GeneralProtecting your data, privacy and personal information is very important to Thanks Anna ApS .(“Anna”, “our”, “us” or “we”).
When visiting Anna’s website at https://helloanna.ai or any of its affiliated websites (our “Website”), using our application “Anna” (our “App”) or using any of the services offered via the Website or the App (the “Services”), you acknowledge, and where applicable consent to, the practices described in this policy.
Anna builds and operates an Applicant Tracking Systems and a connected Shared Talent Pool for businesses and employees in the Hospitality sector.
Shared Talent Pool: Our Services connect you with Job Seekers, Jobs, or Employers (as applicable), giving you the ability to search for, browse, and communicate with Job Seekers, Jobs, or Employers (as applicable). However, we also use automated matching processes facilitated by algorithms within the Services which seek to match you with the most appropriate Job Seekers, Jobs, or Employers (as applicable) by reference to the data you have provided to us along with any criteria specified by the Job Seeker or Employer (as applicable). This may result in decisions being made automatically. For example, we may limit the Job Seekers that are visible to Employers based on the qualifications and expertise required for that job. In relation to this automated processing, we ensure there are safeguards in place to protect your rights and freedoms and legitimate interests and you have the right to contest any automated decisions made and obtain human intervention to alter decisions made, where possible. We may also use non-algorithmic methods to match you with Job Seekers who we believe would be suitable candidates or Employers who we believe have a suitable role for you (as applicable). These will always be recommendations and we will not commence any job applications without your involvement and/or consent.
Information we collectWe may collect and process the following data about you:
Information that you provide to us.
We will ask you to provide us with your information when you:
- fill in forms on our Website, App or correspond with us by phone, email or otherwise;
- register to use our Services;
- use the Services;
- report a problem with our Website, App or Services; or
- complete any surveys we ask you to fill in for research purposes (although you do not have to respond to these if you do not want to).
The information you may be asked to provide to us for these purposes might include your name, address, date of birth, email address, phone number, picture, video, audio, county of location, job title, work history, school attended, references, preferences, opinions, intentions, interests, likes, dislikes, life history, major events, social network, friends, connections, associations, national identification number, and/or driving license number.
Information we collect about you.
With regard to each of your visits to our Website or App we may automatically collect the following information:
- device-specific information, such as your hardware model, operating system version, unique device identifiers, Universal Device Identifier (UDID), ID for Advertisers (IDFA) and mobile network information;
- technical information about your computer, including where available, your IP address, operating system and browser type, and also latitude/longitude and related geo information of your whereabouts (i.e. city, post code), this may be collected if you opt-in to share your location or inferred from your IP address, for system administration, analytical or Service delivery purposes; and
- details of your visits to our Website, App, including your browser fingerprint, the full Uniform Resource Locators (URL) clickstream to, through and from our Website, App (including date and time), length of visits to certain pages, and page interaction information (such as scrolling, clicks, and mouse-overs).
Information we may collect about others. We may collect and process data about others that you provide us with, including (but not limited to) information that you provide by filling in forms on our Website or App, or that you provide to us by email. This information might include, but is not limited to, opinions, ratings and reviews you provide us with on other users you have interacted with, whether Job Seekers or Employers.
Information we receive from other sources. When using our Services, we will be in contact with third parties who may provide us with certain information about you in order to enable your use of the Services. This includes information from service providers such as Facebook or Google if you access our App through your Facebook or Google+ account.
How we use your information and justification of useUse of personal information under EU data protection laws must be justified under one of a number of legal “grounds” and we are required to set out the ground in respect of each use of your personal data in this policy. These are the principal grounds that justify our use of your information:
- Consent: where you have consented to our use of your information (you are providing explicit, informed, freely given consent, in relation to any such use and may withdraw your consent in the circumstances detailed below by notifying us);
- Contract performance: where your information is necessary to enter into or perform our contract with you;
- Legal obligation: where we need to use your information to comply with our legal obligations;
- Legitimate interests: where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights; and
- Legal claims: where your information is necessary for us to defend, prosecute or make a claim against you or a third party
We use information held about you (and information about others that you have provided us with) in the following ways:
Applicable to job seekers
Anna and each Employer acts as a data controller in their own right, which means both independently determine the purpose and means of processing the personal data of the relevant Job Seeker. Where an Employer receives personal data relating to a Job Seeker it will be responsible for how it processes personal data.
