A. WHICH COOKIES DO WE USE?

We select our Cookies prudently. We work with certain third parties to collect data through Cookies, but we are neither responsible nor liable for the processing of personal data by these third parties, and can therefore not guarantee that these third parties will handle your personal data in a reliable and secure manner. You should always read the privacy and Cookie policies of other websites or tools before using them. If you want to know more about Cookies in general, please refer to the website all about Cookies (https://allaboutcookies.org/).

In addition to Cookies, we also use tracking and other technologies that can be very similar. Our Site may contain small transparent image files or codes that record information about you. These are, for example, ‘scripts’, ‘web beacons’ or ‘tracking URLs’. These technologies are also referred to as Cookies.

Below we explain, among other things, which types of Cookies we use and for what purposes.

1. ESSENTIAL COOKIES

These Cookies are essential for our Site’s core activity and are automatically activated when you use the Site. These Cookies are for example used to remember your account details, your selected language settings and your previous searches, so that you can use our Site efficiently and effectively. These Cookies also include the enabling of essential security and accessibility features so that you can safely use our Site. We also save your permission settings in a Cookie to remember these for future visits.

We may use these essential Cookies without your consent. Because these Cookies are necessary for the Site to work, you cannot opt out of this category. However, the Cookies will never be used for any purpose other than ensuring the functionality of our Site.

2. ANALYTICAL COOKIES

These Cookies help improve the performance of the Site and provide a better user experience. This enables us to offer you a high quality experience by adapting our Site and content and identifying and resolving problems quickly. For example, we use performance Cookies to monitor which pages are most popular, which method of navigation between pages is the most effective, and to ascertain why some pages receive error notifications.

We also use Google Analytics. When enabled, Google will collect visitation information and associate it with Google information from accounts of signed-in users who have consented to this association for the purpose of analytics and personalization. This Google information may include the end user location, search history, YouTube history, and data from sites that partner with Google, and is used to provide us aggregated and anonymized insights into our users’ cross device behaviors. We therefore see global statistics and anonymized data.

You can read more about Google Analytics here (English), and also opt out of Google Analytics at any time here (English). Your data with Google may be accessed or deleted via My Activity. You can also refuse these Cookies by changing your browser settings. Please refer to the section “HOW CAN I CONTROL COOKIES?”. Should anything change with regard to the rules on the use of Google Analytics, we will adjust our use accordingly.

3. MARKETING AND TRACKING COOKIES

We collaborate with third parties to display advertisements on our Site or to manage advertisements on other sites. Those third parties can use technologies such as Cookies to collect information about your activities on this Site and other sites in order to offer you advertising based on your browsing activities and interests. You can refuse these First-Party and Third-Party Cookies by changing your browser settings. Please refer to the section “HOW CAN I CONTROL COOKIES?”.

For example, Google may not share your information with other advertisers. If required, they may share this information to comply with applicable laws, regulations, legal process or governmental requests.

B. SOCIAL MEDIA BUTTONS

Our Site may contain buttons, widgets, tools or content that link to services from other companies (for example, Facebook ‘like’ or ‘share’ buttons). We may collect information about your use of these functions. In addition, when you see or use these buttons, tools or content, or if you view a web page that contains these, certain information from your browser can be sent to the other company automatically. Read that company’s privacy policy for more information.

C. HOW DO I FIND OUT THE EXACT COOKIES AND RETENTION PERIODS?

Cookie check via any internet browser

• Press F12 or right-click on the page and select “inspect.” 
• Click on “Application.”
• On the left side of the “inspect” frame, click on the “Cookies” option under “Storage.”  You may need to click on the URL address under “Cookies” to display how many cookies are set, the names and retention periods. 

D. HOW CAN I CONTROL COOKIES? 

If you want to accept or decline certain categories of Cookies, you can do that via our Cookie banner on our Site. This tool is automatically loaded when you visit the Site for the first time. We give you the option of accepting or declining certain Cookies, with the exception of the essential Cookies. 

In addition, you can also change your web browser settings to decline Cookies. In that case, our Site may no longer function properly. More information on how to enable, disable and delete Cookies can be found in the instructions for your internet browser. We always recommend that you check whether your internet browser is up to date. For this purpose, you can use the help and support button of your internet browser. 

