Privacy Policy

Thank you for visiting an offering from BOLD LLC and Auxiliant S.à.r.l (“Provider”, “we”, “us”). To assist our customers (“Customers,” “you” or “your”), we provide this notice ("Policy") explaining our online information practices and the choices you can make about the collection and use of the data and information you submit (“Information” or “Data”) or we collect through our family of websites that link to this Privacy Policy as well as our other related mobile websites, mobile Provider applications ("mobile apps" or “Provider Applications”), services, browser extensions, tools, and other applications that link to this Privacy Policy (all of these collectively, the "Site"). The Site is operated by BOLD LLC, City View Plaza II, Suite 6000, 48 Road 165, Guaynabo, Puerto Rico 00968. BOLD LLC is the data controller of your Information in the context of the Website. 

By visiting the Site, you agree that your information will be processed as described in this Policy. Your use of this Site is subject to this Policy and our Terms of Use. Provider's Terms of Use are incorporated by reference into this Policy.

Privacy Policy Key Points

Please also read our full Privacy Policy

Personal Information We Collect

  • When you register an account, utilise our services, download or use any of our mobile apps, use our forum or make a purchase, you voluntarily share certain Information with us, including, but not limited to, your name, email address, address, mobile number, and/or credit card information). 

Tracking Technologies

  • We utilise tracking technologies such as cookies to measure usage and provide information that we believe will be of utmost interest to you.
  • We may gather further information from you if you access our Site via a mobile device (e.g., unique device identifier, device’s operating system, mobile network provider).
  • You can also provide us with information when interacting with our content through or linking to third-party social media sites, plug-ins, or apps.

Uses, Retention and Storage

  • We and our service providers may store and retain certain information from you for the duration and reasons outlined in this Privacy Policy. 

Disclosure Information

  • By using our Site, you agree that we can share the Information we collect, to the extent permissible by applicable law, with our subsidiaries and affiliates, to our service providers, other entities such as job advertisement third-party websites and potential employers when you request, legal authorities, others (in case of change of control), and social networks and companies within the mobile app industry.

Your Choices

  • You can dictate how and when you wish to receive information from us, you may request removal of the information we have collected from you and a copy of the aforementioned information. Click here for other information options.

Access and Review Choices

  • You can alter your details at any time by editing your profile, updating or removing content that you have posted, or by closing your account.

Update Alerts

  • You agree that we can inform you about significant changes to this Privacy Policy by posting notices on this Site. 

European Economic Area Residents: Special Notice Regarding the General Data Protection Regulation (“GDPR”)

  • The Provider complies with the GDPR. As such, Provider affords to these data subjects their respective privacy rights to the extent they are applicable.

Residents of the United States: Special Notice Concerning the California Consumer Protection Act (“CCPA”)

  • The Provider complies with CCPA as amended by the California Privacy Rights Act (“CPRA”) and other applicable US state-level privacy laws. As such, Provider affords California residents and those in states with applicable privacy laws can exercise their respective privacy rights to the extent they are applicable.

Contact

  • Enquiries about this Policy may be sent to privacy@bold.com or as otherwise set out in this Policy.

Full Privacy Policy

Last Updated: 10/12/2024

1. Scope

Provider is an online destination that provides resume and cover letter building, career tests, salary information, resume and cover letter storage, career enhancing services and other services for individuals seeking to further their career. We do not guarantee employment for any user of the Site. When you utilise the Site, you are entering into a contract with the Provider. By accessing the Site, and the services provided in it or through any of our family of websites that link to this Privacy Policy, including, but not limited to, myperfectcv.co.uk, livecareer.co.uk, and any other Site powered by myperfectcv.co.uk, bold.com, or livecareer.co.uk, you are accessing a Provider offering. 

2. Information We Gather About You

Information we collect about you depends on how you utilise our Site.

(a) Registration, Services and Account Details. You can peruse the Site without registering for an account with us in that instance we may collect information regarding your device, geolocation data, behavioural, target job and target profile. When you register an account or use certain of our services (including, but not limited to, Site email account(s), CV Builder, CV-Check, CV Guide, Cover Letter Builder, Cover Letter Tips, My Perfect CV, CV Review, CV Writing, CV Services, Search Jobs), create a profile, create a CV, search for or purchase services, or otherwise engage with our Site, you must provide certain information such as a username and a valid email address, otherwise, you will not be able to create an account. You must also provide payment information such as credit or debit card details, name and billing address in order to purchase services. This information is only linked to your account once you've logged in as a registered user. We will also gather other data you voluntarily supply, such as forename, surname, contact details, and information you input on the Site, when creating documents (for instance employment status and education).