|Types of Information Collected||Uses of that Information||Use Justification|
|Full name, e-mail address, phone number, password||To enable you to create an Anna account (user ID) and use our services||Contract performance|
|Full name, email address, password, phone number, work history, academic and training history, language proficiencies, any pictures or videos supplied by you, your availability to commence work and what type of employment you are looking for (i.e. full time, part time, freelance, etc.), visa status, job preferences, hobbies, personal preferences and goals, and social connections, (“Job Seeker Profile Data”)||To provide you with access to the Services including creating a profile on your behalf that is visible to Employers.||Contract performance|
|Job Seeker Profile Data, In-App chat messages, work and/or interview references, previous jobs and/or applications undertaken as part of the Services||To provide Employers with a rating for you based on your level of engagement with the Services and performance as a Job Seeker (e.g. application performance, rate of responses, and quickness to respond)||Legitimate interests|
|Job Seeker Profile Data, your previous jobs and recruitment history within Anna’s system.|
Job Seeker Profile Data may be shared with users for this.
|To facilitate the finding of job opportunities for you and to provide you with tailored job opportunities we believe you may be interested in.||Legitimate interests|
|Job Seeker Profile Data||To provide your personal data to third parties in order to facilitate your application to external job opportunities outside of Anna’s network. This will only occur when you have commenced a job application on the Website or App and the particular application requires that you or your details are transferred off our network to complete the application. Such external jobs will be explicitly labeled or you will be specifically advised when your data will be sent off-site.||Consent|
Applicable to employers
Where an Employer receives personal data relating to a Job Seeker pursuant to using our Services, the Employer will be responsible for how it processes such personal data and the Employer will be a data controller in its own right and must comply with all applicable data protection legislation.
|Types of Information Collected||Uses of that Information||Use Justification|
|Full name, company, company location, phone number, social connections, business identification numbers, job title||To provide you with access to the Services including the onboarding process and profile management, job seeker discovering: allowing you to browse applicants’ and potential job seekers profiles, and applicants management allowing you to manage job applicants and review their profiles.||Contract performance|
|Full name, company signature||To manage invoices for customers and service providers/suppliers.||Contract performance|
|Location, interview date/time/length preferences, trial date/time/length preferences, names of decision makers within company||To communicate and schedule interview and trial dates and times with candidates.||Contract performance|
|Employment contract data||To coordinate the employment contract signing between your company and the applicants||Contract performance|
|Recruitment funnel data (i.e. which applicant makes it how far in the recruitment process)||To provide you with more tailed applicant suggestion based on your hiring preferences||Legitimate interest|
On what legal basis is this privacy statement based on?
Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain Consent for a specific processing purpose. If the processing of Personal Data is necessary for the performance of a contract to which the Data Subject is party, the processing is based on Article 6(1) lit. b GDPR. If the processing of Personal Data is necessary to pursue the Data Controller’s legitimate business interests of answering an enquiry submitted by the Data Subject or providing information to the Data Subject, the processing is based on Article 6(1) lit. f GDPR.
Disclosure of Data
We may disclose your personal information to our service providers and business partners, including Google, Firebase, Intercom, Typeform, Twilio, Sendgrid, Cronofy, our network of Employers and third party Employers (with your consent) (to assist us in performing any contract we enter into with them or you, including providing the Website, App and the Services it enables), analytics providers, including Google, and Facebook.
The personal data can also be passed on to subcontractors providing services on behalf of Thanks Anna ApS or acting under our instructions and authority, government bodies and in any and all cases where we are compelled to do so. In this regard and with the aim of protecting your privacy, we follow strict criteria for the selection of our service providers in order to comply with our data protection obligations. In this regard, we undertake to sign with them the corresponding Data Processing Agreement - in compliance with the requirements established by GDPR. This agreement will impose, among others, the following obligations: to apply appropriate technical and organisational measures; to process personal data for the agreed purposes, attending only to Anna's instructions and to delete or return the data once the provision of services has ended. All obligations that we impose on our service providers who access your personal data are aimed at ensuring maximum privacy.
We also inform you that some of the third party service providers mentioned may be located outside the European Union. More precisely, we have service providers located in the USA. In these cases, it is worth noting that these providers are adhered to the "Privacy Shield" between the European Union and the USA, thus providing an adequate level of protection for personal data.
