Leo privacy and cookies policy

Version (Effective): January 1, 2021

This Privacy and Cookies Policy applies to all data collections and other data processing of Talentd Group LTD, in particular through www.hirewithleo.com ​ and through its service platforms app.hirewithleo.com, jobs.hirewithleo.com and briefbuilder.recruitd.com (each referred to herein as a “Site”) owned and operated by it. For purposes of this Privacy Policy any reference to “Leo” (or “our” or “us” or “we”) shall mean Leo (collectively, “Leo” or “Company”). This Privacy Policy describes how Leo collects, uses, shares and safeguards the personal data you provide to us. It also describes your choices regarding use, access and correction of your personal data. The use of personal data collected through our service shall be limited to the purpose of providing the Leo service for which the customer has engaged Leo as set out in the Master Subscription Agreement, Terms of Service, and other agreements with the customer and this Privacy Policy (“Leo Service” or “Service”).


    1. We collect the following categories of personal data from our customers, customers’ candidates and Site visitors:

      1. Personal data – Included in this category are classes of data which identify an individual and their personal characteristics. Examples are names, addresses, job title, employer, contact details, age, sex, date of birth, physical descriptions, identifiers issued by public bodies, e.g. SSN and NI numbers. We may collect names, email addresses and contact information of visitors who register for the Leo Community, in blog entries and of our customers’ users and their recipients. For our customers, we may also collect information about a customer’s business such a company name, company size, business type, and contact information.
      2. Education and professional training information – Included in this category are matters which relate to the education and professional training of an individual. Examples are academic records, qualifications, skills, training records, and professional expertise.
      3. Employment information – Included in this category are matters relating to the employment of an individual. Examples are business role, employment and career history, recruitment and termination details, attendance record, health and safety records, performance appraisals, training records, agency employer, security records or other information necessary to determine an individual’s fitness for employment.
      4. Financial details – Included in this category are matters relating to the financial affairs of an individual. Examples are income, salary, billing rate, payments, benefits, bank or other information necessary to process payroll for an individual. For our customers, information may also include payment processing information such as credit or debit card number, bank information, and billing address.
      5. Goods or services provided – Included in this category are classes of data relating to goods and services which have been provided. Examples are details of the goods or services supplied, licenses issued, agreements and contracts.
      6. IT information – Included in this category is any information relating to an individual’s use of technology or software including IP addresses, any information about the computing or mobile device an individual is using, location data gathered from such devices, connection data, usernames and passwords, and social media handles.
      7. Special Categories – Included in this category are classes of data that are considered sensitive data, personally identifiable information, or sensitive personal data under applicable law. This category of personal data is typically collected to comply with legal requirements or to determine fitness for employment.
      8. We may also collect from you, personal data about your contacts such as email addresses. If you believe that one of your contacts has provided us with your personal data and you would like to request that it be removed from our database, please contact us at privacy@Leo.com.
    2. Personal data is collected and used for Leo’s legitimate business purposes and to comply with the Company’s contractual and legal obligations, including establishing, managing and providing the Leo Service to our customers. Personal data is used by Leo for the purposes described in this Privacy Policy, or for additional purposes that Leo has advised you of, and / or for which Leo has obtained your consent with respect to the use or disclosure of your personal data. Specifically, we use the personal data collected only for the following purposes:

      1. Provide the Service to our customers, including through third parties.
      2. Facilitate the services provided to our customers by Leo partners.
      3. Keep records of customer activity.
      4. Keep records of customer information.
      5. Administer a customer's accounts, including payment.
      6. Respond to a customer's service or support requests.
      7. For marketing, promotional and sales purposes.
      8. For data security purposes.
      9. For machine learning and product enhancement purposes.
      10. Leo does not use personal data for automated decision making.
    3. We will only share your personal data with third parties (our agents) in the ways that are described in our customer agreements and this Privacy Policy. We do not sell your personal data to third parties. Additionally, our employees are trained and subject to confidentiality obligations and only have access to personal data as necessary.
    4. We may email information regarding updates to the Service or service offerings to our customers in accordance with the terms and conditions of each customer’s agreements with us or site visitors in accordance with the terms described in this Privacy Policy.
    5. Other third parties, such as content or third party service providers, may provide content or services through the Service and may need access to your personal data to provide their services to you. Customers will be using a Service to host data and information. Leo will not use or disclose your personal data, except (i) to the extent necessary to provide the Service to you or as requested by you, or (ii) pursuant to law, as determined by Leo in its sole discretion, or (iii) by a court order, or (iv) in connection with third party cookies as described in Section 2.3.5 of this Privacy Policy. Individual customer or customer candidate records may at times be viewed or accessed by Leo’s authorized employees or agents only for the purpose(s) of (i) providing the Service and related professional services to customer or customer candidates, (ii) resolving a support issue affecting any of them, (iii) to inspect and resolve a suspected violation of customer agreements with a customer, or (iv) as may be required by law, as determined by Leo in its sole discretion, judicial proceeding, subpoena, legal process or binding court order. We also reserve the right to disclose your personal data when we believe, in our sole discretion, that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, subpoena, court order, or legal process.
    6. Personal data may be disclosed or distributed to another party with which Leo enters, or may enter, into a corporation transaction. If Leo is acquired in a merger, acquisition, or sale of all or substantially all its assets, you will be notified via email, on our Site and/or by a prominent notice on our Service of any change in the uses of your personal data, as well as any choices you may have regarding your personal data. The disclosure of personal data to another party as set forth herein may involve the transfer of such personal data outside the state, province, country or other jurisdiction in which Leo stores or otherwise processes personal data, subject to Leo taking steps to provide that any such transfer is made only in compliance with applicable laws. In the unlikely event of a bankruptcy, insolvency or liquidation, the database containing personal data may be treated as an asset of Leo and may be subject to transfer to a third party.
    7. Leo may disclose personal data to companies that assist us in providing our Service or that partner with us to provide you their services or content. In this context, any such transfers to third parties are governed by our vendor agreements with them, which provide standards of care for the protection for personal and confidential information that are not less stringent than the standards contained in our customer agreements, and in no event, less than a reasonable standard of care in accordance with any applicable law. Such third-party companies are authorized to use your personal data only as necessary to provide these services to us and/or you and for the purposes for which the personal data was collected. Personal data may be transferred to third parties outside the state, province, country or other jurisdiction in which Leo stores personal data, subject to Leo taking steps to provide that any such transfer is made in full compliance with applicable laws. In the case of partners with whom you contract directly, their policies regarding personal data will govern your relationship with them as stated in the applicable agreement between you and the partner and we will not be responsible for any actions or omission of these partners.
    8. Customers are solely responsible for maintaining the confidentiality and security of their user registration and password. Customers or Site visitors may opt-out of receiving sales, promotional or advertising emails from us by selecting the opt-out link located in the message body of all our electronic communications. Customers or Site visitors may also email privacy@Leo.com directly with a request to be removed from such communications. We may also track and analyze information that doesn’t directly identify you as a person and aggregate usage and volume statistical information from our Site visitors, customers’ candidates and customers and provide such information in aggregated form to third parties.
    9. We are a service provider to our customers and have no direct relationship with the customer candidate or any individual whose personal data a customer processes. If you are a candidate or individual of one of our customers and would no longer like to be contacted by a person or entity that uses our Service, please contact the customer that you interact with directly. If you are a customer and would like to update your account, please contact us at privacy@Leo.com ​.
    10. Marketing:​ Leo may also ask website visitors who register for the Leo Community, to provide certain information, such as email addresses to use and receive content from the site. Leo will provide these visitors with the ability to opt-in or opt-out of future communications from the Company as required by applicable law. If you would like to discontinue receiving this information, you may update your email preferences by using the “Unsubscribe” link found in emails we send to you or at your member profile on our Site or by contacting us at privacy@Leo.com ​​.