(b) Information to Respond to Your Enquiries. You may provide us with contact details (for instance, your email address) so we can reply to your enquiries. Details of how you can opt out of receiving communications from us are detailed in the section headed Accessing, Reviewing, and Changing Your Personal Information.

(c)Third party log-in. We may gather some basic information when you access the Site with third-party login credentials such as your name, user name, and your email address.

(d) User Interaction Information. We can also receive other information (e.g., content viewed and information about the advertisements within the content you have been shown or have clicked on, etc.) from your interaction with our Site. To the extent permissible by law of the country of your residence, you agree that we can share your interaction information with, or obtain information about your interaction from, analytics providers, advertising partners, third-party partners, and social media sites until you withdraw your consent for the purpose of providing or improving our services. Certain information that we may have access to from third-party services providers may be controlled by your privacy settings on that service and by managing your agreement. Information that can be passed to analytics providers and advertising partners can be through cookies and tracking technologies. Please see our Cookies and Tracking Technologies Policy for information, including your options in relation to some of these technologies.

(e) Information from other Sources. To the extent permissible by law of the country of your residency, the information we collect can be combined with publicly available information. 

(f) Mobile Information. By agreeing to this Policy you agree that we may gather further information from you if you access our Site via a mobile device (e.g. your unique device identifier, device’s operating system, mobile network provider, location or GPS/geo-location and mobile number). 

(g) Browser Extensions Privacy Notice and Information We Gather. Provider offers certain browser extensions, including but not limited to the “Apply Tool”, that are all available in certain web browsers such as Google Chrome. When you download a browser add-on, we automatically gather certain information from your device or web browser. We automatically gather information from location storage associated with your web browser, including your browsing behaviour for job hunting activity. We can also automatically log your interactions with certain webpages by accessing local storage associated with your web browser. Each browser add-on was created to automatically interact with third-party websites, so we can also gather some information about you when you visit those websites including, clickstream data, operating system being used, the URL of the site you have come from and move to after your visit, data relating to your activities on third party websites (including IP addresses and URLs) via tracking technologies (such as cookies and measurement software), the date and time of your visit and your server's IP address, the geo-location of your device, and the type of payment you use. We collect this information for statistical purposes to find out how our website and each browser add-on is being used. We use this information to assess and, hopefully, enhance your experience. For instance, when you visit a webpage that supports the autofill function, we can record metadata generated by your web browser that identifies one or more autofill fields that you engage with. In this example, we can also access local storage associated with your web browser to determine information which can be or has been entered into an autofill field. We utilise your information to facilitate your completion of job applications across the internet, on our websites and third-party websites and to provide advertising and/or other content that we believe can be of interest to you based upon your browsing behaviour on the internet.

3. Uses, Retention and Storage

We process your information for the following purposes and legal grounds:

(a) Operate our Site and Provide You with Our Services. We utilise the Information we gather to (i) respond to your queries and requests; (ii) provide customer service (e.g., to fulfil product and service orders made by you, give you information about your account to resolve disputes, problems with your account/profile or the Site, administer a contest, sweepstakes or promotions, or to provide information to third parties at your request such as potential employers, job matching services or third party websites, or other career related services); (iii) personalise your experience by providing content on the Site, including targeted advertising or job-related advertising, that we believe can be of most interest to you; (iv) improve the Site, and; (v) provide you with a safe, efficient, and customised experience. and (vi) share it with third parties that help us deliver career enhancing tools and a broader set of services to assist in your career development.

(b) Analyse and Aggregate Non-Personal Information. We utilise aggregate information about our users and non-personal information to analyse Site and user behaviour and prepare aggregated reports.

(c) Prevent Fraud and Comply with the Law. We utilise information from the Site to prevent, detect, and investigate fraud, security breaches, and potentially prohibited or illegal activities, establish, exercise or defend a legal claim, and enforce our Terms of Use. We also utilise information in response to requests by government or law enforcement authorities, or in response to complaints where we are under a legal or regulatory obligation to adhere to a complaint handling procedure.

(d) Marketing & Communications. We utilise your information to contact you to maintain the Site, your account, or to comply with your stated communication preferences, or to provide other services as described at the time when we collect the information from you, or to contact you for other purposes authorised by law. If you have opted to partake in some of our career development Services, the information you share with us can be provided to third parties such as (i) CV editors, (ii) employers or recruiters who can contact you about job opportunities, (iii) employers or other individuals or companies seeking candidates, and/or (iv) other career service providers.

(e) Mobile Data. When you access the Site on a mobile device, we can utilise the information gathered for any purpose set out in this Privacy Policy. For instance, we can utilise this information to provide you with location-based services, such as advertising, search results, and other personalised content. 

