European Privacy Policy

The following European Privacy Policy applies to residents of the European Union, the European Economic Area and Switzerland.

 

Personal Data and Processing. For the purposes of this European Privacy Policy:

Personal Data” means any information relating to an identified or identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of such natural person; and

Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

EU-U.S. and Swiss-U.S. Privacy Shield. Hireku, Inc. complies with the EU-US Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal data of users of the JazzHR Services who are residents of the EU, EEA or Switzerland that we receive and process through the JazzHR Services. Hireku, Inc. has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability hereinafter, “Privacy Shield Principles”) for individuals in participating European countries whose personal data is processed through the JazzHR Services.  If there is any conflict between the policies in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification page, please visit www.commerce.gov/privacyshield.

In compliance with the EU-US Privacy Shield and Swiss-U.S. Principles, Hireku, Inc. commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss citizens with inquiries or complaints regarding this Privacy Policy should first contact Hireku, Inc. at:

Privacy Shield Inquiry

Hireku, Inc. (d/b/a JazzHR)
1501 Reedsdale Street
Suite 300
Pittsburgh, PA 15233

Hireku, Inc. has further committed to refer unresolved privacy complaints under the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD PROGRAM, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers  for more information and to file a complaint.

Individuals covered by the EU-U.S. Privacy Shield and Swiss-U.S. programs have the right to access and/or correct their data by emailing support@jazzhr.co with their access requirements and/or corrections.  Additionally, in some scenarios, individuals may have the right to invoke binding arbitration before the joint EU-U.S. Privacy Shield or Swiss-U.S. Privacy Shield Panel.  For the purposes of EU-U.S. Privacy Shield and Swiss-U.S Privacy Shield, Hireku Inc.’s participation is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.  Hireku, Inc. retains liability for onward transfer to third parties for purposes other than the ones for which it was originally collected, as required by the Onward Transfer principles.

Hireku, Inc. has further committed to cooperate with EU and Swiss data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU or Switzerland in the context of the employment relationship.  If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU or Swiss DPAs for more information or to file a complaint.  The services of EU or Swiss DPAs are provided at no cost to you.

We may also process personal data submitted relating to individuals in Europe via other compliance mechanisms, including use of the European Union Standard Contractual Clauses or Binding Corporate Rules.

Purposes and Legal Bases for Processing Personal Data. JazzHR processes data for the purposes as set forth in our Privacy Policy, including to provide the JazzHR Services and as explained in the Use of Information and Sharing of Information sections. To fulfill these purposes, JazzHR may access data, including Personal Data, to provide the JazzHR Services, to correct and address technical, service or security problems, or in response to contractual requirements. Please see our JazzHR Privacy Policy Information We Collect and Data Retention sections for additional details on how we collect, use, disclose and share data, make automated decisions, and retain data, including Personal Data, about individual users or customers.

Our legal bases for the processing of Personal Data are: (i) consent or (ii) any other applicable legal bases, such as our legitimate interest in engaging in commerce, offering products and services of value to the customers of the JazzHR Services, preventing fraud, ensuring information and network security, direct marketing and advertising, and complying with industry practices.

Additional Rights for European Residents. As a resident of the EU or a country following substantially similar legislation regarding the protection of Personal Data, individuals may have one or more of the following additional rights:

Access. To request a copy of the Personal Data we have collected about you by contacting us.

Rectification & Erasure. To request that we rectify or delete any of the Personal Data about you that is incomplete, incorrect, unnecessary or outdated.

Objection. To object, at any time, to Personal Data about you being Processed for direct marketing purposes.

Restriction of Processing. To request restriction of Processing of Personal Data about you for certain reasons, such as, for example, if you consider Personal Data about you collected by us to be inaccurate or you have objected to the Processing and the existence of legitimate grounds for Processing is still under consideration.

Data Portability. To request and receive the Personal Data we have collected about you in a commonly used and machine-readable form.

Right to Withdraw Consent. If Personal Data about you is processed solely based on your consent and not for any other legitimate interest, to withdraw your consent at any time, without affecting the lawfulness of our Processing based on such consent before it was withdrawn, including processing related to existing contracts for our products and services.

Right to Lodge a Complaint with a DPA. If you believe our Processing of Personal Data about you is inconsistent with the applicable data protection laws, to lodge a complaint with your local supervisory data protection authority (“DPA”).

To exercise any of the above listed rights, please contact us as set forth below and provide sufficient details so that we can respond appropriately. We will process any requests in accordance with applicable law and within a reasonable period of time. We may need to verify the identity of the individual submitting a request before we can address such request. If the request relates to data our customers collect and process through the JazzHR Services, we will refer the request to that customer and will support them in responding to the request.  For JazzHR customers, certain information may be reviewed, corrected and updated by logging into the JazzHR Services account and editing the profile information.

Questions and Complaints. Residents of a country participating in the Privacy Shield Framework may direct any questions or complaints concerning our Privacy Shield compliance to our Privacy Shield and Data Protection Contact. We will work with you to resolve your issue.

Compelled Disclosures. JazzHR may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.