Privacy and Cookie Policy

Updated and effective as of 28th August 2019

MEDVOCATION takes the privacy of its Users very seriously, investing significant resources as part of our efforts to protect your Personal Data. This includes closely monitoring and carefully adhering to applicable privacy rules provided for in our Privacy Policy and Cookie Policy as well as our Terms & Conditions. We very much value the trust that our Job seekers place in us to help them find jobs, and our Employers/ Recruiters place in us to help them find great candidates. Our Privacy Policy describes how we work to maintain that trust and protect our Users’ information.

This Privacy Policy is meant to help you understand what information MEDVOCATION (collectively “Medvocation”, “MV”, “us”, “our” or “we”) collect, why we collect it and what we do with it. This policy applies to websites, applications, advertising services or technologies (collectively “Services”).

1. Scope

“Personal Data” refers to any information that relates to an identified or identifiable individual, and non-personal data refers to any information that does not identify you as a specific individual. Where this Privacy Policy refers to “information” this may include both Personal and Non-Personal Data.

Medvocation is a data controller and processor for the purposes of the GDPR and by your consenting to this Privacy Statement MV is able to processes your Personal Data in accordance with this Privacy Policy. Personal data processed in connection with the Services is controlled by Medvocation Limited, an Irish company located at The Black Church, St. Mary's Place, D07 P4AX Dublin, Ireland.

Unless indicated otherwise, this Privacy Policy relates to our use of any personal Data we collect or use in relation to the following services (collectively, “Services”):

  • posting a job application
  • posting a job offer
  • messages sent via the MV Application; and
  • the MV official social media channels.

2. Information we collect

When we provide the Services, we collect and receive information in several different ways. In many cases, you choose what information to provide, although some information is required for us to provide you the Services.

2.1. Information You Provide to Us

When you register/login by click box on the Application or by registration system on online platform for each role or provide us with other Personal Data actively, we collect that information for processing and use in accordance with the Privacy Policy. Depending on how you interact with our Application, the Personal Data we collect from you may vary. We 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 MEDVOCATION 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.

We collect information from you when you create MEDVOCATION account, participate in a job seeking, post a question or answer to Employer/ Recruiter, post a resume, upload content or otherwise actively send us data on our Application. This may include, but is not limited to, your first and last name, email addresses, mobile phone numbers, residential address, gender, age, and any other data included in “My Profile” section or resume, including but not limited to application materials and answers to screener questions submitted to Employers through MV and answers you give to any questionnaires sent to you. This information may be associated with your MV’s Profile.

When the Job Application is sent by Job seeker, the Job seeker's Personal Data, together with the attached files, is sent to the Employer Panel. The Employer/ Recruiter becomes the administrator of the Job seeker's Personal Data.

You may provide your specific location data when you provide it yourself on the MV Apps to help you find more relevant Job Listings (including from the location service on your mobile device when you grant permission to MEDVOCATION Application), or when you submit a photo that includes the provision of the location data of where the photo was taken. MV seeks your consent at the time of such provision, and such processing will only be performed where consent is secured.

If you are an Employer, MV may request that you provide certain Personal Data to MEDVOCATION in order to verify your account. This information may include, but may not be limited to, your Business Registration information, or a utility bill, the name and email address of an Employer representative.

MEDVOCATION may collect and analyze information from your computer or mobile device and actions taken on the MV’s platform, including, but not limited to, your resume, your searches on MV, 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, IP address and the domain name from which you accessed the Application.

You may also create an account or log in to your MEDVOCATION Account using third-party websites: Facebook or Google. If you do not already have an MV account but log in to MV using your Facebook or Google account, this creates an MV account using the same email address used in your Facebook or Google account. If you agree to provide this information to MV, Facebook or Google will authenticate you and redirect you to MEDVOCATION’s Platform. Please note, when you log in to MV 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 MV through your Facebook or Google account, you understand that Facebook or Google will share certain Personal Data 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 MV 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 MV 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 MEDVOCATION, 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 MV, which may use this information to provide Services to you, including populating your MV profile. The shared information will remain associated with your MV profile until you modify or delete it.

