Privacy Policy

Updated on 22/06/2022

  1. Introduction

This Privacy Policy is intended to inform you about what personal data we collect about you when you visit the tophirehub.com website (“Website“) or use the Top Hire Hub platform intended for cooperation between employers and recruitment agencies in the recruitment/engagement of suitable candidates for employment/engagement, which is available on the Website and/or a special mobile application (“Platform“), how we use that data, as well as to provide you with other important information regarding the processing of your data and the rights that belong to you in this regard.

We are Top Hire Hub Ltd, with registered seats at the address of International House, 24 Holborn Viaduct, London, United Kingdom, EC1A 2BN (“Controller“, “we“, “our“), the company that manages the Website and Platform and determines the purpose and means in which your personal data is processed, which is why we have the capacity of the controller of the personal data, and we are responsible for its processing.

All our activities related to the collection and processing of your personal data are fully compliant with the Data Protection Law (“Law“) and other applicable regulations of the United Kingdom. We process your data exclusively for legitimate purposes, in a proportionate manner, and with the application of all reasonable protection measures, as explained in more detail below, and we do not sell or otherwise make it available to any third-party contrary to the Law.

By registering your account or (in the absence of registration) accessing the Website or Platform, you are deemed to be familiar with this Privacy Policy, including the additional acts and regulations referred to in it, and to fully understand it. If you do not understand any aspect of this Privacy Policy, please feel free to contact us at support@tophirehub.com. In case you have objections to this Privacy Policy or do not agree with its content, please stop using the Website and Platform immediately. Your use of the Website and Platform is governed by the Terms of Use , so we recommend that you carefully read that document as well.

The controller reserves the right to modify this Privacy Policy at any time. Changes to the Privacy Policy enter into force at the time of their publication on the Website, i.e., the Platform, so please check regularly whether they have been changed since your last visit.

  1. Types of personal data we collect about you

Personal data is any information relating to you as a natural person whose identity is determined or determinable, directly or indirectly (for example, your first and last name, residential address, email address, IP address, etc.). If we process any of your data in an anonymized manner, i.e., in such a form that we cannot attribute them to you as a person whose identity is determined or determinable, the provisions of this Privacy Policy and the Law do not apply to such processing.

We collect two groups of your personal data through our Website and Platform:

  1. Data regarding your use of the Website. When visitors come to our Website, we can track, collect and consolidate data that, among other things, indicates which pages of our Website were visited, the order and time of their visits, and the links on which visitors clicked. We also collect information from the URLs from which you visited the Website, including e.g., your IP address, the operating system, and the browser you use, and we may be able to determine based on them your internet service provider and the approximate geographic location from which you accessed our website. Likewise, we use (or can use) cookies when you visit our Website. For more information about our use of cookies, please see our Cookies Policy . If you have not registered your account on our Website or Platform, during your visits we will not be able to collect your name and surname or other data through which we could directly determine your identity, but we cannot completely exclude the possibility that your identity could be indirectly determined by crossing and analyzing the previously mentioned data.
  2. Personal data that we collect directly from you or through third parties. When you register on the Website (or through a special mobile application) on behalf of the company you represent in order to use the Platform, we collect or may collect (in addition to the above) the following types of personal data about you:
  • first and last name;
  • email address;
  • username and password to access the Platform;
  • the position in which you are employed/engaged with the company you represent;
  • data listed under above point 2/a) that refer (in addition to the Website) to the Platform;
  • other personal information that you provide within the registered account as well as the content that you post on the Platform or exchange with other users of the Platform (including communication);
  • types of content you exchange with other representatives of your company or other users of the Platform, including, mutual exchange of information, through the communication interfaces available within the Platform, and messages with other users
  • data you provide when contacting the Controller via email or in any other form, in comments you leave on our Platform or applications to receive marketing materials.

Depending on the purpose for which they are processed, some of your personal data will in certain situations be used as anonymized data, in order to improve the Website and Platform.

We can therefore collect your personal data both directly from you and during your visit to the Website or Platform, but also through your colleagues who invite you to become a user of the Platform. In reasonable cases, at our discretion, we may ask you for additional evidence to verify your identity, such as identity verification through third parties engaged in providing such services, viewing your photos, or personal identification document.

