Privacy & Cookies
Privacy & Cookies Policy
Version 2.1, June 2018
This privacy and cookies policy (Policy) sets out the basis on which any information that we collect from you, or that you provide to us, will be processed by us through your use of our website.
If you have received an email invitation to complete an interview, by proceeding you confirm that you give your consent to the processing of your personal data as described in this Policy. If you do not agree with this Policy, then you should reply to the email invitation explaining that this is the case and ask the hirer to make alternative arrangements with you.
Our objective is to ensure that you are never surprised by how you personal data has been used by us. You are therefore advised to read this Policy carefully before using our website and the services provided through it.
Who we are
This website is owned and operated by StemX Limited (we, us, our). We are a limited company registered in England and Wales under company number 10335355. Our registered office is located at Nea Cottage West, Somerley, Ringwood, Hampshire BH24 3PL. We are registered with the Information Commissioner’s Office as a data controller under registration number ZA233928.
The personal data we may hold about you
Personal data means any data that identifies or can be used to identify a person. It does not include data where the identity has been removed (anonymous data).
You may provide, or we may collect or be provided with, the following personal data about you:
- your name, email address and mobile phone number by a hirer that wishes to invite you to record a video interview via our website
- a profile picture provided by you (this is optional)
- your answers to any pre-screening questions that a hirer has set in relation to a position
- recordings of your video interviews
- technical information about the device used by you to access our website or app (for example, the internet protocol (IP) address of the device and the characteristics of such device) and about your visit (for example, the pages viewed by you, how you moved about our website and how you interacted with particular pages)
We do not collect any details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.
How we may use your personal data
We will only use your personal data when the law allows us to. We will generally rely on one of three legal grounds for using your personal data:
- where we need to perform the contract we are about to enter into or have entered into with you (see our Terms & Conditions)
- where necessary for our legitimate interests or those of a third party, provided those interests do not override your fundamental rights and interests
- where we need to comply with a legal or regulatory obligation
Generally, we do not rely on consent as a legal ground for using your personal data, except in relation to sending you marketing by email or text message. You have the right to withdraw your consent to marketing at any time either by contacting us, clicking the unsubscribe link in an email or replying to a text message with the required words notified to you in each text message.
Specifically, we will use your personal data to:
- allow you to use the interactive features of our website or app
- carry out our obligations under our Terms & Conditions, including to enable you to answer pre-screening questions and submit recordings of your video interviews
- enable hirers to access your answers to pre-screening questions and recorded videos
- communicate with you regarding positions that you have applied for and any comments, enquiries or complaints made by you
- keep our website secure and ensure that content from our website is presented to you in the most effective way
Our website uses small text files, called cookies, which are automatically stored on your device when you access and use certain features of our website. As cookies are unique, they can be used to distinguish you from other users. To find out more about cookies, how to refuse them and how to change your device’s cookie settings, you should visit All About Cookies. Please note that if you refuse to accept cookies or change your device’s cookie settings, you may not be able to use all of our website’s features.
Our website uses the following types of cookies:
- Strictly necessary cookies – These are cookies that are required for the operation of our website.
- Analytical/performance cookies – These cookies allow us to recognise new and returning visitors to our website and see how they move around our website.
- Functionality cookies – These are used to recognise you when you return to our website. This enables us to personalise our content and remember any preferences set by you.
- Advertising/tracking cookies – These cookies are used to deliver adverts that are more relevant to you and your interests as well are limiting the number of times your see an advertisement and measure their effectiveness. They are placed on your device by third party advertising networks.
The specific cookies used by our website are as follows:
||This cookie is generated automatically by the CodeIgniter framework and is used to identify unique users of the website.
|Google Universal Analytics (website and online application only)
|Doubleclick (support area only)
|Fabric (app only)
||Fabric (a Google company) provides us with analytical data on how the app versions of our product are used, including number of installations, active user numbers, session length, stability and crashes. Fabric also enables us to identify key user demographics and interest through integration with sampled, aggregate and anonymised data from Twitter. We use this data to help us improve our product.
We are required to obtain your consent to all cookies except those that are strictly necessary. You will be asked to confirm your consent when you first visit our website and you can change your cookie settings for our website at any time. Alternatively, you can clear cookies after you visit our website, use a tracking blocker such as Privacy Badger or, for the analytical cookies stored by Google, install the Google Analytics opt-out extension.