    1. Technologies such as cookies or similar technologies are used by Leo and our partners, affiliates, or our service providers. These technologies are used in analyzing trends, administering the site, tracking users' movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
    2. Log in files​: We gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream data, the files viewed on our site (e.g., HTML pages, graphics, etc.), to analyze trends in the aggregate and administer the Site. We do link these automatically-collected data sets to personal data of you that we may have already stored.
    3. Cookies:​ ​We use cookies to remember users' settings (e.g. language preference), and for your authentication when you visit the Site or use the Service, as the case may be. The following information will help you to understand the different types of cookies used:

      1. Strictly necessary​ cookies are required for the operation of the Site. These include, for example, cookies which are necessary for users to create an account or login to secure areas of the Site, and cookies that are required to show error or success messages to users.
      2. Session cookies​ containing encrypted information to allow the system to uniquely identify you while you are logged in. Session cookies exist only during an online session. They disappear from your computer when you close your browser software or turn off your computer. This information allows Leo to process your transactions and requests. Session cookies help us make sure you are who you say you are after you’ve logged in and are required to use the Leo application.
      3. Persistent cookies​​ that only Leo can read and use, to identify the fact that you are a Leo customer or a visitor, who has registered for the Leo Community, to identify and maintain your preferences such as language, country and last check out or to receive certain types of content. Persistent cookies remain on your computer after you’ve closed your browser or turned off your computer. They include such information as a unique identifier for your browser. We are careful about the security and confidentiality of the information stored in persistent cookies. For example, we do not store account numbers or passwords in persistent cookies. Users or visitors who disable their Web browsers’ ability to accept cookies will be unable to use all aspects of our service or the Leo Community.
      4. Targeting cookies​ which store a user’s username, the referring user if using the referral network and the referral source to the Site.
      5. The following ​third party, performance, and targeting cookies​ could be used:

        1. HubSpot​ - the Site uses cookies from HubSpot to track user behaviors and market to users based on their behaviors.
        2. DoubleClick​ - the Site uses cookies from DoubleClick to track user behaviors and market to users based on their behaviors.
        3. Intercom ​- the Site uses cookies from Intercom to track user behaviors and market to users based on their behaviors.
        4. Google Analytics​ - the site uses cookies from Google Analytics to track anonymous interactions and visits.
      6. Opt-out:​ You can control the use of cookies at the individual browser level. If you reject cookies, you may still use our Site, but your ability to use some features or areas of our Site may be limited. Many browsers allow a private mode to be activated through which the cookies are always erased after the visit. Depending on each browser, this private mode can have different names. The following is a list of the most common browsers that support the minimum recommended level of encryption TLS 1.2. Each browser type has a different name for “private mode”:

        1. Internet Explorer 11 ​and later versions = In Private
        2. Safari 7 ​ ​and later versions = Private Navigation/Browsing
        3. Opera 17 and later versions = Private Navigation/Browsing
        4. Mozilla Firefox 27​ and later versions = Private Navigation/Browsing
        5. Google Chrome 30 and later versions = Incognito
      7. Targeted Advertisement:​ We partner with third parties to either display advertising on our Site or to manage our advertising on other sites. Our third-party partners may use cookies or similar technologies to gather information about your activities on this Site and other websites to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking preferences-mgr.truste.com​ (or if located in the European Union click or www.youronlinechoices.eu ​). Please note this does not opt you out of generic ads. You will continue to receive generic ads.
      8. Social Media (Features) and Widgets: ​Our Site includes social media features, such as LinkedIn. These features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy statement of the company providing it.
      9. Blogs:​ Our Site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal data from our blog or community forum, contact us at privacy@Leo.com.​ In some cases, we may not be able to remove your personal data, in which case we will let you know if we are unable to do so and why. Alternatively, if you used a third-party application to post such information, you can remove it, either by logging into the application and removing the information, or by contacting the appropriate third party application.

