Last Updated: March 31, 2021
Company Name: Diversifying Ltd
Company Registration Number: 11441606
ICO registration number: ZB032053
1.1 The Diversifying Entities Responsible for Your Information
1.2 Personal Data and Non-Personal Data
1.5 Diversifying’s approach to privacy and the General Data Protection Regulation (GDPR)
2. Information Collected
You provide different types of information in order for Diversifying to provide our services, products and features to you. Diversifying associates this information with your Diversifying profile.
2.1 Information You Provide to Diversifying
– From Your Account
We collect data from you when you create a Diversifying account, request information, subscribe for a service, participate in a survey, post a rating or review, post a question or answer, post a resume, 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 resume, including but not limited to application materials and answers to screener questions submitted to Employers through Diversifying and answers you give to any questionnaires sent to you. This information may be associated with your profile.
– Through Your Activity on Diversifying
In addition, as part of the standard operation of the Site, Diversifying may collect and analyse information from your computer or mobile device and actions taken on the Site, including, but not limited to, your resume, your searches on Diversifying, 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. Diversifying seeks your consent at the time of such provision, and such processing will only be performed where consent is secured.
– When Using Automated Phone Screening
– When Providing Employer Information
If you are an Employer, Diversifying may request that you provide certain Personal Data to Diversifying in order to verify your account. This information may include, but may not be limited to, your Federal Employer Identification Number (EIN), 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 Diversifying only has access to the last four digits of Employer credit card numbers and does not store full credit card numbers.
2.2 Information Collected When You Apply for Jobs or Access Diversifying from Some Third-Party Websites
– When You Apply to Jobs on Some Third-Party Sites
Diversifying may also collect information about web sites and web pages you visit through our mobile software or while using Diversifying for Chrome about job postings that you save, notes or applications statuses that you save or update, or data regarding how you engage with websites or other actions you take on such website, including URLs of websites you visit. We do this in order to allow a Job Seeker to keep a record of particular Job Listings of interest, to detect a job application form on a third-party website to give a Job Seeker the option to auto-fill parts of the form using Diversifying Resume, or to confirm an application. Diversifying for Chrome also allows Diversifying to learn about what types of jobs and Diversifying product features are of interest to you, so that we can provide you with improved job listing searches, job listing recommendations and product features.
– When You Log In or Use Diversifying from Some Third-Party Sites
You may also create an account or log in to your Diversifying account using third-party websites including, but not limited to, Facebook or Google. If you do not already have an Diversifying account but log in to Diversifying using your Facebook or Google account, this creates an Diversifying account using the same email address used in your Facebook or Google account. If you agree to provide this information to Diversifying, Facebook or Google will authenticate you and redirect you to Diversifying’s Site. Please note, when you log in to Diversifying 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 Diversifying through your Facebook or Google account, you understand that Facebook or Google will share certain data detailed in the above 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 Diversifying 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 Diversifying account at any time by accessing your privacy settings on your Facebook or Google account. Facebook and Google may also ask for your permission to share certain other details with Diversifying, including but not limited to your name, profile picture, public profile information, and email address. Once you give this permission, the requested information will be shared with Diversifying, which may use this information to provide Services to you, including populating your Diversifying profile. The shared information will remain associated with your Diversifying profile until you modify or delete it. For those users that avail of Diversifying Family specifically, Facebook may ask for permission to share your friends list, and Diversifying may use some of this data to connect you with other users of Diversifying 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 Diversifying May Receive from Third Parties
2.4 Storage of Your Information
2.5 What Personal Data is Required
Diversifying 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 Diversifying 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 Diversifying Collects Your Personal Data
Diversifying 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
Some of the Personal Data processed by Diversifying 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 Diversifying sends a Job Seeker’s application to an Employer.
– Legitimate Interest
A second ground relied upon by Diversifying for other types of processing of your Personal Data is that it is necessary for the purposes of legitimate interests pursued by Diversifying. Such legitimate interests will include where Diversifying 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. Diversifying 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 Diversifying to comply with a legal obligation. An example of this would be where Diversifying is required to retain business records for fixed periods of time in order to comply with local legal requirements.
3. 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, resume, 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 Diversifying products and the ability to utilise the “Log in with Diversifying” feature found on certain third-party sites.
Diversifying 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 Diversifying 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, Diversifying 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 Diversifying’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 Diversifying (including the use of an Diversifying 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) Diversifying depends on the Employer or the Employer’s agent to provide Diversifying with the correct destination for all applications.