To the extent permissible by applicable law, we retain Information for as long as it is necessary to fulfil the purpose(s) for which it was collected, our business purposes, and/or to comply with the applicable laws and regulations. 

4. Disclosure

Information we gather can be shared with:

(a) The Provider Group of Companies. We may disclose the information we collect about you with the Provider’s corporate family (our affiliates and subsidiaries). If we disclose your information to them, their use and disclosure of your information will be subject to this Policy. 

(b) Service Providers. We may disclose your information to service providers under contract who assist with our business operations (such as, but not limited to, fraud investigations, bill collection, payment processing, and site analytics and operations as detailed in Section 8 below). For a complete list of processors and sub-processors, please get in touch with us by sending an email to privacy@bold.com.

(c) Additional Services Enquiries. On the Site, you can express interest in or register for other services. If you do, we will supply information about you to those third parties, or parties acting on their behalf, to carry out your request. In order to provide our Services we may share your Information which may involve in some cases a financial compensation to third parties which assist us in delivering career development services to you. Your information may be shared with third parties such as CV editors, employers, recruiters or job advertisement third-party websites, third parties in the career building industry or that are looking to enter into that industry, or other third parties who are interested in receiving information that we collect about you on the Site. You have the option to opt-out from this type of sharing at any time by modifying your settings on your account or contacting our Customer Service team. You may also publish your information by making use of our digital CV tools. In that instance, your information may be viewed by third parties that utilise our CV database search engine or through other publicly accessible search engines, such as Google and Bing.

(d) Legal and Law Enforcement. We may disclose information that we gather if we believe that such action is necessary to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a summons.

(e) Change of Control. We may share your information if there is a bankruptcy proceeding, if substantially all of our assets are transferred to another company, or if we merge with or are taken over by another business entity. Should any of these events occur, we will endeavour to ensure that the new service provider adheres to this Privacy Policy in relation to your information. 

(f) Advert Networks. On the Website, we collaborate with third parties to serve adverts, provide us with data collection, reporting, ad response measurement and site analytics and assist with delivery of relevant marketing messages and advertisements. These third parties can view, edit or set their own tracking technologies/biscuits. 

(g) Analytics Providers. We may disclose information we collected through our Site to our analytics providers such as Google Analytics, to evaluate usage of our Site, and to help us improve our services, performance and user experiences.

(h) To Protect Ourselves and Others. We may share your information where we believe it is necessary to investigate, prevent, or act regarding illegal activities, suspected fraud, potential threats to the safety of any individual, violations of our Terms of Use, or this Policy, or as evidence in litigation in which we are involved.

(i) Aggregated and Anonymised Information. We may share information that has been collated and anonymised with third parties for marketing, advertising, research, or similar purposes.

(j) Your Agreement. By agreeing to this Privacy Policy, we have obtained your agreement, when necessary, for the disclosure of the information we gather. 

5. Accessing, Reviewing, and Altering Your Personal Information

Registered users can review and amend the Information at any time by accessing their accounts on the Site (through the My Account and My Settings tabs). You should swiftly update your information if it changes or becomes inaccurate. 

6. Your Choices

EU users: please refer to Section 9 below for your statutory rights under the GDPR.

(a) Opting Out of Promotional Communications. You can opt out of receiving our promotional communications by clicking the "My Account" tab and clicking the "My Settings" and "Preferences" tabs. You can also click the unsubscribe link in the footer of any email or newsletter you receive. You can also email us at privacy@bold.com.

(b) Update/Delete or Alter Your CV or Covering Letter. To alter or remove your CVs or covering letters that you have uploaded to our site, log in to your account and click "CV" and "Covering Letter" tabs and select edit or delete.

(c) Site Privacy Settings. Information that you disclose whilst participating on the Site may be public and subject to redistribution by us and any third party that reviews your profile or information that you post. You can alter your privacy preferences at any time by logging into your account and clicking on My Settings. You can also set your preferences for other Provider services as set out in Section 5 or by contacting us as set out in Section 17. Please be mindful that the Provider is not accountable for the uses, disclosures or copies of your public postings on or through the Site that you make public and that are downloaded by third parties.