    Upon request and within 30 days, or as otherwise required by applicable law, Leo will provide you with information about whether we hold, or process on behalf of a third party, any of your personal data. In addition, Leo will take reasonable steps to permit customers to correct, amend, delete, or receive a copy of their personal data. To request this access, please contact privacy@hirewithleo.com ​. In accordance with customer agreements, Leo will, upon request, provide our customers with a copy of their personal data stored by Leo upon expiration or termination of the customer agreements, unless applicable law determines otherwise.


    Leo acknowledges that you have the right to access your personal data and to withdraw consent to the use/processing of your personal data. In most cases, Leo has no direct relationship with the individuals whose personal data it processes for customers. We recommend that an individual who seeks access, or who seeks to correct, amend, delete or receive a copy of personal data should direct his/her query to the Leo customer (the data controller). If requested to remove data by our customer, we will respond within 30 days or as otherwise required by applicable law. Individuals may also submit such inquiries or requests directly to Leo at no cost for them by contacting privacy@Leo.com .


    We will retain personal data for as long as a customer’s account is active or as needed to provide the Service to our customer, as required under customer agreements and / or for as long as Leo needs the personal data to fulfill the purposes for which the Company initially collected it, unless otherwise required by applicable law or court order. We will also retain this personal data as necessary to comply with our legal and/or contractual obligations, comply with court orders, resolve disputes, and enforce our agreements. When the purpose for which Leo is processing the personal data is fulfilled, expires or is terminated, Leo will delete any personal data in accordance with our customer agreements, this Privacy Policy and applicable law. In the event we cannot delete your personal data, we will inform you of the reasons, subject to any legal restrictions.


    Leo employs reasonable and appropriate security measures to protect against the loss, misuse, and alteration of the personal data it processes. When the Service is accessed using Microsoft Internet Explorer versions 8.0 or higher, Transport Layer Security (TLS) technology protects information using both server authentication and data encryption to help provide that personal data is safe, and secure while in transit. Leo also implements an advanced security method based on dynamic data and encoded session identifications, and hosts the Service in a secure server environment that uses a firewall and other advanced technology to protect against interference or access from outside intruders. Finally, Leo provides individual usernames and passwords that must be entered each time a customer logs on. These safeguards help protect against unauthorized access, maintain data accuracy, and provide for the appropriate use of personal data. Nevertheless, no method of transmission over the Internet, or method of electronic storage, is one hundred percent (100%) secure, however. Therefore, we cannot guarantee absolute security. If you have any questions about security on our Service, please contact us at ​ privacy@Leo.com​ .


    Our Service includes links to other Web sites whose privacy practices may differ from those at www.Leo.com​,​ jobs.hirewithleo.com, ​ ​ ​ ​ ​ ​briefbuilder.recruitd.com ​and app.hirewithleo.com​ ​. If you submit personal data to any of these sites, your information is governed by the applicable third-party’s privacy policies and we are not responsible for it. We therefore encourage you to carefully read any notices provided through a hyperlink and the privacy policy of any Web site you visit and raise questions directly with these other providers.


    There are many methods where web browser signals and similar mechanisms can indicate your choice to disable tracking. But we may not be aware of or able to honor every such mechanism. Because there is not yet a common understanding of how to interpret web browser-based “Do Not Track” (DNT) signals other than cookies, we may not respond to undefined DNT signals to our Sites or online services. More information about “do not track” is available at ​www.allaboutdnt.org concerning such information.


    The invalidity or unenforceability of any provisions of this Privacy Policy in any country shall not affect the validity or enforceability of any other provision of this Privacy Policy, which shall remain in full force and effect.


    We may update this privacy statement to reflect changes to our information practices that will become effective upon posting. If we make material changes to this policy, we will notify you here, by email, or by means of a notice through the Service prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.