3.4 Where the Employer Contact Details Provided to Diversifying Are Incorrect
In the event that the electronic destination provided to Diversifying is incorrect, your application materials will not be sent to the intended recipient of the application. Diversifying 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 @diversifying.jobboard.io Addresses
When communicating through Diversifying’s message relay system, you will see an email address with an @diversifying.jobboard.io ending. You understand that you retain no ownership rights in these email addresses, which are specific to Employers’ Job Listings, but are owned by Diversifying. However, Diversifying’s relay system will show the name associated with your account or job application in the “To:” or “From:” field.
Please also note that since these message proxy and relay services depend on the functionality of third-party providers, there may be technical delays on the part of those email service providers.
3.6 Minimum Age of our Users
The Site is not for use by anyone under the age of 16. However, if local laws require that you must be older in order for Diversifying 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 Diversifying under the supervision of your parent, legal guardian or responsible adult. Diversifying 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 firstname.lastname@example.org.
4. 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, Diversifying may use your contact information to (i) create an account; (ii) send you job alerts; and (iii) send you information about Diversifying, including promotional materials. Diversifying may use third-party partners to perform these activities on Diversifying’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 Diversifying recommends for you, Diversifying 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, Diversifying 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 Diversifying thinks you may be interested in, and display content according to your preferences. Diversifying 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 Diversifying contact information (such as your name and email address) and other forms of Personal and Non-Personal Data, you agree that Diversifying may utilise this information for the purposes outlined in sections 4, 5 and 9, to the extent applicable. In particular, you agree that Diversifying may, as part of its services to you, communicate with you, or initiate communication with you on behalf of a third party, through your Diversifying 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 Diversifying or that Diversifying may otherwise obtain from third-party resources.
4.4 Your Resume Information
– Private Resumes
Private resumes are only made available to those to whom the Job Seeker has initiated an application or provided their resume. Where this occurs, you make your resume, your name and other Personal Data that you place on your resume available to third parties. Those third parties may be interested in you as an employee, and may forward your resume to other third parties.
– Public Resumes
Public resumes are available to anyone with access to Diversifying’s resume search application and may be accessed by other Diversifying users, in order to increase the visibility of that resume and help Diversifying find you a job. Where this occurs, you make your resume, your name and other Personal Data that you place on your resume available to third parties. Those third parties may be interested in you as an employee, and may forward your resume to other third parties.
If you post a public resume, 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 resume and you may receive unsolicited contact from parties unaffiliated with Diversifying and for whom Diversifying has no responsibility. If you post a public resume on Diversifying, please note that although Diversifying expressly prohibits the scraping of its Site any resume you post publicly is public information and the content may be copied by a third party in violation of these terms.
For public resumes, you also authorize Diversifying to remove your name from your public resume, in certain instances. Diversifying may also change the display of your resume from public to private in certain instances to maintain the quality of the resume database.
– Changing Your Resume Privacy Settings
You will be given the option to make your resume private or public when you place your resume on Diversifying. You may adjust this at any point by editing your privacy settings on Diversifying. Where you adjust your resume from public to private, Diversifying does not warrant how often third-party search engines will update their caches, which may continue to contain your resume information. Additionally, Employers who have saved your resume while it was public may continue to have access to your resume even after you have adjusted it to private.
4.5 Matching Job Seekers with Employers
You acknowledge that Diversifying may determine whether the words of your resume or any other individuals’ resume match the words of certain job descriptions, and vice versa, in order to improve the Site or any other Diversifying product or service (including by displaying or otherwise making available potentially relevant job descriptions and resumes to Job Seekers and Employers).
If you have a Diversifying account or a Diversifying-hosted resume, you agree that Diversifying may contact you or suggest you or your public resume to Employers that might be interested in a person who matches your behaviour on Diversifying.
In addition, if you are located in the United States and you set your Resume to public, this means that Diversifying may share all of the aforementioned information about yourself with recruiters working for or on behalf of Employers. If you do not wish to share such information, you may set your Resume to private.
4.6 Sending Messages on Diversifying
Diversifying provides two-way message proxy and relay services to the users of our Diversifying products (“Relay Service”), including: Diversifying Resume, Diversifying Apply, Post a Job, Diversifying Chat, and Diversifying Onboarding and other electronic communication services whether in the form of text, video or audio. By utilising any Relay Service, you acknowledge that you are asking Diversifying to send these messages on your behalf. This includes your resumes, cover letters, applications, messages, questionnaire answers, responses, offer letters and other materials.