(d) Administrative/Transactional Messages for Registered Users and Subscribers Cannot Be Switched Off. As we provide an online service, you cannot opt-out of administrative or transactional emails (for example emails about your transactions or policy changes) for your registered account. If you are a Visitor and would like to opt out from receiving transactional emails click here

(e) Removal of Your User Content/Account. You may ask that we erase your account and/or certain personal identifiable information we have gathered from our systems. You can do so by clicking here, by utilising any of the options made available to you by us throughout the Site for this purpose, or by sending us an email at privacy@bold.com. When you ask for your account or your personal identifiable information to be deleted, your CV and profiles will be deleted and no longer accessible to you or visible to others. However, if the information you provided was previously accessed by others, we will not be able to delete the information from their systems. When you erase your information, we will keep logs of your information along with an archival copy of your information, which is not accessible by you or third parties but which might be used by us for record-keeping and internal purposes, including enforcing this Policy. To the extent permitted by applicable law, we may retain information from closed accounts so that we can comply with law, prevent fraud, assist with investigations, resolve disputes, analyse or troubleshoot programmes, enforce our Terms of Use, or take other actions permitted by law. Similarly, if your account or subscription is terminated or suspended, we may retain information to prevent re-registration.

(f) Third-Party Ad Network Opt-Out. We may utilise third-party network advertisers to serve advertisements on third-party websites or other media (e.g., social networking platforms). This enables us and these third parties to target adverts to you for services in which you might be interested. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may utilise cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness of their adverts and to personalise advertising content to you. We may provide these third-party advertisers with information about you, if you've given your consent.

(g) Other Data Choices. Unless otherwise required by the laws of the country of your residence, you may request: (i) a copy of the specific pieces of personal identifiable information that we have collected about you in the last 12 months from the date of your request, and; (ii) that we disclose certain information about how we have handled your personal identifiable information in the previous 12 months. You can make such requests, if you have created an account with us, by logging into your account and clicking here, by utilising any of the options made available to you by us throughout the Site for this purpose, or if you have not created an account, by sending us an email at privacy@bold.com.

(h) Text Message. If you choose to subscribe to our SMS alert service, you acknowledge that message or data charges may be incurred. If you no longer wish to continue with the SMS alert service, you may opt-out by replying “STOP” to the SMS text you received or contact our customer service team by any of the options available here. Please allow 3 to 5 working days to process your request. 

(i) Timing and Third Parties. We will endeavour to comply with your requests as soon as reasonably possible but please note that changes requested of us are not always effective immediately. Furthermore, in certain circumstances, and subject to applicable law, the Provider will not be able or required to comply with part or all of your individual requests. Please be aware that we reserve the right to decline and/or levy a financial charge for requests which are clearly unfounded or excessive. 

7. Information You Share on the Website

(a) Public Information. If you participate in Provider services (e.g., CV posting, profile creation, Job Alerts, Digital CV) that permit you or Provider on your behalf to post your Information on Provider’s searchable databases or third-party sites (e.g., websites, bulletin boards, personal URLs) by posting information or content (such as by posting photos, creating a Digital CV or participating in online forums or communities), or when you interact with our Site through social media sites, plug-ins or other sites or applications, depending upon your privacy settings, the information posted will be publicly available and searchable by individuals. Provider reserves the right to aggregate and/or share that information with third parties to perform our Service. We may not be able to prevent the further use of this information. You'll be able to set your privacy preferences and determine how Public or Private you prefer your account, if you have any queries make sure to contact us. Please also remember to refer to those third-party sites' privacy policies and terms of use to learn more about their privacy practices.

(b) Other services. If you utilise the Site, Provider can create a universal application derived from the information you provide on the Site that will be visible to potential employers and others with immediate needs for prospects or collaborate with us to provide you with tools to enhance your career as well as visitors to the Site. Therefore, your Site Profile and/or Digital Profile ("Profile") will be publicly visible. You can choose to have your Profile limited by altering your settings preferences on your Dashboard and change your settings from visible to anyone searching on the site, as well as other search engines such as Google and Bing, or featured on other Profiles ("Public") to only visible to you ("Unpublish" or "Private") as well as have only some of these features enabled. You agree that employers, other third parties viewing your information and/or Provider may use the contact information you have provided to contact you and you understand that this consent is not a condition to having access to the Site or Provider services. 

(c) Scores, ratings and other instruments. As part of the Site offering you may interact with tools that provide matching, check and recommendation mechanisms regarding the information you have provided in the system when creating your CV. These tools are computer based algorithms that have been created to assist you in your career search journey and do not guarantee that you will receive a job offer. When you utilise these tools you also agree and comprehend that the Provider cannot guarantee that you will be contacted by an Employer or receive a job offer, even when your CV has received a high "strength" number. Your use of these tools is entirely at your own risk and provides no guarantees whatsoever.

