Effective January 6, 2020
Your Privacy Matters
Hooga’s mission is to connect the world’s professionals to allow them to be more productive and successful. Central to this mission is our commitment to be transparent about the data we collect about you, how it is used and with whom it is shared.
Our registered users (“Members”) share their professional identities, engage with their network, exchange knowledge and professional insights, post and view relevant content, learn and develop skills, and find business and career opportunities. Content and data on some of our Services is viewable to non-members (“Visitors”).
We use the term “Designated Countries” to refer to countries in the European Union (EU), European Economic Area (EEA), and Switzerland.
Data Controllers and Contracting Parties
If you are in the “Designated Countries”, Hooga Ireland Unlimited Company (“Hooga Ireland”) will be the controller of your personal data provided to, or collected by or for, or processed in connection with our Services.
If you are outside of the Designated Countries, Hooga Corporation will be the controller of your personal data provided to, or collected by or for, or processed in connection with, our Services.
1. Data We Collect
1.1 Data You Provide To Us
You provide data to create an account with us.
To create an account you need to provide data including your name, email address and/or mobile number, and a password. If you register for a premium Service, you will need to provide payment (e.g., credit card) and billing information.
You create your Hooga profile (a complete profile helps you get the most from our Services).
You don’t have to provide additional information on your profile; however, profile information helps you to get more from our Services, including helping recruiters and business opportunities find you. It’s your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add personal data to your profile that you would not want to be publicly available.
You give other data to us, such as by syncing your address book or calendar.
Posting and Uploading
We collect personal data from you when you provide, post or upload it to our Services, such as when you fill out a form, (e.g., with demographic data), respond to a survey, or submit a resume or fill out a job application on our Services. If you opt to import your address book, we receive your contacts (including contact information your service provider(s) or app automatically added to your address book when you communicated with addresses or numbers not already in your list).
If you sync your contacts or calendars with our Services, we will collect your address book and calendar meeting information to keep growing your network by suggesting connections for you and others, and by providing information about events, e.g. times, places, attendees and contacts.
You don’t have to post or upload personal data; though if you don’t, it may limit your ability to grow and engage with your network over our Services.
1.2 Data From Others
Others may post or write about you.
Content and News
You and others may post content that includes information about you (as part of articles, posts, comments, videos) on our Services. Unless you opt-out, we collect public information about you, such as professional-related news and accomplishments (e.g., patents granted, professional recognition, conference speakers, projects, etc.) and make it available as part of our Services (e.g. suggestions for your profile).
Others may sync their contacts or calendar with our Services.
Contact and Calendar Information
We receive personal data (including contact information) about you when others import or sync their contacts or calendar with our Services, associate their contacts with Member profiles, scan and upload business cards, or send messages using our Services (including invites or connection requests). If you or others opt-in to sync email accounts with our Services, we will also collect “email header” information that we can associate with Member profiles.
Customers and partners may provide data to us.
We receive personal data (e.g., your job title and work email address) about you when you use the services of our customers and partners, such as employers or prospective employers and applicant tracking systems providing us job application data.
Related Companies and Other Services
We receive data about you when you use some of the other services provided by us or our affiliates, including Microsoft. For example, you may choose to send us information about your contacts in Microsoft apps and services, such as Outlook, for improved professional networking activities on our Services.
1.3 Service Use
We log your visits and use of our Services, including mobile apps.
We log usage data when you visit or otherwise use our Services, including our sites, app and platform technology, such as when you view or click on content (e.g., learning video) or ads (on or off our sites and apps), perform a search, install or update one of our mobile apps, share articles or apply for jobs. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.
1.4 Cookies and Similar Technologies
We collect data through cookies and similar technologies.
1.5 Your Device and Location
We receive data from your devices and networks, including location data.
When you visit or leave our Services (including some plugins and our cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to and the time of your visit. We also get information about your network and device (e.g., IP address, proxy server, operating system, web browser and add-ons, device identifier and features, cookie IDs and/or ISP, or your mobile carrier). If you use our Services from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location.
If you communicate through our Services, we learn about that.
We collect information about you when you send, receive, or engage with messages in connection with our Services. For example, if you get a Hooga connection request, we track whether you have acted on it and will send you reminders.
