notice was last revised by referring to the date it was last “Updated” above.