Last modified: February, 2021
Joonko Diversity, Inc. and its fully owned subsidiary, Joonko Diversity Ltd. (“Joonko Diversity”, "us", "our" or "we") offers algorithm-based solutions to drive employment diversity (the "Services"), and it is committed to respecting your privacy rights.
By using the Service and/or accepting our Terms of Service (which you can find here), you hereby agree to the collection and use of your information as we have outlined in this Policy. Capitalized terms used and not otherwise defined herein, shall have the respective meanings ascribed to them under our Terms of Service.
We collect information that may personally identify you, which exists on your systems (if you are a Customer and we access your systems to provide you with our Services) or derived from your browsing activities on our Website (the “Personal Information“). This may include:
1.1. your name, age/date of birth and gender, education description, professional experience, training;
1.2. your contact details; postal address including billing and delivery addresses; telephone numbers (including mobile numbers) and e-mail address;
1.3. your online browsing activities on our Website;
1.4. your password(s);
1.5. your interests, preferences, feedback and survey responses;
1.6. your location;
1.7. your correspondence and communications with Joonko Diversity; and
1.8. other publicly available personal data, including any which you have shared via a public platform (for example your LinkedIn profile).
2.1. Joonko Diversity collects information, including Personal Information, which exists on your or one of our Customers' systems (after obtaining your or our Customer's consent), which personally identifies you. For example, the written resume (curriculum vitae) which was submitted by you directly to us or to one of our Customers
2.2. In addition, Joonko Diversity collects information, including Personal Information, during the registration process to our Service, and your online browsing activities on our Website.
2.3. Joonko Diversity may also collect billing and account information for credit cards, payment cards or other payment systems from clients and share this information with our billing and payment processors.
2.4. We do not store credit card or payment card numbers after they have been forwarded to our billing and payment processors.
2.5. Cookies. Like many other websites, Joonko Diversity uses “cookies” to collect data in order to provide our users with a personal experience when accessing our Website.
What are Cookies? Cookies are small data files which are sent to your device (e.g., computer or mobile device) by a website or other online application, to enable the storing of information which uniquely identifies you (e.g., remembering web pages that were viewed).
How do you disable cookies?i If you want to disable cookies, you will have to change your browser's settings to reject cookies. Please note that if you disable all cookies, some (or all) of the features and functionality of our Service may not be available to you.
3.1. Joonko Diversity collects information, including Personal Information, which exists on your or one of our Customers' systems (after obtaining your or our Customer's consent), which personally identifies you. For example, the written resume (curriculum vitae) which was submitted by you directly to us or to one of our Customers
3.1.1. to provide our Services, including, by offering former candidates of Customer as well as other customers of Joonko Diversity with employment opportunities with other Joonko Diversity's customers;
3.1.2. to audit and improve our Service;
3.1.3. to manage any registered account(s) that you hold with us;
3.1.4. to verify your identity;
3.1.5. for crime and fraud prevention, detection and related purposes;
3.1.6. with your agreement, to contact you electronically about promotional offers, products and services which we think may interest you, as well as send you periodic updates, tips, reports and Newsletters (as defined below);
3.1.7. for market research purposes - to better understand your needs;
3.1.8. to enable the team of Joonko Diversity to interact with you; and
3.1.9. where it has a legal right or duty to use or disclose your information (for example in relation to an investigation by a public authority or in a legal dispute);
3.1.10. for customer relations, queries, complaints or disputes, including providing support on Website operations;
3.1.11. for managing insurance claims by Customers;
3.1.12. cybersecurity needs, fraud detection and misuse of our website;
3.1.13. Enhancements and improvements to your and others experience with our Website.
3.2. Marketing (Promotional communications)
3.2.1. Joonko Diversity uses your personal data for electronic marketing purposes (with your consent) and may send you electronic mail to update you on promotional offers, products and services which we think may interest you and are relevant to you as an individual (the "Newsletters").