In addition, we may also disclose your personal information to third parties in the following circumstances:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or in order to enforce or apply our Website Terms and Conditions and other agreements, but we will endeavour to minimise such disclosure to only that reasonably necessary and, where possible, to provide you with notice of such disclosure; and/or
- to protect the rights, property, or safety of Thanks Anna ApS, the Website, our users and any third party we interact with to provide the Website.
- Fraud Prevention and other checks. We and other organisations may also access and use your personal information to conduct credit checks and checks to prevent fraud. If false or accurate information is provided and fraud is identified or suspected, details may be passed to fraud prevention agencies.
Third Party ServicesOur Services may contain links to third party services. If you click on a link to access any of those third-party services, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal information. Please check these policies before you submit any personal information to such third-party websites.
In the future, you will also be able to log on to the App via an account with various social media networks, such as Facebook. In that case, please note that we can gain access to certain data in your social media account, such as your name, profile photograph and contacts. Furthermore, in that case, your social media username and profile photograph may become automatically visible on the App and information may be published on your social media page.
SecurityNo data transmission over the internet can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal information in accordance with data protection legislative requirements.
Sensitive information between your browser and our Website and App is transferred in encrypted form using secure socket layer (“SSL”) or equivalent cryptographic protocols using certificates issued by a trusted third-party authority.
All information you provide to us is stored on our or our subcontractors’ secure servers and accessed and used subject to our security policies and standards.
We use hosted servers (such as Google Cloud Computing Services) in the course of our business, including for the permission of marketing and sales activity. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential, ensuring it is secure and strong, and for complying with any other security procedures that we notify you of. We ask you not to share your password with anyone.
How long we retain your personal dataWe will hold all the data for so long as we have an obligation to the Customer to provide the Services, and thereafter until such time as we delete the Customer’s account in accordance with our Customer Terms and Conditions.
Your personal information will be deleted on one of the following occurrences:
- deletion of your personal information by you (or by another person engaged by the Customer); or
- receipt of a written request by you (or another person engaged by the Customer) to us.
Your RightsUnder the General Data Protection Regulation (EU) 2017/676, you have various rights in relation to your personal data. All of these rights can be exercised by contacting us firstname.lastname@example.org.
In certain circumstances, you have the following rights in relation to your personal data:
|Right of Access||You have the right to obtain from us information as to whether your personal data is being processed, and, where that is the case, access to such personal data.|
|Right to Rectification||We will use reasonable endeavours to ensure that your personal information is accurate. In order to assist us with this, you should notify us of any changes to the personal information that you have provided to us by sending us a request to rectify your personal data where you believe the personal data we have is inaccurate or incomplete. You may also change most of your personal details within our app directly.|
|Right to erasure / ‘Right to be forgotten’||Asking us to delete all of your personal data will result in Anna deleting your personal data without undue delay (unless there is a legitimate and legal reason why Anna is unable to delete certain of your personal data, in which case we will inform you of this in writing).|
|Right to restriction of processing||You have the right to ask us to stop processing your personal data at any time.|
|Right to data portability||You have the right to request that Anna provides you with a copy of all of your personal data and to transmit your personal data to another data controller in a structured, commonly used and machine-readable format, where it is technically feasible for us to do so and the processing is based on consent or contractual performance.|
|Right to complain||You have the right to lodge a complaint to a supervisory authority such as the Danish Data Protection Agency (https://www.datatilsynet.dk/english/). Although we encourage our customers to engage with us in the event they have any concerns or complaints.|
Anna will not ordinarily charge you in respect of any requests we receive to exercise any of your rights detailed above; however, if you make excessive, repetitive or manifestly unfounded requests, we may charge you an administration fee in order to process such requests or refuse to act on such requests. Where we are required to provide a copy of the personal data undergoing processing this will be free of charge; however, any further copies requested may be subject to reasonable fees based on administrative costs. Asking us to stop processing your personal data or deleting your personal data will likely mean that you are no longer able to use Anna’s Services, or at least those aspects of the Services which require the processing of the types of personal data you have asked us to delete, which may result in you no longer being able to use the Services. Where you request Anna to rectify or erase your personal data or restrict any processing of such personal data, Anna may notify third parties to whom such personal data has been disclosed of such request. However, such third party may have the right to retain and continue to process such personal data in its own right.
For the purpose of the GDPR, the data controller is Anna ApS, registered under:
Corporate name: Thanks Anna ApS
Tax number: 40687963
Address: Strandvejen 75, 1 TV, 2100 Copenhagen, Denmark