PRIVACY POLICY
Last amended on: 6th Feb 2023
1. INTRODUCTION
We, at Kramer Poole, (collectively “Kramer Poole”, “Firm", “we”, “us”, “our”), operating website URL “www.kramerpoole.com” (“Website”) value your association with us and are committed to protecting your data from any unauthorized use or misuse. We have curated this Privacy Policy ("Policy”) to illustrate how Kramer Poole collects, uses, or share the information that you may provide to us in good faith and trust. In addition to this, this Policy also lays down how we protect, secure, and encrypt your data from any unauthorized use or dissemination.
2. ABOUT THE PRIVACY POLICY
This Policy is curated to protect and safeguard the Data that you may share with Kramer Poole or Kramer Poole may use and store and further lays down the parameters and approach that we use in respect of the collection, storage, usage, disclosure, and safeguarding your personally identifiable or other Data (defined later) as collected from you for the purposes and usages as encapsulated under this Policy in accordance with the applicable laws for the time being in force.
This Policy covers in its ambit all the Data which includes but is not only limited to sensitive personal data, personally identifiable data, and details in respect of your medical records, banking, educational qualifications, etc., or such other details (“Data”) that you as a User (defined later) may provide to us, whether directly or indirectly.
3. DEFINITIONS
For the purpose of this Policy, the terms mentioned below shall have the meaning as specifically assigned to them:
3.1. “Applicable Law(s)” shall mean and apply to the terms of any applicable laws, common law, orders, ordinances, codes, licenses, permits, tariffs, and approvals in regard to this Policy for the time being in force in France.
3.2. “Cookie(s)” is a small piece of data or software code that automatically records and saves the data and the pattern on your hard drive or in your device's web browser. Cookies help us to provide better Services on or through our Website and enhance your use and browsing experience by helping you remember your activities, information, and preferences over time.
3.3. “Candidates” shall mean and include the individuals who wish to avail of the Services of Kramer Poole in order to find the desirous job in the industry.
3.4. “Data” shall refer to any information like name, address, email address, correspondence information, details in respect of web browser, version, browsing history and such other details, that you may provide or share with the Kramer Poole at any point in time. For the purpose of this Policy, the term Data connotes and relates to personally identifiable data and non-personal data.
3.5. “Non–Personal Data” means such data that is of impersonal nature and is incapable of identifying and ascertaining any individual or any personal or specific other information related to that individual like the information in relation to the device, Internet Protocol (IP) address, browser type, version of browser, URLs of referring/exit pages, operating system, pages visited, geographical location, device ID, amongst others.
3.6. “Personal Information” shall mean the personal details of the User like name, address, mobile number, email address, and such other details which are of idiosyncratic nature, shared by the User with Kramer Poole or any of its affiliates.
3.7. “Personally Identifiable Information” means any information or detail in regards to an individual or entity or a natural legal person that can lead to identification and ascertainment of such individual, or entity either directly or indirectly, when consolidated or joined with the other information about such entity or individual that is available or likely to be available.
3.8. "Recruiters” shall mean and include the entities or organizations who avail the Services of Kramer Poole in order to recruit the candidate against the relevant job openings.
3.9. “Sensitive Personal Information” shall mean and include the details like license numbers, passwords, financial information like bank details, card details, pins, medical records, gender, sexual orientations, and any other details of like nature.
3.10. “Services” shall mean the services offered by the Website like recruitment and consultancy services in respect of industries like logistics, supply chain, automation, technology, and any other industry in accordance with the need and requirements of the Candidates and Recruiting Companies.
3.11. User(s)” shall mean any individual or entity that uses or browses through the Website of Kramer Poole for the purpose of seeking and availing Services listed on the Website. The term user is inclusive of Candidates and Recruiters, both.
4. INTERPRETATION
4.1. For the purpose of interpretation in this Policy,
4.1.1. the terms “Candidate”, “Recruiter”, “User”, "you", "your", and "yours" shall refer to any natural person or legal person who is either browsing our Website or availing our Services, unless the context denotes otherwise;
4.1.2. the words denoting the singular shall include the plural and vice versa for the purposes of interpretation in this Policy unless the context denotes otherwise;
4.1.3. the words denoting any gender include all genders for the purposes of interpretation in this Policy unless the context denotes otherwise; and
4.1.4. the headings in this Policy are inserted for convenience only.
