Privacy Policy

Last updated: 26 December 2022

Thank you for choosing CV Genius, owned by Sonaga Tech Limited, Hamilton, Zweigniederlassung Luzern, Switzerland (“Company”, “Service Provider”, “we”, “us” or “our”), to create your CV and cover letter. We are committed to protecting your information and your right to privacy. Your data controller is Sonaga Tech Limited, Hamilton, Zweigniederlassung Luzern, Switzerland. If you have any questions or concerns about our policy or our practices with regard to your personal information, please contact us at [email protected].

When you visit our website https://poccvgeniusdev.wpengine.com (the “Site”), and use any of the services, or you share with us some personal information, we take your privacy very seriously. In this Privacy Policy, we seek to explain, in the clearest way possible, what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this Privacy Policy that you do not agree with, please discontinue use of the Site and our services.

This Privacy Policy applies to all information collected through our Site. It also applies to any service related to the Site, sales, marketing or events (we refer to them collectively in this privacy policy as the “Services”).

Please read this Privacy Policy carefully as it will help you make informed decisions about sharing your personal information with us.

Table of Contents

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

We collect information that you voluntarily provide us when opening an account, or when registering at the Site expressing an interest in obtaining information about us or our products and services, when participating in activities on the Services or otherwise contacting us. Please be informed that, in some cases, providing some personal information will be required to use our service. Otherwise, we may not be in a position to render services. This relates in particular to your email address (if you decide to register the account) and information you provide while using our services.

The information that we collect depends on the context of your interactions with the Site and the Services, the choices you make and the products and features you use. The personal information we collect can include, but is not limited to, the following:

Information provided by you. We collect data provided by you when using our services that may be, for example, your name, surname, email address, phone number, address and/or information you introduced to our tools (professional experience, information about your education, skills), but also collected from surveys, CVs and other job application or similar data.

Credentials. We collect passwords, password hints and similar security information used for authentication and account access.

Social media login data. We provide you with the option to register using social media account details, like your Facebook or another social media account. If you choose to register in this way, we will collect the information described in the section called ‘HOW DO WE HANDLE YOUR SOCIAL LOGINS’ below. All information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information automatically collected. We may collect certain information when you visit, use or navigate the Site and the Services. This information may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Policy.

Online identifiers. We collect devices, tools and protocols, such as IP (Internet Protocol) addresses, cookie identifiers, or others such as the ones used for analytics and marketing, device’s geolocation and other similar data.

Information collected from other sources. We may collect information about you from third parties when you use your social media account to sign up with us. Examples of the data collected from these services are your email, first name, last name and login information from those third parties.

2. HOW DO WE USE YOUR INFORMATION?

We use personal information collected via our Services for a variety of purposes as described below. We process your information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on for the reasons described next to each purpose listed below.

We use the information we collect or receive:

To facilitate account creation and login process. If you choose to link your third-party social media account to your account with us (such as your Google or Facebook account), we may use the information you allowed us to collect from those third parties to facilitate the account creation and log-in process for the performance of the contract. See the section below headed ‘HOW DO WE HANDLE YOUR SOCIAL LOGINS’ for further information;
To send you marketing and promotional communications. We may use the information you send to us for marketing purposes as this is our legitimate interest. You can opt-out of our marketing emails from us at any time (see the ‘WHAT ARE YOUR PRIVACY RIGHTS’ below). Marketing emails from our partners will only be sent to you if you grant your consent;
To provide you with our Services: to (i) respond to your questions and requests; (ii) provide customer service, (e.g. to fulfill product and service orders made by you; to give you information about your account to resolve disputes, problems with your account/profile or the Site; to administer a contest, sweepstakes or promotions). We may use your information to send you product, service and new feature information and/or information about changes to our terms, conditions and policies; (iii) to request feedback and to contact you about your use of our Services;
To post testimonials. We post testimonials on our Services that may contain user information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update or delete your testimonial, please contact us at [email protected] and be sure to include your name, testimonial location and contact information;
Deliver targeted advertising to you. We may use your information to develop and display content and advertising (and work with third parties who do so), tailored to your interests and/or location, and to measure its effectiveness. This is our legitimate business interest. For more information, see our Cookie Policy;
Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in competitions;
Request feedback. We may use your information to request feedback and to contact you about your use of our Services;
To protect our Services. We may use your information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention);
To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond. This is our legitimate interest;
For location-based services. When you access our Site through your mobile device we may access your location to provide you with location-based services and other personalised content. This is our legitimate interest;