3.2.2. You are not obligated by law to receive our Newsletters and you have the right to opt out of receiving such communications at any time, by:
188.8.131.52. following the unsubscribe instructions included in each Newsletter; and/or
3.3. Sharing your information with third parties
3.3.1. We may use and share your name, business name, e-mail address and other information related to the Service (in this Section 3.4, the "Information") with certain third-parties that help us operate our Service, such as cloud providers, newsletter distribution service providers and other similar service providers. When we use such third parties, we restrict them from using or disclosing the Information, except as required to perform the services on our behalf or to comply with legal requirements.
3.3.2. Other than as described in this Section 3, Joonko Diversity will not disclose your Information to any third party.
3.3.3. We will never sell or rent our customers' data to other organisations for marketing purposes.
3.3.4. We may share your data with:
184.108.40.206. credit reference agencies and payment card issuers (such as Visa, Mastercard and American Express) where necessary for card payments;
220.127.116.11. governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers where we are required to do so (a) to comply with our legal obligations; (b) to exercise our legal rights (for example in court cases); (c) for the prevention, detection, investigation of crime or prosecution of offenders; and (d) for the protection of our employees and customers;
18.104.22.168. If Joonko Diversity becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, it may transfer all the Information that was collected from users in connection with such a transaction.
3.3.5. We may post our own Customers' testimonials on our Website which may contain personally identifiable information. We will obtain your consent to post your name along with its testimonial (unless such information was made public by you).
3.4. International transfer of information
3.4.1. For US-residents. Joonko Diversity is a US-based company. To deliver our Services to you, it may sometimes be necessary for us to share your data outside of the United States. Joonko Diversity is providing access to your data, to its fully owned subsidiary Joonko Diversity Ltd, which is located in the State of Israel. These transfers are subject to special rules under data protection laws.
3.4.2. For EU-residents. Joonko Diversity is a US-based company. To deliver our Services to you, it will be necessary for us to share your data outside of the European Economic Area. These transfers are subject to special rules under data protection laws.
3.4.3. If this happens, we will ensure that the transfer will be compliant with data protection law and all personal data will be secure. Our standard practice is to use ‘standard data protection clauses’ which have been approved by the European Commission for such transfers. Those clauses can be accessed here.
3.5. Aggregated and Analytical Information. Joonko Diversity may use standard analytics tools such as Google Analytics, to learn more about how you and other users use our Service, and how we should improve our user experience. These tools maintain their own privacy practices in accordance with their own privacy policies to provide their service. Further information about how Google uses data when you use our Service, can be found here.
3.7. We reserve the right to disclose your Information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, or court order.
3.8. Also, please note that we may disclose general, aggregated, non-personal and non-identifiable information about our users to potential business partners, investors, or the public.
4.1. Joonko Diversity will retain your information for as long as your account is active or as needed to provide our Service. If you wish to deactivate your account, or you no longer wish that Joonko Diversity shall use or hold your information, please contact us via %supportMail%. However, please note that we may retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our Terms of Service.
4.2. Notwithstanding the aforementioned, please note that Joonko Diversity will not retain your data for longer than necessary for the purposes set out in this Policy. Different retention periods apply for different types of data, however the longest we will normally hold any Personal Information is seven (7) years.
4.3. When you send an email or other communication to %supportMail%, or any other correspondence that you have with us, we may retain those communications in order to process and respond to your requests and improve our Service.
4.4. Please DO NOT send us any communication which contains confidential or sensitive information, since we are unable to evaluate whether your content constitutes as confidential or sensitive information, or not, and we may retain or use such communication as described hereinabove, and such retention or use shall not be deemed as a breach of any of our obligations pursuant to this Policy.
5.1. Because we value your privacy, Joonko Diversity uses industry standard measures to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of data which is stored in our records. These measures include internal reviews of our data collection, storage and processing practices and standard measures. Joonko Diversity is ISO27001 compliant and certified. Joonko Diversity utilizes AWS certified data centers managed by Amazon, for cloud services. Amazon (AWS) security measures and compliance standards are covered here and here.