5. COMPLIANCE WITH APPLICABLE LAWS
This Policy is framed and enforced in accordance with the provisions and clauses of the General Data Protection Regulation. Commencing from May 25, 2018, this Policy is in drafted and made in compliance with the General Data Protection Regulation (GDPR), and any parts that contradict the GDPR will be declared invalid and unenforceable.
Please refrain from using or gaining access to the Website if You disagree with the terms and conditions of this Policy, particularly those pertaining to the way in which Your information is collected, used, or stored. In case You have any queries or concerns in respect of this Policy, You should immediately contact Our customer support at support@kramerpoole.com. This Policy will be amended by Kramer Poole on a timely basis, and you are urged and advised to read the Policy each time, before using or interacting with the Website.
6. APPLICABILITY
All individuals and natural legal persons who visits or browses through the Website are subject to this Policy along with all the amendments made to it from time to time. The Policy is applicable in the event any individual or natural legal person is either availing of the Services of Kramer Poole or for the purpose of gaining information about our Services.
7. WHY DO WE COLLECT DATA?
For the purpose of furnishing and providing you with our Services and a seamless experience while browsing through the Website, we may collect and retain your certain information. We also understand and acknowledge our responsibility towards protecting your Data and information that you may share with us. we may collect your Data for the following purposes:-
7.1. to provide and offer you the Services illustrated on our Website;
7.2. to maintain internal records towards the sales and delivery of the Services;
7.3. to analyze and enhance the Services illustrated on the Website;
7.4. to cater to the Services required by you and to offer additional services of like nature;
7.5. to corroborate the allegations, queries, and claims and to resolve any disputes that may arise concerning the usage of the Website by you with other Users or with us;
7.6. to keep you posted and informed about our newsletters, brochures, additional services, or any other advertising material developed or generated by us;
7.7. to adhere and abide by all the legal and statutory requirements as per the applicable laws for the time being in force;
7.8. to keep you posted about the amendments and/or modifications or alterations, that we may introduce in our applicable policies like terms and conditions, refund and cancellation, disclaimer, or any other policy that we may introduce in the future at any point in time;
7.9. to send you a notification, in the event, there is any malware attack, downtime, virus attack, hacking of the Website; and
7.10. to undertake such other purposes and activities as may be required in accordance with the provisions of the Applicable Laws.
Notwithstanding anything illustrated in this Policy, we will neither disseminate, sell, trade, or license your Data or any information with any third-Party at any point in time. However, we will share the Data shared by you, if the same is required to be undertaken by way of any order, notice, or ordinance, of any governmental body or authority and shall send a notification to that effect to you.
8. WHAT DO WE COLLECT?
8.1. The Data and information that we will collect for the purposes mentioned in Clause 7 of this Policy are inclusive of Non-Personal Data, Sensitive Personal Information, and any other details related, associated, or shared by you like your movement, search history on the Website, access time, server details, access duration, etc.
8.2. To be more precise, we may collect the following Data:
8.2.1. contact Data (such as Your email address and phone number);
8.2.2. Data related to the Services used by You through Our Website;
8.2.3. demographic Data (such as Your gender, Your date of birth, and Your pin code);
8.2.4. other Data that you voluntarily choose to provide to us or may be required by the Recruiter or Candidate (such as your Personal Information which may be related to the Services listed on the Website and/or shared by you with us through emails or letters, your work details, salary expectations, work experience, details in Curriculum Vitae, etc.,);
8.2.5. passwords;
8.2.6. sexual orientation; and
8.2.7. information received by body corporate under lawful contract or otherwise.
8.3. Data not considered to be Personal Information or Sensitive Personal Information or that information which is easily available and accessible in the public domain.
8.4. Tracking Data, which is inclusive of but not limited to Your device's IP address and device ID when it's online. This Data may also include the URL from which you are redirected, or the URL You may be redirected to, or the browser information for Your computer or device, and other Data.