1.7 Workplace and School Provided Information
When your organization (e.g., employer or school) buys a premium Service for you to use, they give us data about you.
Others buying our Services for your use, such as your employer or your school, provide us with personal data about you and your eligibility to use the Services that they purchase for use by their workers, students or alumni.
1.8 Sites and Services of Others
We may get data when you visit sites that include our ads, cookies or some of our plugins or when you log-in to others’ services with your Hooga account.
We receive information about your visits and interaction with services provided by others when you log-in with Hooga or visit others’ services that include some of our plugins (such as “Apply with Hooga”) or our ads, cookies or similar technologies
We are improving our Services, which means we get new data and create new ways to use data.
2. How We Use Your Data
We use your data to provide, support, personalize and develop our Services.
How we use your personal data will depend on which Services you use, how you use those Services and the choices you make in your settings. We use the data that we have about you to provide and personalize our Services, including with the help of automated systems and inferences we make, so that our Services (including ads) can be more relevant and useful to you and others.
Our Services help you connect with others, find and be found for work and business opportunities, stay informed, get training and be more productive.
We use your data to authorize access to our Services and honor your settings.
It is your choice whether to invite someone to our Services, send a connection request, or allow another Member to become your connection. When you invite someone to connect with you, your invitation will include your network and basic profile information (e.g., name, profile photo, job title, region). We will send invitation reminders to the person you invited. You can choose whether or not to share your own list of connections with your connections.
2.2 Premium Services
We sell premium Services that provide our customers and subscribers with customized functionality and tools.
We contact you and enable communications between Members. We offer settings to control what messages you receive and how often you receive some types of messages.
We will contact you through email, mobile phone, notices posted on our websites or apps, messages to your Hooga inbox, and other ways through our Services, including text messages and push notifications. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use our Services, network updates, reminders, job suggestions and promotional messages from us and our partners. Please be aware that you cannot opt out of receiving service messages from us, including security and legal notices.
We also enable communications between you and others through our Services.
We do not serve you ads.
We promote our Services to you and others.
2.6 Developing Services and Research
We develop our Services and conduct research.
We use data, including public feedback, to conduct research and development for our Services in order to provide you and others with a better, more intuitive and personalized experience, drive membership growth and engagement on our Services, and help connect professionals to each other and to economic opportunity.
We seek to create economic opportunity for Members of the global workforce and to help them be more productive and successful. We use the personal data available to us to research social, economic and workplace trends, such as jobs availability and skills needed for these jobs and policies that help bridge the gap in various industries and geographic areas. In some cases, we work with trusted third parties to perform this research, under controls that are designed to protect your privacy. We publish or allow others to publish economic insights, presented as aggregated data rather than personal data.
Polls and surveys are conducted by us and others through our Services. You are not obligated to respond to polls or surveys, and you have choices about the information you provide.
2.7 Customer Support
We use data to help you and fix problems.
We use data (which can include your communications) to investigate, respond to and resolve complaints and for Service issues (e.g., bugs).
2.8 Insights That Do Not Identify You
We use data to generate insights that do not identify you.
We use your data to produce and share insights that do not identify you. For example, we may use your data to generate statistics about our members, their profession or industry, to calculate ad impressions served or clicked on, or to publish visitor demographics for a Service or create demographic workforce insights.
2.9 Security and Investigations
We use data for security, fraud prevention and investigations.
We use your data (including your communications) for security purposes or to prevent or investigate possible fraud or other violations of our User Agreement and/or attempts to harm our Members,Visitors or others.
3. How We Share Information
3.1 Our Services
Any data that you include on your profile and any content you post or social action (e.g., likes, follows, comments, shares) you take on our Services will be seen by others, consistent with your settings.
Your profile is visible to some Members and customers of our Services, subject to your settings.
Posts, Likes, Follows, Comments, Messages
Our Services allow viewing and sharing information including through reviews and comments.
Your employer can see how you use Services they provided for your work (e.g. as a recruiter or sales agent) and related information. We will not show them your job searches or personal messages.
Depending on the enterprise Service, before you use such Service, we will ask for permission to share with your employer relevant data from your profile or use of our non-enterprise Services.