For other business purposes. We may use your information for other business purposes (this is our legitimate interest), such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

We may process or share data based on the following legal basis:

Consent. By using the Services, you are contracting with us and agree that we may process your data;
Legitimate interests. We may process your data when it is reasonably necessary to achieve our legitimate business interests;
Performance of a contract. Where we have entered into a contract with you, we may process your information to fulfil the terms of our contract;
Legal obligations. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements);
Vital interests. We may disclose your information where we believe it is necessary to investigate, prevent or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

Vendors, consultants and other third-party service providers. We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data about how you interact with the Services over time. This information may be used to, among other things, analyse and track data, determine the popularity of certain content and better understand online activity. We may also share your information with third parties if the activity is understood to be illegal, fraudulent or poses a potential threat to security. Unless described in this Privacy Policy, we do not share any of your information with third parties for their promotional purposes. Data protection laws are not the same in all parts of the world, but as part of our business protocols and to ensure the safety of your data, we have contracts in place with third parties who we share personal information with and have instructed them to hold your data securely and use it only for the purpose set out in the contract. These agreements may include the use of Standard Contractual Clauses when sharing EU customer information.

If you are an EU resident, please note that we are cooperating with vendors all over the world. That is why your data may be transferred outside the European Economic Area (“EEA”). We are making the best effort to ensure your data is safe. That is why transfer will only take place in accordance with the applicable regulations. To obtain a copy of the relevant transfer mechanism or additional information on the transfers, please address these requests to [email protected].

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.

4. WHO WILL YOUR INFORMATION BE SHARED WITH?

We share and disclose your information with third parties for the following purposes: advertising, direct marketing and lead generation, allow users to connect to their third-party accounts, cloud computing services, communicate and chat with users, invoice and billing, social media sharing and advertising, user account registration and authentication, web and mobile analytics, website hosting, customer satisfaction, job alerts and provision of services. We may also share your information with third parties if the activity is understood to be illegal, fraudulent or posts a potential threat to security. If we have processed your data based on your consent and you wish to revoke your consent, please Contact Us.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Depending on your country of residence, you may be able to select your cookie preferences. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

Our Services offer you the ability to register and login using your third-party social media account details. Where you choose to do this, we may receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list and profile picture, as well as other information you choose to make public.

We use the information we receive only for the purposes that are described in this privacy policy or that are otherwise made clear to you on the Site. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy policy to understand how they collect, use and share your information, and how you can set your privacy preferences on their sites and apps.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep your information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). When your data is processed based on our legitimate interest (for example, for data analysis, or to respond to your legal request) you can always object to such processing. If you object to the processing of your personal data, we will discontinue such processing if the objection is well-founded by law.

When we have no ongoing legitimate business need to process your information, we will either delete or anonymise it, or, if this is not possible (for example, because your personal information has been stored in backup archives), we will securely store your information and isolate it from any further processing until deletion is possible.

If data is processed based on your consent, we will process it until you withdraw your consent. If you wish to revoke your consent, please Contact Us.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate technical and organisational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the Internet itself is 100% secure. Although we will do our best to protect your information, transmission of information to and from our Services is at your own risk. You should only access the services within a secure environment. Our Data Protection Officer may be contacted by sending an email to [email protected].

8. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18. If we learn that information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at [email protected].

9. WHAT ARE YOUR PRIVACY RIGHTS?

Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information or delete it in some circumstances. To request to access, update or delete your personal information, please submit a request by clicking here. You can also make your request by sending an email to [email protected] or contacting one of our representatives through the phone number provided here. We will respond to your request within 30 days.

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information; (ii) to request data rectification or erasure; (iii) to restrict the processing of your personal information; (iv) right to withdraw consent; (v) right to object and (vi) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please click here, send us an email to [email protected] or use the contact details provided in Section 18 below. You also have a right afforded by Article 77 of GDPR to file a complaint with the competent data protection authority. This complaint may be filed where the data protection breach occurred, at your place of work or your residence.

Please know that some minimal information will be requested for identification purposes and as a safeguard to your privacy before providing access to your personal data. If you do not provide this information, it will affect our ability to provide the information requested in a timely manner. GDPR provides us the right to refuse and/or charge a fee for requests that are found to be manifestly unfounded or excessive. We will consider and act upon any request in accordance with applicable data protection laws. For the purposes of this section, your data controller is Sonaga Tech Limited, Hamilton, Zweigniederlassung Luzern, Switzerland.