If you enter credit card information on the Application in connection with a purchase, that information is sent directly from your browser to the third-party service provider we use to manage credit card processing and we do not store it on our servers. The service provider is not permitted to use the information you provide except for the sole purpose of credit card processing on our behalf.

When you submit Personal Data to a third party and are informed at the time of collection that your information may be shared with us, we may collect that information for lawful marketing purposes.

2.2. Information We Collect Automatically

When you use the Application, your device is automatically providing information to us so we can respond and customize our response to you. Automated means of data collection include the following:

  • Cookies and Tracking Technologies. We use technologies such as: cookies, web beacons, locally shared objects, mobile identifiers and similar technologies (collectively “Cookies”). We use Cookies to remember Users’ settings as well as for authentication and analytics. These technologies may be used in analyzing trends, administering the Application, tracking Users’ movements around the Application and to gather demographic information about our user base as a whole. You can control the use of Cookies at the individual browser level, but if you choose to disable Cookies, it may limit your use of certain features or functions on our website or service.
    For more information on Cookies, how we use them, the third parties we work with who use them, and how you can control them, please see the section 13. entitled Cookie Policy.
  • Log File Information. Log file information is automatically reported by your browser or mobile application each time you access a website on our Application. For example, when you access Medvocation Website, our servers automatically record certain information that your web browser sends when you visit any website.
  • Device Information. We collect information about the device you use to access the Application, including type of device, operating system, settings, and unique device identifiers, and IP address. Whether we collect some or all of this information often depends on what type of device you’re using and its settings. For example, different types of information are available depending on whether you’re using an iPhone or Android phone. We collect the device type and any other information you choose to provide, such as indicated as email address, mobile phone number or geolocation. We also use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.

3. How we use your information

We are able to deliver, personalize, and improve our Services by combining and using the information we have about you to understand how you use and interact with our Services and the people or things you’re connected to and interested in. We also may use the information we have about you for the following purposes:

  1. Providing and improving the requested Services. Some of the Personal Data processed by us are 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 MV sends a Job seeker’s application to an Employer.
  2. Communicating with you. We use your Personal Data to contact you regarding your registration to Application, to notify you of any changes to our policies and practices and to respond to any requests or inquiries you may submit to us. We may collect information from these communications to improve our Services and for the training and development of our staff.
  3. Marketing. If you opt-in to receiving marketing communications from us, we will use your Personal Data for outreach and marketing, such as to send you information about news. You can opt-out of these communications by using the unsubscribe links in our communications or by changing your Application settings.
  4. Advertising. We use your Personal Data to be able to show you advertising on other websites.
  5. Location. Provide location-based Services, advertising, search results, and other content consistent with your location settings.
  6. Unlawful actions. Detect and defend against fraudulent, abusive, or unlawful activity.

4. Legal bases for processing your information

We rely on a number of bases to lawfully process your Personal Data for the purposes described in the Privacy Policy. We process your Personal Data:

  1. when necessary to perform the Terms & Conditions or to provide you the Services;
  2. where you have consented to the processing, which you may revoke at any time, as detailed in section 6 point 4 of this Privacy Policy;
  3. when necessary for us to comply with a legal obligation, a court order, or to exercise and defend legal claims;
  4. legitimate interest when necessary to protect your vital interests, or those of others, such as in the case of an emergency;
  5. where necessary for the purposes of our, your, or a third party’s legitimate interests, such as those of partners or other job seekers or employers.

5. Our legitimate interests

As indicated above, in certain cases we use your information where necessary to pursue our, your and others’ legitimate interests, including where necessary to:

  1. Keep the Services safe and secure. We use your information as it is necessary to pursue our legitimate interests, or those of our users or our partners in ensuring the Application is a safe, such as enforcing the Terms & Conditions. We also act in the legitimate interests of these parties with respect to our Applications or website such as by implementing and enhancing security measures and protections and protecting against fraud, spam and abuse.
  2. Provide, develop and improve the Services. We process your information as necessary to pursue our legitimate interests in improving the Application. We also use your information to conduct data analysis and analytics across our Services.
  3. Market the Services. We process your information in accordance with our legitimate interests of marketing the Services to you.
  4. Provide seamless Services with MV group companies and affiliates. We may share Personal Data amongst our parent company, subsidiaries, or affiliates for internal business purposes and to provide you with the Services in accordance with the Terms & Conditions and this Privacy Policy. If we share your information within our corporate group we will ensure that your information continues to be used only in accordance with this Privacy Policy and your expressed choices, and in accordance with applicable law.