5.2. Nonetheless, we cannot guarantee a perfect and absolute security measure, as no method of transmission over the Internet and or electronic storage is perfectly secure or invulnerable. However, should we become aware of a security breach, we will notify any affected user, so that they can take appropriate protective steps. Such notification shall be issued by Joonko Diversity in accordance with the applicable (local) laws and regulations, as well as Joonko Diversity's internal policies.
5.3. Physical Standard. Joonko Diversity follows Amazon's security standards with respect to physical access. You can read more about it here.
6.1. First, please remember that Joonko Diversity will never ask you to confirm your account password, bank account or credit card details via email or text message. If you receive such communication asking you to provide such information, please ignore it and do not respond. You can let us know you received such communication via %supportMail%.
6.2. If you are using a computing device in a public location, we highly recommend that you always log out and close the browser after completing your session.
7.1. This Section 7 applies to citizens of the European Union which resides in the EU. Joonko Diversity adopted these provisions to comply with the EU 2016/679 Directive General Data Protection Regulation (“GDPR”), pursuant to which Joonko Diversity will be considered as a "Data Controller" with respect to our use of your Personal Information.
7.2. Legal Basis. We base our processing of personal data as a Data Controller on the following lawful grounds:
7.2.1. Joonko Diversity relies, primarily, on your consent to the terms of this Policy and the terms set forth under our Terms of Service, as a legal basis for processing any Personal Information, including, in relation to us sending you Newsletters, or communicating any other promotional material, via email or text message.
7.2.2. Joonko Diversity may collect and use your Personal Information when it is necessary for one of the legitimate uses set out in Section 3 above, which we believe are not overridden by your fundamental rights. For example, we may process your Personal Information as a preliminary necessary step prior to initiating an engagement with you as our Customer.
7.2.3. We may process your Personal Information to comply with a legal obligation and to protect our users' vital interests.
7.2.4. If, at any time, you wish to exercise your rights in accordance with the provisions provided by law (including as provided under Section 9 of this Policy) you may send us an email to via %supportMail%, and request:
22.214.171.124. to access your Personal Information together with information about how and on what basis such information is being processed. Should you desire to receive such information in a different format than the one that was provided to you, you can contact us via %supportMail% and we shall use commercially reasonable efforts to accommodate your request, if applicable;
126.96.36.199. to rectify any of the Personal Information being held when such information is inaccurate;
188.8.131.52. to delete or restrict access to Personal Information related to you in limited circumstances as described under the GDPR. Please note that if we need to delete any Personal Information related to you following your request, it can take time until we completely delete residual copies of Personal Information from our servers and backup systems.
184.108.40.206. to withdraw your consent to the processing of your Personal Information. However, please note that exercising this right will not affect the lawfulness of any previous processing activities based on consent that was lawfully obtained before its withdrawal.
220.127.116.11. the transfer of Personal Information related to you in accordance with your right to data portability.
18.104.22.168. to object to the processing of Personal Information related to you, for example in relation to direct marketing (Newsletters) or if you believe that we have no legitimate reasons to use or hold such information.
7.3. Please note that you have the right to complain to a Data Protection Authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority in the European Economic Area (EEA).
7.4. If you have any concerns about the way we process Personal Information related to you, or if you wish to withdraw your consent, for any reason, kindly let us know by sending an email to %supportMail%.
7.5. Joonko Diversity shall not charge you for requesting to exercise any of the aforementioned rights.
8.1. This Section 8 applies to you only if you reside in the State of California, United States. Joonko Diversity adopted these provisions to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Section herein.
8.2. The following categories reflect to type of Personal Information's categories which we have collected within the last twelve (12) months:
8.2.1. Identifiers and Personal information as listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), for example, first names, sure names, alias, signatures, telephone numbers, address, online Identifier, Internet Protocol address, business or private email addresses, account names and financial information.
8.2.2. Educational and professional background, and employment history.
8.2.3. Electronic network activity information, including, but not limited to, browsing history, search history and any additional information related to your interaction with our Website, location data, etc.