8. Tracking Technologies (Biscuits)

Depending on your country of residence, when you first accessed this Site you may have been prompted to set your cookie setting preferences. Your biscuit settings will be saved in accordance with privacy laws. Otherwise, when you visit our Site, we collect usage information sent to us by your computer, mobile, or other access device that tells us how you are using the Site including, but not limited to, video-viewing, site views, key stroke data, mouse movement, scrolling, clicks, and typing ("usage information"). We utilise tracking technologies (including cookies, unique device identifiers, web beacons/GIFs, embedded scripts, e-tags/cache browsers, cross-device tracking) to collect usage information. More information about cookies can be found on our Cookie Policy. We can utilise tracking technologies for a variety of purposes, including:

(a) Necessary. We can utilise tracking technologies required for system administration, to prevent fraudulent activity, enhance security or permit you to make use of shopping trolley functionality. We are not obliged to gain your consent for tracking technologies that are operationally necessary.

(b) Performance and personalisation. We can utilise cookies or other tracking technologies to assess the performance of the online services, including as part of our analytic practices to enhance the content offered through the online services. For instance, as detailed in our Cookies and Tracking Technologies Policy, we utilise Google Analytics and Inspectlet to carry out site analytics.

(c) Analytics. We can utilise tracking technologies to inform us, for instance, whether you've visited the Site previously or if you're a new visitor and to assist us in identifying the features in which you have the most interest.

(d) Advert. We can utilise tracking technologies to provide content, including adverts, relevant to your interests on our online service and third-party sites based on how you interact with our advertisements or content as well as track the content you access (including video viewing). Further information on this, and your opt-out choices, is in the “Your Choices” section above.

We can also gather password information from you when you log in, as well as computer and/or connection information. During some visits we may utilise software tools to measure and collect session information, including page response times, download errors, time spent on certain pages and page interaction information.

Tracking technologies, such as cookies, are primarily alphanumeric identifiers that we transfer to your computer’s hard disk through your web browser for record-keeping purposes. When you visit the Site, we and our business partners may utilise tracking technologies to enhance your online experience or customise our offerings. For some customers a privacy settings option will be available to set your biscuit preferences. Some biscuits allow us to make it easier for you to navigate our Site, while others are used to enable a faster login process. A few additional important things you should know about our use of tracking technologies (biscuits):

  • We can offer certain features that are available only through the use of tracking technologies.
  • There are two types of biscuits: session biscuits and persistent biscuits. We utilise both session and persistent tracking technologies. Tracking technologies can either be persistent (i.e., they remain on your computer until you delete them) or temporary (i.e., they last only until you close your web browser). You might be able to refuse tracking technologies if your browser allows, although doing so can interfere with your use of the Site. Refer to the help section of your browser, browser extensions, or installed applications for instructions on blocking, deleting, or disabling tracking technologies such as cookies.
  • We encode and safeguard the tracking technologies that the Provider sets, so that only we can interpret the information stored in them. You may come across tracking technologies from our third-party service providers, whom we have permitted on our Site to assist us with various aspects of our Site operations and services, such as Google Analytics.
  • You may also come across tracking technologies from third parties on certain pages of the websites that we do not control and have not authorised. (For instance, if you view a web page created by another user, there might be a cookie placed by that web page).
  • Clear GIFs are tiny graphics with a unique identifier, similar in function to biscuits. In contrast to biscuits, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may utilise clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our third-party service providers may also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded on.

For more information about the use of cookies and similar technologies on our Site please review this Privacy Policy and our Tracking Technologies Policy.

9. Notice to Residents of the European Economic Zone 

Provider complies with the General Data Protection Regulation (“GDPR").
As such, Provider affords to all European data subjects their respective data protection rights to the extent they are applicable including: 

(i) right to correct inaccurate data; 

You have the right to obtain from us, the rectification of inaccurate personal data. Taking into account the reasons for the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement. You may carry this out by logging in to your general account settings or by any of the methods provided on our Contact Us page.

(ii) right to erasure (deletion of your personal data); 

You have the right to request erasure or deletion of the personal information collected by us, only when: the personal data is no longer necessary in relation to the purposes for which it was gathered or otherwise processed; or you withdraw consent on which the processing was based, and where there is no other legal ground for the processing; or you object to the processing and there are no overriding legitimate grounds for the processing, or you object to the processing for direct marketing purposes; or when the data has been unlawfully processed, or the personal data has to be erased in compliance with a legal obligation. If you wish to exercise your right to erasure you can do so by clicking here or by sending an email to privacy@bold.com

(iii) right to restrict processing of your personal data; 

You have the right to restrict the processing of your personal data if (i) the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data (ii) the processing is unlawful and you oppose the erasure of the personal data, and request the restriction of their use instead; (iii) we no longer need the personal data for the purposes of the processing, unless the processing is required by you for the establishment, exercise or defence of legal claims; 

(iv) right of data portability; 

You have the right to receive the personal data provided to us via the site in a commonly used and machine-readable format – if it was collected in an automated manner, and the legal bases of processing was your consent or a contract (for instance, if you agreed to our terms of service). You may also ask us to transfer your information to another provider or data controller, where technically feasible.