9. HOW DO WE COLLECT THE DATA?
9.1. We collect your Data keeping in mind the purpose and usage of the Data. We, do not collect, use, and store any Data without obtaining your prior permission and only collect, use, and store the Data, that has been explicitly provided by you or by way of your browsing of the Website, feedback forms, surveys, questionnaires, or any other form filled by you either on the Website or shared via emails. Notwithstanding anything contained in this Policy, the Data collected by us is for specific purposes only, and the same will at all times be collected in a stipulated manner only.
9.2. We respect and value your privacy and therefore we collect the Data only after taking and obtaining your due approval. By way of your continued browsing of the Website and availing the Services of Kramer Poole, you provide your consent to the Firm to collect, use and store the Data for carrying out the permissible works only.
9.3. For the purpose of collection or storage of your Data, we may engage or hire or recruit any third-party associates or affiliates to collect, store and protect the Data furnished by you through Our Website or via any other mode with utmost diligence and care.
10. COOKIES AND ANALYTICAL THIRD-PARTY SOFTWARE
10.1. We may also install Cookies on your hard drives which are used for analyzing and tracking your movement on Our Website. The types of Cookies that we use are of different types and can be persistent cookies, session cookies, functional cookies, targeting cookies, etc. If you provide your acceptance to the usage of the Cookies, we may place a small text file on your computer's hard drive or in your browser.
10.2. You consent to our usage of Cookies by continuing to browse the Website. You may configure and align your browser in such a manner, to keep you informed and updated as and when the Website access or set Cookies, or to reject all or certain browser Cookies. Take note that certain features of Our Website may stop working or become unavailable or restrict you to view, in the event you disable or reject the Cookies. Here is a list of the many kinds of Cookies we employ while rendering the Services to You on the Website:
10.2.1. Analytical/Performance Cookies: These types of Cookies enable us to identify and tally the number of visitors/Users as well as track their movements while using Our Website. This helps us in enhancing the functionality of Our Website, for instance by ensuring that Users can quickly locate what they're looking for.
10.2.2. Functionality Cookies: When you return back to Our Website through the browsing history we may recognize your previous activities and these are used to identify your choices and preferences. Because of this, we may tailor our content to be presented to you, address you by your name, and/or keep track of your preferences (for example, your choice of language or region).
10.2.3. Targeting cookies. These types of Cookies keep track of your usage of Our Website, including the webpages you visited and the links you clicked. By utilising this Data, we can better tailor our Website and amend it to suit your preferences. In order to achieve this, we could also disclose this Data to other third parties.
10.3. You understand and acknowledge that we do not have any control over the use of Cookies by the third parties, such as advertising networks and companies that offer external services like online traffic analysis tools. By turning on the browser setting that enables you to deny the setting of all or specific Cookies, you can prevent the Data collected by such Cookies. However, it is reiterated again that you might not be able to access all or some Services that we may offer through Our Website in the event you modify your browser’s setting to block all the Cookies (including necessary cookies).
10.4. In order to better understand how you use our material and identify areas for improvement, we utilize Squarespace Analytics services on the Website. These Cookies may track every User of the Website and gather anonymous information about their origin, the pages they visit, and how long they stay there. The Analytics stores the information in order to generate reports. These Cookies don't keep any private or business information.
10.5. The Analytics may receive and keep the Data collected by the source of Cookies regarding how the Website is used, including IP addresses, on its servers in the United States. This information may be used by the Analytics to assess how an User uses the Website, to compile reports on Website activity for us, and to perform other functions related to the Website activity and internet usage. When obliged to do so by law or when such third parties handle the Data on Analytics behalf, Analytics may also disclose this Data to third parties.
10.6. By using this Website, all users agree that the Analytics may treat their Data as described and set forth in the objectives as abovementioned. Additional details regarding Analytics and a copy of their Privacy Policy pages are available on their Websites.
11. DATA SECURITY AND HOW WE RETAIN THE DATA?
11.1. Security of Data:
11.1.1. We are very careful and cautious about the security of the Data that you provide to us with utmost good faith and in lieu of that, we use and take all the reasonable and valid measures to secure and protect the Data available at our server from any unauthorized use, dissemination, or malicious attacks and hacking. However, we expressly do not guarantee or represent any absolute protection and security of the Data from any unauthorized use or misuse.