We process, monitor, review, store and analyse such content, including via automated means, for data analysis, quality control, enforcement of the Site Rules and other Diversifying policies, content moderation, and to improve the Site or any other Diversifying product or service. Examples of such improvements would be optimizing our search results, improving Job Listings, ensuring you are provided with personally relevant product features and communications, and preventing fraud and spam. As a result of this activity, or due to technical malfunction, in certain circumstances such content may be delayed or may not be delivered to the intended recipient. Diversifying may (but is not obligated to) notify you in such an event. By using a Relay Service or otherwise providing User Content through the Site, you consent to this activity and acknowledge that this activity is necessary for maintaining the quality of the Site and for providing the Relay Service.
4.7 Sending You Text Messages About Employer Appointments
Diversifying may offer you the opportunity to receive a text message from Diversifying when an Employer has scheduled an interview or event with you or responded to your application via Diversifying’s email relay. In such an event you will enter your phone number on the Diversifying consent form and by entering your phone number you are representing and confirming it is your number and you have the right to accept text messages at the number. Diversifying will only send you a text message reminder for such interviews or messages through Diversifying’s email relay, and you agree to accept such text messages on your cell phone including messages sent by automated telephone dialing system.
4.8 Preventing Fraud and Spam
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
Diversifying also reserves the right to drop messages from our relay system that Diversifying determines do not adhere to Site Rules or any of the terms of this agreement. Diversifying further reserves the right to conduct investigations to determine whether you are perpetrating a scam, spamming Diversifying or its users, or otherwise conducting fraudulent activity on Diversifying by various means, including but not limited to investigating your functionality by setting up profiles and names that belong to Diversifying. Diversifying also reserves the right to turn over any information gathered via such investigations to the police or other third party if Diversifying has a good faith belief that you are using the Site in violation of these terms.
Diversifying 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.
4.9 Facilitating Payment
If you provide credit, debit or other payment card and related details to us in order to make a payment, Diversifying will use such information only for the purpose of processing the payment (e.g., the last four digits of credit card numbers and related verification information). Any credit card and related billing and payment information that you provide to Diversifying may be shared by Diversifying with companies who work on Diversifying’s behalf, such as payment processors and/or credit agencies, solely for the purposes of checking credit, effecting payment to Diversifying and servicing your account.
4.10 Automated Processing of Your Personal Data
In order to optimize the performance of the Diversifying Site and services for users, Diversifying 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 Diversifying’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 Diversifying to provide its services to Job Seekers and Employers, including analysing applications and resumes on behalf of Employers, or in other cases on the basis of a user’s consent.
4.11 Transfer of Information to Diversifying Affiliated Entities
Any information shared by you with Diversifying may be shared with or transferred to any Diversifying affiliated entity (including Diversifying Hire, Inc.), no matter where located, for the purpose of providing you services and improving the Site, and other purposes as described in this Policy. This includes Diversifying affiliated entities located outside the European Union (“EU”) or Switzerland.
Such transfers are performed in full compliance with applicable data protection rules and subject to appropriate safeguards, primarily through the use of extensive data protection agreements, in order to ensure adequate protection of users’ Personal Data. The services provided to you and the functionality of the Site could not be provided without such a transfer. If you do not wish your information to be transferred in this way you should not use this Site.
4.12 Transfer of Information to Third Parties
– Transfers to Employers
Employer account holders 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.
Diversifying may transfer your Personal Data in limited situations to certain third-party vendors that assist Diversifying with protecting our users and maintaining the quality of our services, products and features provided to those users. An example would be vendors Diversifying uses for fraud detection purposes.
Diversifying may also share any credit card and related billing and payment information that you provide to Diversifying with companies who work on Diversifying’s behalf, such as payment processors and/or credit agencies, solely for the purposes of checking credit, effecting payment to Diversifying 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 Diversifying in a manner that is intended to make that content publicly available and searchable by individuals, Diversifying reserves the right to aggregate and share that information with third parties. For example, if an Employer posts a job on Diversifying, Diversifying may share that job posting or information contained within that job posting with third parties, at Diversifying’s discretion and subject to agreement between Diversifying and any such third parties. Diversifying also reserves the right to share information aggregated from public sources in this capacity.
– Third-Party Sites You Link to from Diversifying
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
5. Additional Uses and Disclosures of Non-Personal Data
Diversifying seeks to use reasonable security measures to help protect against the loss, misuse and alteration of the Personal Data under Diversifying’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.
8. 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.
WE 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.
9. Acquisitions and Other Reorganizations
10. Exercising Rights with Respect to Personal Data
Diversifying 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