Privacy Policy
1. Important information and who we are
Purpose of this privacy policy
Welcome to inkscroll’s privacy policy. We respect your privacy and are committed to protecting your personal data. This privacy policy explains how we process your personal data when you visit our website or app or use our services and tells you about your privacy rights and how the law protects you.
This website and the inkscroll app are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
If you are a California resident, please see our California Resident Privacy Notice for supplemental information and disclosures regarding your rights.
Controller
inkscroll Ltd, trading as inkscroll is the data controller and is responsible for your personal data (collectively referred to as "inkscroll", "we", "us" or "our" in this privacy policy).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Contact details
Full name of legal entity: inkscroll Ltd, trading as inkscroll.
E-mail address: dpo@inkscroll.com
Postal address: inkscroll, 30 Cliddesden Court, Basingstoke, RG21 3ES
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review and may update this policy from time to time without notice. If we materially change the ways in which we use or share personal data previously collected from you through the website, app and services, we will notify you through the website, app and services, by email, or other communication.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website and the inkscroll app may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website or app, we encourage you to read the privacy policy of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, email address, address, date of birth, telephone number.
- Contact Data includes address, email address and telephone number.
- Engagement Data includes details about how you use our platform, jobs that you have seen, applied for and/or are interviewing for, feedback about your progress in relation to job applications, and messages that you send to and/or receive from recruiters on our platform.
- Profile Data includes your username and password, your interests, preferences and feedback, languages that you speak, your education and work history (including details of roles, projects and your salary (if you choose to provide it)), and your job search preferences.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website or the app.
- Usage Data includes information about how you use our website, app, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Special Categories of Data includes details about your ethnicity, sexual orientation and gender identity. By providing this data, you consent to it being processed as further described in this privacy policy.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
3. How your personal data is collected
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact, Profile, Engagement, Marketing and Communications and Special Categories of Data by entering data on our website or app, or by corresponding with us by post, phone, email or otherwise.
- Automated technologies or interactions. As you interact with our website and app, we will automatically collect Technical Data and Usage Data. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources, including information sent to us by employers that use our platform and publicly available sources such as LinkedIn.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
- Where we have your consent, when processing Special Categories of Data or when the law requires us to seek your consent before sending marketing emails to you. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below a description of the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose / Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
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| To register you as a new customer and allow you to access our website, app, and services, including our Qualify to Apply (Q2A), job matching and career coaching services. |
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| To manage our relationship with you which may include contacting you with updates or information about our service (but excluding marketing). |
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| To operate, administer and protect our business, this website and the app (including dealing with our customers, troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). |
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| To deliver relevant website and app content and advertisements to you, and measure or understand the effectiveness of the information we serve to you. |
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| To use data analytics to improve our website, app, products/services, marketing, customer relationships and experiences. |
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| To make suggestions and recommendations to you about roles, companies, courses that may be of interest to you, and to allow companies to reach out to you about roles that may be of interest. |
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Tailored Content and Marketing
We may use your Identity, Engagement, Profile, Technical, Usage and Special Categories of Data to form a view on jobs or services that you may be interested in, or that may be suitable for you and may display relevant content on our website or app, or send it to you by email. You may also receive marketing communications from us if you have opted in to receive marketing, or if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
Opting out
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or notification messages at any time by turning the notification off in your account settings.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
When processing your personal data as described above, we may share your personal data with the parties set out below:
- Third party employers that use our website and services to select and recruit candidates. Those third parties will process any personal data that we provide to them as data controllers.
- Service providers acting as processors who provide IT, software and/or system administration services.
- Professional advisers acting as processors including our lawyers, bankers, auditors and insurers who provide us with consultancy, banking, legal, insurance and accounting services.
- When required by law or regulation, HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
Some of the suppliers that we use to operate our services, and some of the employers that use our website are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have internal procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long we will use your personal data
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
As a user of our products, you may have certain Personal Data rights. All users of inkscroll, regardless of location, may exercise these rights with some limitations, as set out in this Privacy Policy. These rights are provided only to human account holders, and are not available to employers or other legal entities, except as required by law. If permitted by the law, a third-party is able to make a request on your behalf.
We verify all requests through email before actioning them and reserve the right to deny a request where we are unable to verify your identity satisfactorily. This also applies to requests submitted on your behalf by someone else.
Although inkscroll offers these rights to all its users, subject to applicable laws, Employers may not offer the same rights. You should consult your local laws and the laws in the Employer’s location to understand what your rights are regarding your application materials and other Personal Data of which the Employer is the data controller.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are to:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
The Right of Access to and Portability of Your Personal Data
You may make a formal request to access (also referred to as the “right to know”) your Personal Data by emailing us from the email address associated with your account. You are able to access much of your Personal Data by viewing it directly in your account.
You have the right to request that we disclose the Personal Data we collect, use, disclose and “sell” or “share” (for the purposes of CCPA and as explained here) about you. We will provide your Personal Data to you in a portable format. This enables you to take your data from us in an electronically usable format and to transfer your data to another party in an electronically usable format. If you have interacted with us using more than one email address, please submit a separate request for each email address so that we may provide this personal data as well.
The Right to Rectify Your Personal Data
You have the right to rectify (update or correct) your Personal Data. You can modify much of your Personal Data by editing your account profile information directly.
You may also make a formal request to have inkscroll rectify any inaccurate, incomplete, or outdated Personal Data on your behalf by sending an email from the email address associated with your account.
The Right to Delete Your Personal Data
You have the right to request that we delete your Personal Data. Also known as the “right to erasure”, Users may close or permanently delete their account. You are able to delete much of your Personal Data by removing it from your account directly. If you wish to close your account, please click the “close my account” option on our support form page.
You may request the permanent erasure of your Personal Data processed by our site via our support form. You may also request that we delete your Personal Data by sending an email to us from the email address associated with your account.
Deletion of your Personal Data may have additional effects on your account. For example, if you have used Qualify to Apply for a job listed in our App, you may not receive certain communications associated with your application from us or from other users of our Site or affiliated sites. Deletion of your Personal Data does not affect messages we process on behalf of others in connection with their use of our site, and they may continue to have access to all messages sent to or received from you.
By making a Personal Data deletion request, you acknowledge that you will be removed from consideration for all active sweepstakes, contests, prize draws, and other promotions.
Please note that a deletion request only affects your Personal Data. If you submit a deletion request against your Employer account, we will only delete your Personal Data, and any non-Personal Data such as information about your company will not be deleted.
The Right to Object to or Restrict the Processing of Your Personal Data
You have the right to object to and to request the restriction of the processing of your Personal Data.
Where we rely on legitimate interests as a legal basis to process your Personal Data, you can object to this processing and request that we no longer process your Personal Data in this way, unless we have compelling legitimate grounds which override your rights.
You also have the right to object to automated processing, including decision-making and profiling, which produce a legal effect or similarly significant effects.
If you wish to make a formal request to object to or restrict the processing of your Personal Data, please email us.
Withdrawing Consent
Where we rely on your consent to process your Personal Data, you have the right to withdraw your consent at any time. Instructions on how to withdraw consent will be explained to you at the time that you are asked to provide your consent.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
Time limit to respond
We try to respond to all legitimate requests within 28 days. Occasionally it could take us longer than 28 days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Version v.1.02. Last updated: 4 October 2023