  1. Purposes for which we use your personal data

We process your personal data related to the use of the Website (listed in paragraph 2/a above) and the Platform (if you have registered an account) in order to enable the functioning of the Website and the Platform and provide you with the best possible service, and we do this, among other things, through statistical analysis of the aggregate number and the subject of visits by users of the Website and Platform, etc., as well as to be able to detect and eliminate errors and technical problems that may occur in connection with browsing and using the Website and Platform, including responding to your possible inquiries.

Also, we collect and process your personal data (including those listed under paragraph 2/b above) in order to enable you to register your account, search and use the content and services offered by the Platform, as well as to enter into individual communication with other users of the Platform and thus achieve mutual business cooperation.

We may also process your personal data for the purpose of preventing, investigating, and sanctioning abuses and reporting violations of regulations, including in particular those related to the unauthorized use of the user account or other forms of violation of the Terms of Use and applicable regulations, in order to protect our rights and interests (including the rights and interests of our employees), as well as to preserve the functionality and security of the Website and Platform and the integrity of their content.

In addition, we may use your personal data to send you notifications about our activities and news in the form of newsletters, as well as to send advertising messages to your email or place them on the Website or Platform, including related profiling in accordance with your preferences, in which case we will obtain your prior consent.

  1. Legal basis for processing your data?

We base the processing of personal data for the above-mentioned purposes on the following legal bases, depending on the purpose of the processing and the context in which it is carried out:

  • performance of the contract concluded with you (e.g., regarding the processing of opening an account on the Platform and enabling the functioning and use of the content of the Platform, ensuring the fulfillment of the obligations stipulated in the Terms of Use or another agreement concluded with us, etc.);
  • compliance with our legal obligations (e.g., fulfilling legal obligations regarding reporting violations of regulations and acting on the requests of competent authorities in accordance with the law);
  • pursuing our legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms. Our legitimate interests include e.g., managing and improving our business, administering the Website and Platform and providing our services, establishing and nurturing relationships with partners and users, conducting statistical and other research, conducting marketing activities, preventing abuses, etc.),
  • your consent (e.g., if you choose to receive our newsletter or our other advertising messages or agree to the use of marketing cookies).
  1. Personal data storage periods

We store your personal data on servers in the United Kingdom.

Bearing in mind our commitment to complying with the Law and its principles, including the principle of data storage limitation, we store your personal data only for as long as is necessary to achieve the specific purpose of the processing, unless different deadlines are provided by the relevant regulations. Criteria for determining the retention period of personal data include (i) the duration of your contractual relationship with us; (ii) the existence of a legal obligation that we, as the controller, are obliged to respect; and (iii) the circumstances of whether storage is advisable in terms of our legal position and the protection of our rights and interests (e.g. data retention within the statute of limitations for initiating and/or conducting disputes).   

In cases where your consent is the legal basis for the processing of your personal data, and you decide to withdraw that consent at any time, we will stop any further processing of your personal data after that withdrawal, unless there is another legal basis for processing it. With the fact that the withdrawal of consent does not affect the lawfulness of the processing of personal data that was carried out before the withdrawal.

  1. Access to your personal data

In addition to us, third parties may also have access to your data that we hire to provide us with certain services, such as for example the maintenance of the Website or the Platform, data storage, etc., and who in this case act in the capacity of personal data processors. With each such processor, we conclude a separate contract on the processing of personal data by which we regulate mutual rights and obligations in accordance with the Law, thereby ensuring that your data is processed in a secure manner, in accordance with our instructions, and exclusively for the purposes and under the conditions specified in this Privacy Policy.

In certain cases, the following may also have access to your personal data:

  • competent state bodies, organizations, or institutions, such as courts, police, prosecutor’s office, competent inspections, etc., if within the scope of their legal powers they ask us to do so, as well as for the purpose of realizing our or defending against other person’s legal claims, initiating investigations of possible violations of applicable regulations, or the protection of our property and safety (as well as the property and safety of our employees, users, and partners);
  • potential buyers of shares in the Controller or parts of the Controller’s business, or persons with whom the Controller is considering any joint venture or other joint projects, merger, acquisition, or other status change, but only to the extent that it is necessary to achieve such a purpose.