(v) right to withdraw consent, 

When you have given your agreement to the processing, you may retract it at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. This includes your right to withdraw consent to the sharing of your data for financial compensation with a third party. You can exercise this right by sending a request to privacy@bold.co.uk

(vi) right to object;

When you object, we will cease to process your personal data unless we can demonstrate compelling, legitimate grounds for the processing that override your interests, rights and freedoms. Where your data is processed for direct-marketing purposes, you have the right to object at any time to the processing of your data for such marketing. 

(vii) right to access and to obtain a copy of personal data; You have the right to obtain from us confirmation as to whether or not your personal data is being processed, and, where that is the case, we will provide you with access to the personal data. If you've registered an account on our Site, you can access certain of your personal data within your account. For obtaining a copy of other information not available through the site please use this linkor contact our customer service with your specific request for assistance. If you do not have an account on our Site, please send us an email to privacy@bold.com with your request and one of our agents will do their utmost to verify whether we hold any of your personal data. 

(viii) the right not to be subject to a decision based solely on automated processing; 

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This will not apply if the decision: (a) is necessary for entering into, or performance of, a contract between you and us; (b) is authorised by Union or Member State law to which we are subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or is based on your explicit consent.

You also have the right to make a complaint to the appropriate data protection regulatory authority (Article 77 of the GDPR). You can lodge this complaint both at your place of residence, at your place of work or at the place of the data protection breach you are complaining about. You may also lodge a complaint with the supervisory authority at our place of representation in Luxembourg.

You can exercise any of these rights by getting in touch with us at privacy@bold.com. Also if you have registered an account on our Site, you can request data access or request data deletion by clicking this link. In order to protect your personal details from unauthorised access, we may request that you provide sufficient details to identify yourself prior to granting access to your personal information.

We take suitable steps to ensure sufficient protection of the privacy rights of EEA data subjects in relation to personal information that we transfer outside the EEA to a country that is not subject to an adequacy decision by the EU Commission. Please refer to Clause 14 for more information about storage and international transfers.

In certain circumstances, and subject to applicable legislation, the Provider will not be able or required to comply with part or all of your individual requests. Please be aware that we reserve the right to refuse and/or levy a financial charge for requests which are clearly unfounded or excessive, for instance due to their repetitive nature. If you have unresolved issues, you have the right to lodge a complaint with an EU Supervisory Authority. The representative is Auxiliant S.à.r.l. 1A, Thomas Edison Street, L-1445 Strassen, Luxembourg.

We have appointed a Data Protection Officer. You may contact the Data Protection Officer by sending an email to dpo@bold.com.

Providing your information to us is optional, but it can affect our ability to offer the Service to you. For instance, if you do not provide your full personal details, we will not always be able to respond to your enquiry in a timely fashion. 

We process your information for the following purposes and legal grounds:

(a) Operate our Site and Provide You with Our Services. We utilise the Information we collect as it is necessary for the performance of a contract between you and us in particular to (i) respond to your enquiries and requests; (ii) provide customer service (e.g., to fulfil product and service orders made by you, give you information about your account to resolve disputes, problems with your account/profile or the Site, administer a contest, sweepstakes or promotions, or to provide information to third parties at your request such as potential employers, job matching services or third party websites, or other career related services); (iii) personalise your experience by providing content on the Site, including targeted advertising or job-related advertising, that we believe can be of most interest to you. Furthermore, we utilise the information we gather to (iv) enhance the Site and; (v) provide you with a secure, efficient, and personalised experience; this is our legitimate interest within the meaning of art. 6(1) f of GDPR.

(b) Analyse and Aggregate Non-Personal Information. We utilise aggregate information about our users and non-personal information to analyse Site and user behaviour and prepare aggregated reports. This is our lawful interest within the meaning of art. 6(1) f of GDPR

(c) Prevent Fraud and Comply with the Law. We utilise information from the Site to prevent, detect, and investigate fraud, security breaches, and potentially prohibited or illegal activities, and for the purposes of the following legitimate interest: to establish, exercise or defend a legal claim, and enforce our Terms of Use. We also utilise information in response to requests by government or law enforcement authorities, or in response to complaints where we are under a legal or regulatory obligation to adhere to a complaint handling procedure.