6. Your rights

You have a number of rights in relation to your information that we process. While some of these rights apply generally, certain rights apply only in certain limited cases. We describe these rights below.

  1. Access and Porting. You can access much of your information by logging into your Application profile. If you require access to additional information, or you do not have an Application profile, please contact us. Where legally required, we will provide your information in an easily accessible format and assist in transferring some of this information to third parties.
  2. Rectify, Restrict, Delete. You can amend, update and delete some of your information by logging into your Application profile. If you don’t have an Application profile, or want us to amend, update or delete other information, please contact us.
  3. Object. Where we process your information based on the legitimate interests described above, or in the public interest, you can object to the processing in certain circumstances. We will generally stop processing your information unless we have compelling grounds to continue processing, such as where needed for legal reasons. Where we use your information for direct marketing, you can always object using the unsubscribe link in such communications, changing your profile settings or by contacting us.
  4. Revoke consent. If we have specifically asked for your consent to use your information, you have the right to withdraw your consent at any time. For example, if we ask for your consent for direct marketing purposes, you can revoke your consent using the unsubscribe link in such communications, changing your profile settings or just by contacting us via email gdpr@medvocation.com .
  5. Complain. If you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority or MV’s lead supervisory authority, the Irish Data Protection Commission.

7. Sharing with third parties

We share information with Job seekers, Employers/ Recruiters, service providers, affiliates, partners, and other third parties where it is necessary to perform the Terms & Conditions, to provide the Services, and for other purposes described in the Privacy Policy. Any Personal Data that MEDVOCATION may obtain from other third-party sources will be processed by MV in accordance with this Privacy Policy and all applicable laws:

  1. Sharing with other Recruiters/Employers. Our Services provides Recruiters/ Employers with the means of making connections with other attendees. For example, the CV application that they choose.
  2. Marketing. In order to further our legitimate interests in marketing the Services, we rely on third-party marketing platforms and service providers to assist us and perform certain marketing services.
  3. Advertising. We share your Personal Data with common advertising platforms such as Facebook, Google and LinkedIn to show you advertising when you use those services.
  4. Third party service providers. We may share your Personal Data to help us operate, provide, improve, understand, customize, support, and market our Services. These third parties provide us with services including for customer support, data storage and website hosting, and payments processing, legal advice and compliance, and marketing and data analysis. These third parties are contractually required to use it only to provide their service to us, and prohibited from using it for their own purposes.
    We work with third parties, such as Google Analytics, to provide analytics services that use the Cookies set on your device to measure the performance of advertising and track traffic to MV generally.
  5. Legal and safety reasons. We may retain, preserve, or share your Personal Data if we have a good-faith belief that it is reasonably necessary to (a) respond, based on applicable law, to a legal request (such as, a search warrant, court order, or other request from government or law enforcement); (b) detect, investigate, prevent, and address fraud and other illegal activity, security, or technical issues; (c) protect our rights, property, or safety; (d) enforce our Terms & Conditions or other agreement we have with you; or (e) prevent physical injury or other harm to any person or entity, including yourself and members of the general public.
  6. Payment Information. If you decide to pay directly by our online payment processing partner Stripe, Inc. any payment card information you use to make a purchase on the Service is collected and processed directly by Stripe, Inc. and we never receive or store your full payment card information. Stripe, Inc. may use your Payment Information in accordance with its own privacy policy: https://stripe.com/en-US/privacy

8. Data transfers

As a global business, we access and transfer information around the world. If you are based in the EU, this means that we access and transfer your Personal Data outside the EU, including in and to the United States. The privacy protections and the rights of authorities to access your Personal Data in some of these countries may not be the same as in your home country.