If we process personal data through our Cookies, we can also delete or anonymize your personal data on request, unless we are subject to a statutory retention obligation. For more information on your rights in respect of your personal data and how to exercise these rights, on the security measures we have taken and on any potential data transfers, please refer to our Privacy Policy.

You can submit requests for the exercise of your rights to us at support@writesea.com

E. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

The Platform, one of our websites or mobile applications may offer you the ability to register and login using your third party social media account details (like your Facebook or Twitter logins). If you choose to do this, we will receive certain profile information about you from the social media company. The profile information we receive may vary depending on the social media provider, but will often include your name, email address, friends list, profile picture as well as other information you choose to make public.

We will use the information we receive for the purposes that are described in this Policy. For more information about your rights with respect to this information, please see the section “WHAT ARE YOUR PRIVACY RIGHTS?” below.

Please note that we do not control, and are not responsible for, other uses of your personal data by the social media company. We recommend that you review their privacy policy to understand how they collect, use and share your personal data, and how you can set your privacy preferences on their sites and applications.

G. HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep your personal data for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).  

When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymize it.

H. HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal data we collect, receive, use, or store. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal data, transmission of personal data to and from the Platform is at your own risk. You should only access the Platform within a secure environment.  If you believe your account has been compromised or you suspect any type of data breach, please contact us at support@writesea.com.

I. WHAT ARE YOUR PRIVACY RIGHTS?

The rights described in this section apply to all users.  As noted above, if you reside in a particular state or country, you may have additional rights as required by applicable law.  Please see our specific notices for those regions for more information about your specific rights: 

United States Residents

Account Information

If you would at any time like to review or change the information in your account to make sure it is accurate and up-to-date, please log into your user account and update the information as needed.

If you terminate your subscription or account with us, then we will deactivate your account. However, we retain a copy of all resumes created by us or on the Platform, and some additional information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use, or comply with applicable legal requirements.  We try to minimize the data we retain to only that which is necessary for these purposes. 

Opt 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. Even if you opt out of marketing emails, we may still send you service-related emails that are necessary for the administration and use of your account.

Cookies and Tracking Technologies

Some tracking technologies help us maintain the security of our websites and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions. These tracking technologies are “necessary” because we need them for the websites to work properly. We don’t provide the option to opt-out of these tracking technologies, but you can remove these “necessary” tracking technologies by modifying your browser settings. Please note, some features of our websites may not be available to you as a result.

You may choose whether to allow or disallow other types of tracking technologies used to enable a website to remember certain information that changes how the website looks (preference cookies), to help us understand how visitors interact with our website (statistics cookies), and to track visitors across websites and which may be used to display ads that are more relevant or engaging for the individual visitor (marketing cookies). Please review our Cookie Policy for more information on how to change your preferences. 

J. DO WE MAKE UPDATES TO THIS POLICY?

We may update this Policy from time to time. The updated version will be indicated by the “Last Updated” date and the updated version will be effective as soon as it is accessible. We encourage you to review the posted Policy frequently to stay informed about how your information is being used.

K. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this Policy, you may contact us by email at support@writesea.com.

When And How Do We Request Consent?

1. Collecting and sharing your personal data

As set out in the Policy, we may collect your personal data from other sources and we may share your personal data with affiliated companies, group companies and subsidiaries, third-party services providers and marketing partners. In these cases and to the extent that the receiving party is not a processor on our behalf, we will only collect or share your personal data if we have obtained your consent. This consent is obtained for example via a consent banner or a cookie banner depending on the receiving party.

2. Marketing purposes

We will not use your electronic contact details for marketing purposes, unless you are our customer or meet another exception under the applicable telecommunications laws. As mentioned in the Policy, you can unsubscribe from our marketing email or text message list at any time by clicking on the unsubscribe link in the emails or text messages that we send (this is also called ‘OPT OUT’). If you are not our existing customer, we will ask for your consent to send direct marketing messages (this is also called ‘OPT IN’).

For the underlying processing of your personal data for marketing purposes, we may process your personal data on the basis of our legitimate interest, except when your interests or your fundamental rights and freedoms outweigh our interests. This legal basis is referred to below as ‘legitimate interest’.

3. Special categories of personal data Our Platform does not intend to collect special categories of personal data, such as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs. However, we cannot fully guarantee that we will not collect such data if you provide it to us (for example, in your resume). We will not use it for purposes other than creating your resume. 

