Privacy

Privacy policy

This privacy policy should be read alongside, and in addition to, our terms of use.

Definitions

Running Start Ltd trading as Cruiton (”Cruiton,” “we,” or “us”) is a website (the “App”) that allows you to obtain employee and personal character references from job candidates. We offer this App via cruitonapp.com (our “Website”) and any other website or application owned, operated or controlled by us. These will be referred to as the “Service”.

As a customer of the Service you’re a “User” (“you”).

"Data"

Collectively all information submitted to us via the Service. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws.

"Cookies"

Small text files placed on your computer by this Service when you visit certain parts of the Service and/or when you use certain features of the Service. Details of the cookies used by this Service are set out in the cookie clause below.

"Data Protection Laws"

Any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long asthe GDPR is effective in the UK.

"GDPR"

The General Data Protection Regulation (EU) 2016/679.

"UK and EU Cookie Law"

The Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011.

General

Scope of this privacy policy

This privacy policy applies only to the actions of Cruiton and Users with respect to this Service. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

For purposes of the applicable Data Protection Laws, Cruiton is the "data controller". This means that Cruiton determines the purposes for which, and the manner in which, your Data is processed.

Data collected

We may collect the following Data, which includes personal Data, from you:

  • Name
  • Date of birth
  • Job title
  • Profession
  • Employment history
  • Contact information such as email address, street address, telephone number and website
  • Relationship to job candidate such as "manager", "colleague", "friend"
  • IP address (automatically collected)
  • Web browser type and version (automatically collected)
  • Operating system (automatically collected)
  • A list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected)

How we collect Data

We collect Data in the following ways:

  • Data is given to us by you
  • Data is collected automatically

Data that is given to us by you

We will collect your Data in a number of ways, for example:

  • When you register with us and set up an account to receive our Service
  • When you use our Service. For example, when you (a job candidate) submit your previous employment details to us, or you (a referee) submit employee or personal character references to us
  • When you elect to receive marketing communications from us
  • When you contact us through the Website, by telephone, post, email, or through any other means

Data that is collected automatically

To the extent that you access the Website, we will collect your Data automatically, for example:

  • We automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
  • We will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the cookie section below

Our use of Data

Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:

  • Internal record keeping
  • Improvement of our Service
  • Transmission by email of marketing materials that may be of interest to you

We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights" below).

For the delivery of direct marketing to you via e-mail, we'll need your consent, whether via an opt-in or soft-opt-in.

Soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about our Service, and we are marketing similar products/services). Under "soft opt-in" consent, we will take your consent as given unless you opt-out.

For other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we'll provide.

If you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed "Your rights" below.

Who we share Data with

We may share your Data with the following groups of people for the following reasons:

  • Our employees, agents and/or professional advisors, to enable us to assist our users if they experience any issues with our service
  • The company or organisation who requested your job references

Keeping Data secure

We will use technical and organisational measures to safeguard your Data, for example:

  • Access to your account is controlled by a password and a username that is unique to you
  • We store your Data on secure servers

Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via hello@cruitonapp.com.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Data retention

Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.

Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your rights

You have the following rights in relation to your Data:

  • Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why
  • Right to correct - the right to have your Data rectified if it is inaccurate or incomplete
  • Right to erase - the right to request that we delete or remove your Data from our systems
  • Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it
  • Right to data portability - the right to request that we move, copy or transfer your Data
  • Right to object - the right to object to our use of your Data including where we use it for our legitimate interests

To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via hello@cruitonapp.com.

If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner's Office (ICO). The ICO's contact details can be found on their website at ico.org.uk.

It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

Changes of business ownership and control

Cruiton may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Cruiton. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.

We may also disclose Data to a prospective purchaser of our business or any part of it.

In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Cookies

Please see our cookie statement.

The final bit

You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

We reserve the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.

Updated August 2020