Where we transfer information to persons outside EU we take reasonable steps to ensure that the recipients of such information do not breach the Ireland Privacy Principles (and where appropriate the GDPR) in relation to that information by entering into binding contractual arrangements with such third parties.

In particular, where we transfer information to countries that are not viewed as providing adequate protections, we generally rely on an approved mechanism known as the “standard contractual clauses” to protect the information transferred. These are template contracts published by the European Commission containing approved commitments to protect the privacy and security of the information transferred.

9. Storage of Your Information

MEDVOCATION shall retain Users’ Personal Data to the extent such retention is adequate, relevant and limited to what is necessary for the purposes for which they are processed. We keep your Personal Data only so long as we need it to provide the Application to you and fulfill the purposes described in this Privacy Policy. This is also the case for anyone that we share your Personal Data with and who carries out services on our behalf. Retention periods can vary significantly based on the type of information and how it is used. Our retention periods are based on criteria that include legally mandated retention periods, pending or potential litigation, our intellectual property or ownership rights, contract requirements, operational directives or needs, and historical archiving.

When we no longer need to use your Personal Data and there is no need for us to keep it to comply with our legal or regulatory obligations, resolve disputes and enforce our agreements, we’ll either remove it from our systems or depersonalize it so that we can't identify you.

10. Security

The security of your Personal Data is very important to us. We strive to use appropriate technical and organisational to protect your Personal Data. MEDVOCATION employs various practices with the goal of preventing unauthorized access, disclosure, destruction or accidental loss. These practices will vary depending on the nature of the data, the context of the processing, the risks involved and the technology available.

MEDVOCATION uses a range of security measures aimed at complying with the requirements of the GDPR. These include:

  1. adopting a risk-based approach to securing the personal data of our Users;
  2. using selective pseudonymisation and encryption of personal data kept by MV;
  3. designing systems with the goal of enabling MV to protect the (i) confidentiality, (ii) integrity, (iii) availability and (iv) resilience of MV's processing systems and services;
  4. using systems and processes designed to give MV the ability to restore the availability and access to personal data kept by MV in a timely manner in the event of a physical or technical incident;
  5. regularly testing, assessing and evaluating the effectiveness of MV's security measures.

With respect to data transfers, MEDVOCATION Inc. is certified under EU-US Privacy Shield, and adheres to applicable Privacy Shield principles. It also adheres to GDPR requirements concerning transfers of personal data to MV entities and to third parties.

11. Protecting Children's Privacy

Our Services are for an adult audience. We do not knowingly collect, use, or share information that could reasonably be used to identify children under age 18 without prior parental consent or consistent with applicable law.

12. Changes to Privacy Policy

We may update this Privacy Policy from time to time so please review it periodically. If we make material changes, we will take steps to notify you. The date of the most recent revisions will appear on the top of this page.

13. Cookies Policy

By creating the Medvocations’s Account, you accept that Cookies may be placed on your mobile or fixed device, under the conditions provided below.

13.1. What are Cookies?

A Cookie is a file of limited size, generally made up of letters and numbers, sent by an Internet server to the browser’s cookie file, and located on your computer’s hard disk. A cookie records information about how the user browses the website (page views, date and time, etc.; “Cookie”). When you visit the MV website again, the cookies allow us to recognize your browser. Cookies may store your preferences and other information but cannot read data off your hard disk or read cookie files created by other sites.

Cookies help us recognize you on the Platform, enhance your user experience, understand usage of the Platform, and show you relevant advertising. Cookies may also be set by other websites or services that run content on the page you're visiting. After you register on the Platform, we may connect information we collect from the Cookies set by us and our partners with other information received from you. The provision of your data via Cookies is voluntary except for those Cookies that we place on your device because we need them for the performance of our Platform and our services.

13.2. What types of Cookies do we use?

We use two types of Cookies on the Platform: “Session cookies” and “Persistent cookies”.