(d) Marketing & Communications. We utilise your information as it is necessary for the performance of a contract between you and us in particular to contact you to maintain the Site, your account, or to comply with your stated communication preferences, or to provide other services as described at the time when we collect the information from you, or to contact you for other purposes authorised by law. If you have opted to partake in some of our career development Services, the information you share with us can be provided to third parties such as (i) CV editors, (ii) employers or recruiters who can contact you about job opportunities, (iii) employers seeking candidates, and/or (iv) other career service providers.

(e) Mobile Data. When you access the Site on a mobile device, we can utilise the information gathered for any purpose set forth in this Privacy Policy. For instance, we can utilise this information to provide you with location-based services, such as advertising, search results, and other personalised content. This is our legitimate interest within the meaning of art. 6(1) f of GDPR To the extent permissible by applicable law, we retain Information for as long as it is necessary to fulfil the purpose(s) for which it was collected, our business purposes and/or to comply with the applicable laws and regulations. This includes but is not limited to the purposes stated in the previous paragraphs of this Clause 9. 

(f) Profiling. We utilise your data to create your professional profile corresponding to your skills, education, experience, interests and preferences. Then, based on the profile created we suggest how you might complete your profile and encourage you to utilise our other services. We may also suggest job offers to you which match your profile, and recommend your profile to employers, whom we believe may be seeking candidates with experience and qualifications similar to yours. Based on your information we may also provide you with targeted adverts.

Please refer to Section 3 for more information about data retention.

10 . Notice to United Kingdom ("UK") inhabitants

Provider complies with the UK General Data Protection Regulation (“UK GDPR”) and affords UK residents their rights in accordance with law. All rights listed in Clause 9 shall apply to UK residents respectively. If you are a UK resident and have any queries please contact us by sending an email to legal@bold.com. 

11 . Third Parties

Our Site may contain links to other third-party websites and Provider may supply products and services that share information with third-party sites for your job hunt. We are not responsible for the privacy practices or the content of these third-party sites so it is important to familiarise yourself with their privacy policies before providing your Information. 

12 . Information Security

We maintain suitable technical, physical, and administrative security measures designed to protect the security of your information against loss, misuse, unauthorised or accidental access, disclosure, copying, use or alteration. However, no method of transmission over the Internet or method of electronic storage is completely secure. Therefore, we cannot guarantee its absolute safety. If you wish to contact our Data Protection Officer, please send an email to dpo@bold.com.

13. Children's Privacy

The Site is a general audience site and it is not intended for children under the age of 16. We do not knowingly gather information via our websites, applications, services, or tools from users in this age group. Our websites are equipped to block the registration of a minor under 16 years of age. If you become aware that a child under 16 has provided us with information, please contact us immediately so we can remove such information from our system.

14. Storage and International Transference

As we operate internationally, and many of our computer systems are currently based worldwide, for the purposes set out in this Privacy Policy your Information can be stored and processed elsewhere by us, our affiliates or an unaffiliated service provider. The data protection and privacy rules do not always provide the same level of protection as in other parts of the world, such as the European Economic Area (“EEA”). Nevertheless, we have made certain that our service providers and affiliates have been subjected to stringent contractual provisions in their agreement with us, including Standard contractual clauses, to ensure that an adequate level of data protection for your data is achieved. When you set up an account/profile or otherwise supply us with your details, you agree to the gathering, storage, utilisation of certain tracking technologies as outlined above, and/or handling of your details, including personal information, in the United States and other countries. To obtain a copy of the relevant transfer mechanism or additional information on the transfers, please address these requests by any of the means provided in our Contact Us page. 

15. Notice Regarding Review and Updates.

From time to time and at least once every twelve (12) months we review this Privacy Policy and we may choose to update its terms. The Privacy Policy displayed at any time or intermittently on the Site shall be considered to be the Privacy Policy currently in effect. You agree that we can inform you about significant changes in the way we handle your Information by placing a notice on the Site. You should check the Site regularly for updates. Furthermore, we have supplied the Privacy Policy Highlights section to provide a summary of the main points of our Full Privacy Policy for your ease. In the event of a conflict between the Privacy Policy Highlights and the Full Privacy Policy, the Full Privacy Policy will have precedence.

16. CALIFORNIA RESIDENTS

Various regulations across the country require that we provide certain information to customers about how we manage personal information that we have gathered from them. "Personal data" is any data that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, including the categories identified in the table below to the extent they identify, relate to, describe, are capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household.