11.1.2. You completely understand and acknowledge that Data storage and transmission is subject to cyber-attacks like viruses, hacking, malware attack, trojan attacks, etc., and the protection of the same in entirety cannot be guaranteed in entirety. Despite using our best efforts and endeavors, you understand and acknowledge that:
a. all the thing’s governing cyberspace is very wide and the same suffer through certain limitations, and such limitations are beyond the control of the Firm; and
b. the security, integrity, and privacy of the Data can be viewed, breached, or altered by any third parties at the time of transmission of your Data for security purposes or to provide you the desired Services.
11.1.3. We further try to mitigate the risk of Data breach by having internal as well as external agreements, arrangements, and/or policies with the workers/employees, third-party associates/ affiliates.
11.2. Disclosure of Data:
11.2.1. Though we strongly stand by and abide by the non-dissemination of any information or Data of our Users, we, at times, may have to disclose the Data under specific circumstances to the following categories of recipients in order to enable them to provide the Services as requested by you as illustrated on our Website or for other legitimate Services requested by you for the purpose of transacting business:
a. to our group companies, affiliates, recruiters, recruiting agencies, and subsidiaries, as the case may be to offer the Services requested by you;
b. to our associates, third-party vendors, service providers, and partners to enable them to connect and get in touch with you for rendering the Services requested by you;
c. to any governmental body or statutory authority, agency, court, or tribunal where it is ordered to share the information or where for the purpose of compliance with any law or regulations, such disclosure of Data and information is necessary;
d. to the legal advisors, statutory auditors, accountants, or such other person with similar roles and responsibility for obtaining necessary and legitimate advisory services; and
e. to our employees and personnel to carry out their roles and responsibilities and business operations on behalf of Kramer Poole.
11.2.2. All the parties with whom we will share your Data and information are obligated and under compulsion to use all the reasonable and necessary steps to protect and secure your Data and shall at all times use and process your information in accordance with our instructions.
11.3. Retention of Data:
11.3.1. You understand and acknowledge that we will retain the Data shared by you for undertaking the business-related operations i.e., in case you are a recruiter, then to provide you the right candidates against your requirements and in case you are a candidate, the best available openings available in the industry based on your qualification and skills for a period of 2 years , however, we will only retain your Data as long as it is required in accordance with the legal and statutory requirements.
11.3.2. Kramer Poole will delete your Data from the servers after completion of the purpose or fulfillment of the statutory requirements.
11.3.3. We may retain your Data for a longer period of time i.e., over and above the term mentioned in Clause 11.3.1. of this Policy as well and the period for which we will retain your Data is based upon certain factors like the nature of Data, the sensitivity of Data, loss or threat associated with unauthorized use of Data, reason, and purpose for which we need your Data, etc.
12. DATA PROTECTION RIGHTS OF USER
12.1. Right to access: You have the right to request access to the Data that we have access to and stored with us. In order to provide you a copy of such Data, Kramer Poole might charge a small amount of fee from you.
12.2. Right to Rectification: In the event, the Data that is shared by you suffers any discrepancy, or inaccuracy, you have the right to request for the rectification of the records and we can make amendments in the Data based on your inputs.
12.3. Right to erase: In the event you want us to remove the information available with us, we will erase and remove all the Data that is readily available with us.
12.4. Right to restrict or object to processing: You have the right to restrict or raise any objection in respect the processing of Data that you may share with us at any point in time and on the basis of your correspondence, the Data will not be further processed.
12.5. Right to data portability: With this right you can raise requisition of your Data or credentials to yourselves or any third person/ entity, or organization.
12.6. In order to access any of your above-mentioned right, you may write a mail to support@kramerpoole.com.
13. THIRD-PARTY WEBSITE LINKS
13.1. For providing you with our Services offered via Website, we offer and provide you with third-party links on the Website.
13.2. You understand and acknowledge that such third-party affiliates are independent of Kramer Poole and their activities and operation are beyond our control and we hold no responsibility or liability towards any act, omission, commission, or negligence on the part of such third-party affiliates and their links provided on Our Website.