If we are relying on your consent to process your information, you have the right to withdraw your consent at any time. Please note, however, that this will not affect the lawfulness of the processing before its withdrawal.

If you have questions or comments about your privacy rights, you may email us at [email protected].

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

■ Log into your account settings and update your user account

■ Contact us using the contact information provided

Upon receiving your request to terminate your account, we will proceed to deactivate it. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

Cookies and similar technologies: When accessing the Site you may have been prompted to provide consent with regards to your cookie preferences. You can modify your selection at any time by login in and accessing your Settings page. For further information, please see our Cookie Policy.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the ‘Unsubscribe’ link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list. However, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt out, you may:

■ Note your preferences when you register an account with the site

■ Access your account settings and update your preferences

■ Contact us using the contact information below

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers, and some mobile operating systems and mobile applications, include a Do-Not-Track (“DNT”) feature or setting that you can activate to signal your privacy preference of not having data about your online browsing activities monitored and collected. No uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

This section exclusively and only applies to users that are California residents in compliance with the California Consumer Privacy Act (“CCPA”). ‘Personal information’, according to the CCPA is ‘information 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.’ California residents have the right to opt out of the sale of their personal information. We do not sell personal information. Under the CCPA we are prohibited from discriminating against California residents for exercising their rights. There are also certain requirements we must meet if any financial incentives are offered to California residents in connection with our handling of their personal information (we improve our offering when the difference in pricing, rates or quality of goods is reasonably related to the value of the California resident’s personal information).

If you are a California resident, you have the following rights (subject to some exceptions):

The right to request deletion of personal information that we have collected about you.
The right to request a copy of the specific pieces of personal information that we have collected about you in the last 12 months.
The right to request that we disclose certain information on how we have handled your personal information in the prior 12 months, which include the categories of personal information collected and sources of personal information, the business purposes for collecting and selling personal information, the categories of third parties with whom we have shared your personal information, the categories of personal information that we have disclosed with a third party for a business purpose, the categories of personal information collected and the categories of third parties to whom your personal information has been sold, and the specific categories of personal information sold to each category of third parties.
Do not sell. California consumers have the right to opt out of the sale of their personal information.
Do not sell or share my personal information. In compliance with privacy regulations enacted in various US states, we afford the right to opt out of selling or sharing of personal information. Personal information is generally defined as information that identifies, relates to, or could reasonably be linked to a person or his/her household. Your personal information is used as part of the performance of the contract, to provide you with our services, but may be shared with other third parties. You can find more details of how we use your personal information in our Privacy Policy. We may also drop cookies or other collection tools and share your activity. From the information shared we may receive information about the performance of our services and campaigns. The definition of selling or sharing of personal data is very broad, therefore the exchange of information with third parties or service providers may be considered a sale. If you wish to opt out of the sale or sharing of your personal information you may do so by clicking on the link provided on our home page or sending an email to [email protected]. If an agent will make the request on your behalf he or she will need to provide the necessary evidence to confirm his/her agent status. After we verify and confirm your identity as part of this process and may require additional information if needed.

We may collect and share for a business purpose the following personal information from California residents:

Name, contact information and identifiers – real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name or other similar identifiers.
Customer records – electronic customer records containing personal information, such as name, signature, physical characteristics or description, address, telephone number, education or employment history.
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.
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.
Usage data – Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a California consumer’s interaction with an Internet website, application or advertisement.
Geolocation data – precise geographic location information about a particular individual or device.
Employment history – professional or employment-related information.
Education information – information about education history or background.
AudioVisual – audio, electronic, visual, thermal, olfactory or similar information.
Inferences drawn from any of the information identified above to create a profile about a California consumer reflecting the California consumer’s preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities and aptitudes.

The categories above do not address our handling of personal information that is subject to an exemption under Section 1798.145(c) – (f) of the CCPA.

You may submit a deletion, copy and right-to-know request online by emailing us at [email protected] or contacting us at the toll-free number in the contact us section below. CCPA prohibits businesses from any type of discrimination against California residents that exercise their CCPA rights.

12. DO WE MAKE UPDATES TO THIS POLICY?

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated ‘Revised’ date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may contact us by calling us on Phone: 0808 196 2674 (Monday to Friday, 8 AM – 12 AM and Saturdays and Sundays, 10 AM – 6 PM), by sending an email to [email protected], or by post to Sonaga Tech Limited, Hamilton, Zweigniederlassung Luzern, Hertensteinstrasse 51, 6004 Luzern, Switzerland.