(a) Categories of Personal Information that We Gather and Disclose. We may gather and disclose for a business purpose the following personal information from users:(1) name, contact details and identifiers (real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers); (2) customer records (electronic customer records containing personal information, such as name, signature, physical characteristics or description, address, telephone number, education, employment, employment history); (3) protected classifications (characteristics of protected classifications under California or federal law such as race, colour, sex, age, religion, national origin, disability, citizenship status, and genetic information) only when voluntarily provided by the customer; (4) purchase history and tendencies (commercial information including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies); (5) usage data (internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding consumer’s interaction with an Internet website, application, or advertisement); (6) geolocation data (precise geographic location information about a particular individual or device); (7) employment history (professional or employment-related information); (8) education information (information about education history or background), (9) Audio/Visual: audio, electronic, visual, thermal, olfactory, or similar information, and; (10) profiles and inferences (inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes).

The list above does not address our handling of personal information that is subject to an exemptions under law.

(b) Consumer Rights. State laws afford consumers certain rights and place limitations on specific business practices as outlined below.

(1) Do Not  Sell or Share my Personal Details. The California Consumer Privacy Act (CCPA) provides all California residents the right to opt out of the selling or sharing of their personal information. The DPA recognises personal data as information that identifies, relates to, or could reasonably be associated with an individual or his/her household. Provider uses your personal information to carry out the contract and provide our Services. When you utilise our Services, we may deploy data collection tools (i.e. cookies, web beacons, and other similar technologies) and share some of your digital activity information with third parties in order to receive information about the performance of our marketing campaigns and the usage of our websites and applications. Details about how we utilise your information and for what purposes can be found in our Privacy Policy. Due to the wide-ranging definition of data selling under the CCPA, in some cases, our sharing of data may be considered a sale. You may ask us to cease sharing or selling your personal information and we will respect your request for at least 12 months before asking you to opt back in. You have the right to exercise this right personally or through an authorised representative, who will have to provide the necessary evidence to confirm his/her representative status. Your request will be subject to an identification process, and we will not fulfil your request unless you have provided all the necessary information.

To make a Do Not Sell or Share my Personal Information request, please submit your details using the form available here or by contacting us at privacy@bold.com and following the instructions.

Residents of states with applicable Do Not Sell or Share My Personal Information effective regulations, please note that Provider will also honor your Do Not Sell or Share my Information request(s), in compliance with state privacy regulations.

Our US websites recognise and adhere to the Global Privacy Control (“GPC”) signal for relevant US jurisdictions. By using our website, you acknowledge and agree that we will process your browser’s GPC signal as a request to not share your information with our advertisers. If a GPC signal is detected from your browser, we will not display a cookie banner during your visit to our site and instead, we will automatically apply the relevant privacy settings to your data according to applicable regulations and pursuant to our privacy policy.

(2) Requests for Copy, Amendment, Deletion and Right to Know. Subject to certain exceptions, and as a California consumer, you have the right to make the following requests: at no cost, up to twice every 12 months:

(i) Deletion. You have the right to ask for the removal of personal information that we have gathered about you, subject to certain exceptions (for instance, where the information is used by us to detect security incidents, debugging or to comply with a legal obligation).

(ii) Copy. Customers have the right to request a copy of the specific pieces of personal data that we have collected about them in the previous 12 months.

(iii) Right. Customers have the right to request a correction of any inaccurate personal information we hold about them. 

(vi) Right to Know. Customers have the right to ask that we reveal certain information about how we've managed personal information in the previous 12 months, including the: 

  • categories of personal data collected
  • categories of personal information sources
  • business and/or trade purposes for collecting and selling their personal information
  • categories of third parties/with whom we have disclosed or shared their personal data
  • categories personal information that we have disclosed or shared with a third party for a business purpose.
  • categories of personal data collected
  • categories of third parties to whom the consumer’s personal data has been sold and the specific categories of personal data sold to each category of third party

(c) Submitting Enquiries. You can submit a copy, deletion and right-to-know request online by sending a request through your account if you are registered on the Site, by emailing us at privacy@bold.com, by utilising any of the options made available to you by us throughout the Site for this purpose, or by contacting us at the freephone number in Contact Us.

 (d) Incentives and Discrimination. The CCPA and similar state laws prohibit discrimination against consumers for exercising their rights under the CCPA and similar state laws and impose requirements on any financial incentives offered to California consumers related to their personal information. Businesses may offer different prices, rates, or quality of goods or services if the difference is reasonably related to the value of the consumer’s data. 

17. Contact Us

The Site is controlled and operated by the Provider. Whether you access the services through any of our family Websites, you may contact Provider by any of the means in the Contact Ussection on the Website. If your queries are not resolved online, you can email us at privacy@bold.com, write to us at Auxiliant S.à.r.l, 1A, Thomas Edison Street, L-1445 Strassen, Luxembourg or to BOLD LLC at City View Plaza II, Suite 6000, 48 Road 165, Guaynabo PR 00968.