8.3. We have obtained such Personal Information as listed above from the following sources:
8.3.1. Directly from you, or indirectly through your activity on our Website.
8.3.2. Third parties such as our Customers, reliable service providers and professional advisers.
8.4. We use the Personal Information we collect or receive for our legitimate interests (as set out in Section 3 above), which we believe are not overridden by your fundamental rights. We may also disclose such Personal Information to third parties for our legitimate purposes as described in Section 3 above.
8.5. In the preceding twelve (12) months, Joonko Diversity has disclosed the following Personal Information for its business purposes:
8.5.2. Personal Information's categories as listed in the California Customer Records statute;
8.5.3. Your educational and professional background, and employment history;
8.5.4. Internet or another similar network activity;
8.6. In the preceding twelve (12) months, Joonko Diversity has not sold your Personal Information.
8.7. Your rights as a California Resident. As a California resident, you are entitled to the following specific rights under the CCPA, solely with respect to Personal Information related to you:
8.7.1. Request to access to specific information and data portability rights;
8.7.2. Request that we will disclose certain information to you about our use and collection of Personal Information related to you, over the past 12 months.
8.7.3. After authenticating your identity, we shall disclose to you:
22.214.171.124. The specific categories of Personal Information's components and sources we collected about you;
126.96.36.199. Our purpose for collecting and using (if applicable) your Personal Information;
188.8.131.52. The categories of personal information that we disclosed for the purpose described above, and the categories of third parties with whom we have shared any particular category of your Personal Information.
8.7.4. You have the right to request that we delete any personal information related to you. After authenticating your identity, we will delete (and direct our service providers to delete) any Personal Information related to you from our records, unless an exception applies.
8.7.5. If we disclose any of your Personal Information to a third-party, we will provide you with a list that will identify the specific category of your Personal Information which was disclosed.
8.8. You have the right not to be discriminated against by Joonko Diversity, for exercising your rights under the CCPA. If you have any concerns about the way we process Personal Information related to you, or if you wish to withdraw your consent, for any reason, kindly let us know by sending an email to %supportMail%. Please note that exercising this right will not affect the lawfulness of any previous processing activities based on consent that was lawfully obtained before its withdrawal. Also, please note that Joonko Diversity shall not charge you for requesting to exercise any of the aforementioned rights.
9.1. You have the right to ask that Joonko Diversity will provide you with a copy of any Personal Information that we keep about you.
9.2. You have the right to ask that Joonko Diversity shall update and correct any outdated or inaccurate Personal Information that we keep about you. Should you find that the Personal Information related to you is not accurate, complete, or updated, then please provide us the necessary information to correct it.
9.3. You have the right to ask that Joonko Diversity shall delete your Personal Information in limited circumstances as described under the applicable law. Please note that if we need to delete any Personal Information related to you following your request, it can take time until we completely delete residual copies of Personal Information from our servers and backup systems.
9.4. If you wish to exercise any of the aforementioned rights, please notify us by email to %supportMail% and we will use commercially reasonable efforts to accommodate your request. Joonko Diversity shall not charge you for requesting to exercise any of the aforementioned rights.
If you believe that we have not adhered to our Policy as outlined herein, please notify us by email to %supportMail%. Joonko Diversity will look into any query and make commercially reasonable efforts to resolve any existing or potential dispute. Note that when you send us a request to exercise your rights, we will need to reasonably authenticate your identity and location, and therefore we may ask you to provide us credentials to make sure that you are who you claim to be and will further ask you questions to understand the nature and scope of your request.
We reserve the right to change this Policy from time to time, so please review it frequently. If we make material changes to this Policy, and you are a registered user of the Service, we will notify you by email when we make any changes.
This Policy shall be construed in accordance with and governed for all purposes by the substantive laws of the State of New York without regard to conflicts of law provisions. You agree that any claim or dispute you may have against the Company and its affiliates, directors, officers, employees, and representatives must be resolved by a court located in New York, New York and waive any jurisdictional, venue or inconvenient forum objections to such courts.
If you have any questions about this Policy, please contact us via %supportMail%.