Session Cookies are temporary Cookies that remain on your device only until you leave the Application. A persistent Cookie remains on your device for much longer until you manually delete it (how long the Cookie remains will depend on the duration or “lifetime” of the specific Cookie and your browser settings). An example of permanent cookies are the ones holding data such as login details, contact information and account numbers, so that you don’t have to type them in every time you use the Application.

13.3. What are Cookies used for?

Cookies transmit information about you and your use of the Platform, such as your browser type, search preferences, job titles, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. With the exception of an identifier Cookie that we associate with registered accounts to prevent fraud by members of the Platform, Cookies link to certain unique information such as the job titles that you entered at time of registration or on your profile, but this is not linked to your name.

In addition, we may also provide an employer with code for a Conversion Tracker to place on its Site that pings the job seeker web beacon and tracks whenever a job seeker has applied to a job on that employer’s website. This Conversion Tracker will attribute an application to Indeed any time the job seeker started their search on Medvocation, despite any intervening activity. MV does not have access to the cookies in the employer’s domain. The Conversion Tracker is simply a counter that notifies us that a job seeker has applied. If a job seeker has disabled the web beacon, the Conversion Tracker will have no functionality.

13.4. Cookies, Scripts and Related Technologies

When you visit our Application, we and our third-party service providers receive and record Personal Data that you may have provided and your digital signature, such as your IP address. The technologies we use to track your movements around our website include cookies, tracking scripts and pixels, and tagging technologies, which we may employ to understand your preferences, improve your experience on our website, etc. You can control the use of cookies at the individual browser level. If you want to learn more about cookies, or how to control, disable, or delete them, please visit http://www.aboutcookies.org for detailed guidance.

13.5. Collection of Data by Advertisers

We may also use third parties to serve ads on our website or to manage our advertising on other sites. Certain third party partners may automatically collect information about your visits to this and other websites, your IP address, your ISP, the browser you use to visit our website (but not your name, address, e-mail address or telephone number). They do this by using cookies, pixel tags or other technologies. Information collected may be used, among other things, to deliver advertising targeted to your interests and to better understand the usage and visitation of our website and the other sites tracked by these third parties.

This Policy does not apply to, and we are not responsible for, cookies or pixel tags in third party ads, and we encourage you to check the privacy policies of advertisers and/or ad services to learn about their use of cookies and other technologies. If you would like more information about this practice and to know your choices about not having this information used by these companies, click here: http://www.aboutads.info/choices or http://www.networkadvertising.org

13.6. Settings for Cookies

Cookies are only used if you accept them or if you continue browsing the Platform. When you visit the Platform, you are notified that Cookies are used and you are also given the possibility to refuse and remove them.

You do not have to accept Cookies and consent can be withdrawn at any time, although you may not be able to use certain features on MV Application. You can do this by clicking the appropriate opt-out provided in the cookie table above or by activating the settings on your browser that allows you to refuse all or some cookies.

You can opt out Cookies through the “Help” function in your browser settings. For further information on Cookies and how to deactivate them in your browser, we recommend that you consult the information made available to you by your browser. Alternatively, visit www.aboutcookies.org for comprehensive information on how to control or delete cookies in a wide variety of browsers, including how to delete cookies from your computer. For information on how to do this on your mobile device – such as a smartphone or tablet – please refer to your handset manual.

14. Contact us

Medvocation welcomes ideas and feedback about all aspects of the Application. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We will respond to all requests within a reasonable timeframe. Notwithstanding the foregoing, we reserve the right to keep any information in our archives that we deem necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

If you have any questions or concerns about this Privacy Policy or our privacy practices generally, if you would like to exercise your statutory rights or wish to make a complaint, you can contact us at: gdpr@medvocation.com

Registered Offices

IRELAND
Medvocation Limited
The Black Church,
St. Mary's Place,
D07 P4AX Dublin
Republic of Ireland
Company Number 638818
Registered in the Republic of Ireland
VAT number: IE3601646GH

UNITED STATES
Medvocation, Inc.
2035 Sunset Lake Rd
Newark, DE 19702
Company Number 7282439
Registered in the Delaware State, the United States of America