If in a specific case, we transfer data to one of the countries that do not provide an adequate level of protection in accordance with the Law (which includes most countries outside Europe), we will always ensure appropriate safeguards to protect your data by applying the mechanisms provided for by the Law (including Standard Contractual Clauses approved by Commissioner), as well as the realization of your rights and their effective legal protection. If you would like to learn more about these safeguards, feel free to contact us at support@tophirehub.com.

  1. What rights do you have in relation to the processing of your personal data?

In accordance with the Law, you can request from us at any time the exercise of the following rights in relation to the processing of your personal data:

  • to provide you with access to your personal data, as well as to give you a copy of it – you can ask us for what purposes your data is used and request other relevant information about its processing, to access such personal data, as well as to request that we provide you a copy of some or all of the personal data we hold about you;
  • to request the rectification of incorrectly entered data – you have the right to ask us to rectify data that you consider incorrect or outdated;
  • to request the erasure of your personal data (right to be forgotten) – you have the right to request that we erase the data we have about you if the legal requirements for their processing are no longer met;
  • to restrict the processing of your data by us and/or third parties – if you have contested the accuracy of your data, or their processing is unlawful and you oppose to their erasure, and in other cases provided by the Law, you have the right to request the restriction of the processing of your personal data;
  • to object to the way we handle your data – you have the right to object to the processing of your personal data based on our legitimate interest, as well as the right to object at any time to the processing of your personal data for direct marketing purposes, including any related profiling;
  • to request the transmission of data to another data controller (right to data portability) – if the processing is based on your consent and at the same time is carried out by automated means, you have the right to ask us to transmit your personal data to you or to another controller of your choice in a structured, commonly used and electronically readable form;
  • to withdraw your consent to the processing of personal data – when we process based on your consent, you have the right to withdraw your consent at any time. Withdrawal of consent does not affect the admissibility of processing that was carried out on the basis of consent before the withdrawal;

To exercise the aforementioned rights, please contact us at email support@tophirehub.com. If you are not satisfied with the way we process your personal data, you always have the right to file a complaint with the Information Commissioner’s Office (via web site https://ico.org.uk), as well as to turn to the competent courts in order to protect your rights.

  1. Security of personal data

The security and confidentiality of your personal data are extremely important to us, and therefore, in order to protect them, we always apply appropriate security mechanisms, as well as all necessary technical, organizational, and personnel protection measures in accordance with the Law. These measures include, among others, the use of encryption tools, password-protected login, malicious code protection technologies, physical and electronic access control (by establishing authorization to access personal data), transfer control, organizational control (by establishing internal procedures for the processing of personal data, etc.), contractual confidentiality protection mechanisms and mechanisms for recovery from disruptions and failures.

Also, any external service provider is contractually obligated to ensure the same level of personal data protection as the Controller.

  1. Cookies

In order to maintain the Website and Platform and ensure adequate functionality, we use the so-called “cookies”. Cookies are small text files that the websites you visit send to your computer (or other devices through which you visit them), and which provide prerequisites for the functioning of those websites and enable them (or third parties, if their cookies are also located on those websites) to recognize you and make your next visit simpler, more efficient and more customized, thus improving your user experience. Cookies show us what interests you and other visitors to our Website and Platform, which helps us improve their experience for everyone.

Some of these cookies are necessary because without them it is not possible to search and use the Website and Platform, while others can be used to remember your settings, improve the performance of the Website and Platform (analytics and statistics), or for marketing purposes. When you first visit the Website, you will be notified about all the cookies we use, what data they collect, and for what purposes, and you will be given the opportunity to choose whether you allow the use of only necessary cookies, or agree to the use of some or all other cookies. More information about cookies and guidance on how to make choices regarding the use of cookies can be found in our Cookies Policy .

  1. Other websites

The Website and Platform may contain links to third-party websites. This Privacy Policy applies only to this Website and Platform, so when you link to other websites, we recommend that you read the privacy policies of those specific websites. The Controller does not recommend or endorse any of those websites and therefore assumes no responsibility for the processing of personal data by third parties that have been obtained by referring from the Website or Platform.

We do not share your personal data with third parties who are the owners of such websites unless we have your consent or another legal basis that authorizes us to do so.

  1. Contact

If you have any questions about this Privacy Policy or if you want to request the realization of any individual right, you can contact via email support@tophirehub.com or at the address of the Controller’s registered seat.