Subject to your settings, when you use workplace tools and services certain of your data may also be made available to your employer or be connected with information we receive from your employer to enable these tools and services.
3.2 Communication Archival
Regulated Members may need to store communications outside of our Service.
Some Members (or their employers) need, for legal or professional compliance, to archive their communications and social media activity, and will use services of others to provide these archival services. We enable archiving of messages by and to those Members outside of our Services. For example, a financial advisor needs to archive communications with her clients through our Services in order to maintain her professional financial advisor license.
3.3 Others’ Services
You may link your account with others’ services so that they can look up your contacts’ profiles, post your shares on such platforms, or enable you to start conversations with your connections on such platforms. Excerpts from your profile will also appear on the services of others.
Subject to your settings, other services may look up your profile. When you opt to link your account with other services, personal data will become available to them. The sharing and use of that personal data will be described in, or linked to, a consent screen when you opt to link the accounts. For example, you may link your Twitter or WeChat account to share content from our Services into these other services, or your email provider may give you the option to upload your Hooga contacts into its own service. Third-party services have their own privacy policies, and you may be giving them permission to use your data in ways we would not.
Subject to your settings, excerpts from your profile may appear on the services of others (e.g., search engine results, mail and calendar applications that show a user limited profile data of the person they are meeting or messaging, social media aggregators, talent and lead managers). “Old” profile information remains on these services until they update their data cache with changes you made to your profile.
3.4 Related Services
We share your data across our different Services and Hooga affiliated entities.
3.5 Service Providers
We may use others to help us with our Services.
We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.
3.6 Legal Disclosures
We may need to share your data when we believe it’s required by law or to help protect the rights and safety of you, us or others.
It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you; (3) investigate and defend ourselves against any third-party claims or allegations; (4) protect the security or integrity of our Services (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of Hooga, our Members, personnel or others. We attempt to notify Members about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
3.7 Change in Control or Sale
4. Your Choices & Obligations
4.1 Data Retention
We keep most of your personal data for as long as your account is open.
We generally retain your personal data as long as you keep your account open or as needed to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of our Services. Even if you only use our Services when looking for a new job every few years, we will retain your information and keep your profile open, unless you close your account. In some cases we choose to retain certain information (e.g., insights about Services use) in a depersonalized or aggregated form.
4.2 Rights to Access and Control Your Personal Data
You can access or delete your personal data. You have many choices about how your data is collected, used and shared.
For personal data that we have about you, you can:
- Delete Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).
- Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
- Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
- Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.
Visitors and Members can make these requests here. You may also contact us using the contact information below, and we will consider your request in accordance with applicable laws.
Residents in the Designated Countries and other regions may have additional rights under their laws.
4.3 Account Closure
We keep some of your data even after you close your account.
If you choose to close your Hooga account, your personal data will generally stop being visible to others on our Services within 24 hours. We generally delete closed account information within 30 days of account closure, except as noted below.
We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse. We will retain de-personalized information after your account has been closed.
Information you have shared with others will remain visible after you close your account or delete the information from your own profile or mailbox, and we do not control data that other Members have copied out of our Services. Groups content and ratings or review content associated with closed accounts will show an unknown user as the source. Your profile may continue to be displayed in the services of others (e.g., search engine results) until they refresh their cache.
5. Other Important Information
We monitor for and try to prevent security breaches.
We implement security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
5.2. Cross-Border Data Transfers
We store and use your data outside your country.
We process data both inside and outside of the United States and rely on legally-provided mechanisms to lawfully transfer data across borders. Countries where we process data may have laws which are different from, and potentially not as protective as, the laws of your own country.
5.3 Lawful Bases for Processing
We have lawful bases to collect, use and share data about you. You have choices about our use of your data.
At any time, you can withdraw consent you have provided by submitting such request through support.
We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g., to deliver the Hooga Services you have requested) and “legitimate interests.”
Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact our Data Protection Officer here.
5.4. Direct Marketing and Do Not Track Signals
Our statements regarding direct marketing and “do not track” signals.
We currently do not share personal data with third parties for their direct marketing purposes without your permission.
5.5. Contact Information
You can contact us or use other options to resolve any complaints.
If you have questions or complaints regarding this Policy, please first contact Hooga online. Residents in the Designated Countries and other regions may have more options under their laws.