13.3. You are aware and acknowledge that you are using such Third-party Links at your own risk and in no event Kramer Poole will be held liable for any material breach or unauthorized usage of Data.
14. DISCLAIMER
14.1. You understand and acknowledge that we will always seek your permission before collecting your Data and such collected Data will at all times be used for authorized and legitimate business purposes only as mentioned in this Policy. We use your Data for our internal business activities, management, and compliance only.
14.2. Any storage and retention of the Data are in compliance with the Applicable Laws and the same is not used for undertaking any unauthorized or illegitimate purposes.
15. DISCLAIMER OF LIABILITY
Except as otherwise expressly stated in this Policy, Kramer Poole disclaims from any liability in respect of the correctness, completeness, and accuracy of information provided by the third-party links and at no point in time shall be held liable for any material or immaterial breach of information or unauthorized usages of the Data that you may provide over such Third-party Links.
16. LIMITATION OF LIABILITY
You understand and acknowledge that Data collection, retention, storage, and transmission are prone to cyber-attacks and threats. The term cyber-attacks include hacking, malware attack, trojan attacks, leakage, unlawful dissemination, disclosure, etc. Despite using our best efforts, these attacks may happen and take place and you understand and acknowledge that Kramer Poole will never be held responsible for such activities and acts. The Firm will at all times intimate and bring to your notice as soon as possible in the event occurrence of any of the cyber-attacks by issuing an email on your registered email id.
17. WITHDRAWL OF CONSENT
17.1. This Policy is applicable to you because of your usage and browsing of the Website.
17.2. If at any point in time, you wish to withdraw your consent, you can write to us at support@kramerpoole.com. You shall also immediately refrain yourselves from using our Website and shall not surf or browse through the Website in case you do not agree with any of the terms and conditions of this Policy or any other policy of the Firm.
17.3. In addition to accessing, you can also opt out of the promotional and marketing information that is provided to you by us on your registered email address or via messages on your registered mobile number. You can opt out of such Services by writing to us an email at support@kramerpoole.com.
17.4. Notwithstanding anything written and outlined in this Policy, we retain the right to hold your Data for meeting the compliance work and statutory requirements in accordance with the Applicable Laws for the time being in force.
18. REMOVAL OF ACCOUNT AND ACCESS TO INFORMATION
18.1. We, reserve the right in our sole discretion to remove or suspend your access to our Website in the event, we find any acts or activities in violation of this Policy or any other policies applicable to you. The specific circumstances are illustrated as under:
18.1.1. in case you provide any wrong, incorrect, or materially altered information or Data; and/or
18.1.2. any act or actions which is strictly against this Policy of the Firm or any other policy or agreement which the Firm may enter with you for the purpose of rendering the Services.
19. AMENDMENTS
You understand and acknowledge that we reserve the sole right, in our own discretion to amend and alter this Policy whenever there is any change in the Applicable Laws or the policies, procedures, and norms of the Firm. The amended Policy will be uploaded on the Website from time to time and it is your duty to read the Policy from time to time for better understanding and stay updated with the amended policy. Your continued usage of the Website shall be deemed as acceptance of the amended policy of the Firm.
20. GOVERNING LAW AND DISPUTE RESOLUTION
In case any dispute(s), disagreement(s), or conflicts arises between the parties, in relation to the interpretation, validity, implementation, or alleged breach of any provision(s) or clauses(s) of this Policy, the same shall be dealt as per the laws of French Republic under the jurisdiction of the appropriate courts situated in Paris, France.
21. GRIEVANCES AND COMMUNICATION
We appreciate your commitment to us and value your input to enable us to provide the best services and seamless experience while using our Website. We welcome and honor your inputs and in case you have any suggestions in respect of the Website, feel free to write to us support@kramerpoole.com, we surely will look into your suggestion and consider to implement the same in the best interest of business.
In case you have any queries or concerns or grievances in relation to this Policy or with the information which we collect, please feel free to reach out to us at support@kramerpoole.com.
In the event your grievances or disputes in respect of this Policy is not resolved by the representatives of Kramer Poole, you can raise your concerns and queries with CNIL at Contact us | CNIL.