Additional Privacy Rights

Right to Erasure. You generally have a right to erasure; however, we may not always erase your personal data because sometimes the processing is still necessary: for example, for complying with statutory obligations or for lodging, exercising or substantiating legal claims. Therefore, we will weigh your interest in having your personal data erased against the necessity of maintaining the personal data for other legitimate interests. Regarding the deactivation of your account we refer to the information mentioned in the Policy. 

Right to Restriction of Processing. Under certain circumstances, you may have us restrict the processing of your personal data. For example, if the accuracy of your personal data are contested. 

Notification of Rectification, Deletion or Restriction. Unless it is impossible or involves a disproportionate effort, we will inform the recipients of your personal data about rectification, deletion or restriction of processing. 

Right to Data Portability. Under certain circumstances, you may request us to transfer your personal data to another party.

Right of Objection. Furthermore, under certain circumstances you may object to the processing of your personal data by us (or third parties engaged by us). For example, you may object to the use of your personal data for marketing purposes. 

Right to Withdraw Consent. If we have requested your consent for data processing, you have the right to withdraw your consent at any time. The withdrawal of consent will not affect the lawfulness of the processing prior to the withdrawal.

Right of Complaint. If you believe that the processing of your personal data violates applicable laws and regulations, please contact us at support@writesea.com. 

How to exercise these rights and what we may need from you?

You can submit your request(s) for exercising these rights to us at support@writesea.com, please provide your name, telephone number, and type of request. To protect your privacy and security, we will take reasonable steps to verify your identity before responding to your request(s). Only you or someone legally authorized to act on your behalf may make a verifiable request related to your personal data. For example, if you make a request, we will ask you to confirm your name, email address, and/or other information we in our records to verify your identity. This is a security measure to ensure that personal data are not disclosed to someone who has no right to receive it.  

We will respond to your request as soon as possible, and no later than one month from receipt of your request. In doing so, we will also assess whether, and if so to what extent, we can or must comply with your request under the law. If a longer period of up to two months is needed, we will inform you within one month of receipt of the request. The submission and processing of your request is free of charge, unless your request is manifestly unfounded or excessive, in particular because of a repetitive character.

U.S. RESIDENTS NOTICE

This Notice provides more information about specific disclosures and rights we provide to residents of the U.S. in accordance with U.S. law. 

Categories of Information Collected

Category

Types of Information Collected

Purpose for Collection

A. Identifiers.

Name, mailing address, Internet Protocol (IP) address, email address.

– Account registration 

– Fulfilling customer orders for our services

– Marketing our services

– Customer service

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Name, address, telephone number, education, employment, employment history, credit card number, debit card number.

(Some personal information included in this category may overlap with other categories.)

– Account registration 

– Fulfilling customer orders for our services

– Marketing our services

– Customer service

C. Characteristics of protected classifications under California or federal law.

Age (40 years or older), race, color, national origin, citizenship, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), veteran or military status.

– Fulfilling customer orders for our services

– Analytics and improvement of our services

– Customer service

D. Commercial information.

Records of products or services purchased.

– Account registration 

– Fulfilling customer orders for our services

– Marketing our services

– Customer service

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

– Web site optimization

– Marketing our services

G. Geolocation data.

Physical location or movements.

– Web site personalization

– Marketing our services

H. Sensory data.

Audio, visual, and electronic information.

– Fulfilling customer orders for our services

I. Professional or employment-related information.

Current or past job history or performance evaluations.

– Fulfilling customer orders for our services

– Marketing our services

– Customer service

– Analytics and improvement of our services

J. Education information that is not publicly available

Education records such as education history and degrees achieved.

– Fulfilling customer orders for our services

– Marketing our services

– Customer service

– Analytics and improvement of our services

K. Inferences drawn from other personal information. 

Profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

– Marketing our services

– Analytics and improvement of our services

Categories of Information Disclosed

In the 12 months preceding the Last Updated date of this Notice, we have disclosed the following categories of personal information for a business purpose as described above:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category C: Protected characteristics information.

Category D: Commercial information.

Category F: Internet or other similar network activity.

Category G: Geolocation data.

Category H: Sensory data.

Category I: Professional or employment-related information.

Category J: Education information.

Category K: Inferences drawn from other personal information. 