Who we share your personal data with
We do not sell any personal data for commercial purposes.
We may share your data with:
- hirers in respect of positions for which you have been invited to submit a video interview via our website
- our external website developers, analytics and search engine providers that assist us in the improvement and optimisation of our website (though such information will be anonymised or pseudonymised where possible so that you cannot be identified)
- any actual or prospective buyer of our business or its assets
- other third parties as may be required by law or any order of a court or other competent authority
Where we store your personal data
Many of the service providers that we use in connection with our website and the services provided through it are based outside the European Economic Area (EEA), which means that your personal data may be transferred outside the EEA. Whenever we transfer your personal data outside the EEA, we ensure that a similar degree of protection applies to your personal data in one or more of the following ways:
- the country to which your personal data is transferred is deemed by the European Commission to provide a similar degree of protection for your personal data
- we have entered into a specific contract with our service providers that has been approved by the European Commission as providing a similar degree of protection for your personal data
- where any service provider is based in the US and they have self-certified under the EU-US Privacy Shield Framework which requires them to provide a similar degree of protection for your personal data]
Your personal data may also be processed by individuals based outside the EEA who work for us or one of the hirers using our platform.
How we keep your personal data secure
We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Policy. For example, our website uses an encrypted connection to make it difficult for unauthorised people to view information travelling between our server and your device. We also limit access to your personal data to those within our organisation that have a need to access it. They will only process your personal data on our instructions and they are required to keep your personal data confidential.
We have put in place procedures to deal with any suspected personal data breach and will notify you and the Information Commissioner’s Office or any other relevant regulator where we are legally required to do so. How long we keep your personal data for
We will only keep your personal data for as long as necessary in connection with the purposes we collected it for and to comply with any legal requirements. To determine how long we keep your personal data for, we consider the amount, nature and sensitivity of the personal data, the purposes for which it was collected and the potential risk of harm from us continuing to keep it.
We will keep personal data relating to any interviews for as long as any position that you have applied for remains open and for a period of 12 months after a hirer has archived your interview or notified us that the position has been filled or the position has otherwise been removed.
We will retain personal data relating to email marketing data until you unsubscribe or your email address has become permanently unavailable.
We will retain the analytical data collected about your use of our website for a period of 25 months before 25 May 2018 and  months on and after 25 May 2018.
You have a number of rights in relation to the personal data we hold about you:
- Access: You have the right to request access to and be provided with a copy of the personal data held about you together with certain information about the processing of such personal data to check that are holding it lawfully
- Correction: You have the right to ask us to correct any inaccurate or incomplete personal data held about you
- Deletion: You have the right to ask us to delete or remove any personal data held about you where there is no good reason for us to continue holding it or where you have exercised your right to object
- Restriction: You have the right to ask us to restrict how we hold your personal data, for example, to confirm its accuracy or our reasons for holding it
- Objection: You have the right to object to our holding of any personal data about you which is based on our legitimate interests or those of a third party based on your particular circumstances. You also have the right to object to our holding your personal data for direct marketing purposes
- Portability: You have the right to receive or request that we transfer a copy of the personal data we hold about you in an electronic format where the basis of our holding such information is your consent or the performance of a contract and the information is processed by automated means
- Complaints: You have the right to complain to the Information Commissioner’s Office (ICO) or any other EU supervisory authority in relation to how we collect and use your personal data
You will not have to pay any fee to exercise any of the above rights though we may charge a reasonable fee or refuse to comply with your request if any request is clearly unfounded or excessive. Where this is the case, we will let you know.
To protect the confidentiality of your personal data we may need to ask you to verify your identity before fulfilling any request in relation to your personal data.
Depending on the nature of your request and the personal data to which your request relates, the above rights may be exercised by you against us or against the hirer that invited you to submit a video interview using our website or app. In the first instance you should contact the hirer; however you may also contact us by email at email@example.com. Where necessary, we will liaise with the hirer regarding any request made by you.
Changes to this Policy
As we make changes to our website, we may need to update this Policy. If we make any important changes that affect your rights and interests, we will make sure we bring this to your attention and explain what this means for you.
Questions, comments and requests regarding this Policy should be emailed to firstname.lastname@example.org.