Categories of Information “Sold”

We do not sell your personal data for a monetary fee; however, some U.S. privacy laws define a “sale” very broadly such that it may include our sharing of your personal data with certain third parties if we receive anything of value in return.  In that regard, we share your personal data with certain third-party marketing partners and in exchange we receive the ability to market or offer our products and services through their websites and applications.  This may be considered a “sale” under some laws.

The personal data that may be shared or sold in this context is: your name; email address; other contact information; and information obtained through cookies about, for example, your location, the website that directed you to our Platform, how you navigate our sites, and what purchases you make.  

Our use of tracking technologies may be considered a “sale” under California law; however, we do not knowingly sell the personal information of consumers under 16 years of age. The categories of personal information shared or sold in this context are: 

Category A: Identifiers.

Category D: Commercial information.

Category F: Internet or other similar network activity.

Category G: Geolocation data.

The categories of third parties with which personal information collected via tracking technologies was shared or sold are: advertisers and marketing partners, data analytics providers, and social media networks. 

Do-Not-Track Features

Many web browsers and some mobile operating systems and mobile applications include a “do-not-track” feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.  No uniform technology standard for recognizing and implementing do-not-track signals has been finalized and, as such, we do not currently respond to do not track browser signals or any other mechanism that automatically communicates your choice not to be tracked online.  We will update this Policy if that changes in the future.

Additional Privacy Rights

Right to Information.  Subject to certain limits, you may ask us to provide the following information for the 12-month period preceding your request: 

• The categories of personal information we collected about you;
• The categories of sources from which the personal information was collected;
• The business or commercial purpose for collecting the personal information;
• The categories of third parties with whom we shared the personal information;
• If we disclosed personal information for a business purpose, a list of the disclosures including the personal information categories that each category of recipient received; and 
• The specific pieces of personal information we collected about you.

We do not provide these information rights for personal information that we obtain through a business-to-business (B2B) relationship. 

Right to Delete.  You also have the right to ask us to delete any personal information that we have collected about you, subject to certain limitations. We may deny your deletion request if the information is necessary for us or our service providers to, among other things, provide a service you requested, take actions reasonably anticipated in the context of our business relationship with you, perform a contract we have with you, detect and protect against security incidents or illegal activity, comply with a legal obligation, or exercise a right provided for by law. 

Right to Opt Out of Sale.  You have the right to opt out of the sale of your personal information.  You may exercise this right by clicking on the “Do Not Sell My Personal Information – U.S.” link located at the bottom of our homepage or by submitting a request as described in the “Submission of Requests” section below.  You can opt-out third-party tracking technologies by clicking “Do Not Sell My Personal Information – U.S.” link at the bottom of our website and selecting your cookies preferences, by clicking on the “Change My Consent” link in our Cookie Policy, or by broadcasting the global privacy control signal. Please note that your use of our website may still be tracked by us and/or our service providers. 

Right to Nondiscrimination.  We will not discriminate against you if you exercise your privacy rights under any applicable privacy law, including by:

• Denying you goods or services.
• Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Providing you a different level or quality of goods or services.
• Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

We are permitted under applicable law to offer you certain financial incentives that can result in different prices, rates, or quality levels, which are related to your personal information’s value.  Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.    

Submission of Requests.  You may submit a request regarding your personal information by:

Emailing us at support@writesea.com – please provide your name, telephone number, and type of request (that is, a request for categories of information, a request for specific pieces of information, a request to delete, or a request to opt out the sale of your information).

What We May Need from You.  We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to someone who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Verifying Your Identity: To protect your privacy and security, we will take reasonable steps to verify your identity before providing your personal information and before deleting your information. Only you or someone legally authorized to act on your behalf may make a verifiable request related to your personal information. For example, if you make a request, we will ask you to confirm your name, email address, and/or other information we in our records to verify your identity, so that we can help protect your information.  

Requests from Authorized Agents:  You may designate an authorized agent to make a request for you.  If you designate an authorized agent to make a request on your behalf, we may require you to verify your identity and provide the authorized agent’s identity and contact information to us.

Responses to Requests.  We will confirm receipt of your request within 10 business days of receipt and generally will respond to your request within 45 days of receipt.  If we need more time to respond, we will inform you of the reason and we may take up to an additional 45 days to respond.  

No Fee Usually Required.  You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.