UK Hays App
Privacy Policy 

INTRODUCTION

• This Privacy Policy explains what we do with your personal data when you sign up for and use our digital platform app, and related services (the "Hays App"). The Hays App is designed to provide a range of services to Work Seekers.
• If you use the Hays App in connection with browsing, finding and undertaking assignments (for example, if you browse the Hays App, sign up for assignment alerts or if you accept an assignment through the Hays App), then you will be a "Work Seeker" for the purposes of this Privacy Policy, as we explain in more detail in the section "Types of Work Seekers" below.
• This Privacy Policy describes how we collect, use and process your personal data in connection with the Hays App, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.
• This Privacy Policy applies to the personal data of users of the Hays App.
• For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) and the UK General Data Protection Regulation (either or both, the "GDPR")), the company responsible for your personal data ("Hays" or "us") can be found here.
• It is important to point out that we may amend this Privacy Policy from time to time. Please check this page from time to time as we will post any changes here.
• If you are dissatisfied with any aspect of our Privacy Policy, you may have legal rights and, where relevant, we have described these as well.
• When you use the Hays App as a Work Seeker who is a Registered User or a Fast Assignment User (each as further described below) it is also important that you understand that you are registering not just for services provided through the Hays App but also for other services provided by, and interactions with, Hays outside of the Hays App as a Candidate, (as the term is used in the Hays General Privacy Policy) and/or any other relevant category of individual referred in the Hays General Privacy Policy, including Temporary Worker (for example, we may send you marketing materials). How we use your personal data in this context is set out in full in the Hays General Privacy Policy, and we have provided further information on the types of circumstances where we may do so in the relevant areas of this Privacy Policy.

HOW TO USE THIS PRIVACY POLICY

• This Privacy Policy gives you an insight into how we use your personal data and what your rights are in relation to this. The Privacy Policy is divided into the following sections:
  • How do we collect your personal data?
  • What kind of personal data do we collect and how do we use it?
  • Our legal bases for processing your data
  • Profiling
  • Use of and links to third parties
  • Who do we share your personal data with?
  • How do we safeguard your personal data?
  • How long do we keep your personal data for?
  • How can you access, amend or take back the personal data that you have given to us?
  • How do we store and transfer your data internationally?
  • Who is responsible for processing your personal data when you access the Hays website?
  • What are cookies and how do we use them?
• This Privacy Policy also contains a number of defined terms, so we have included a glossary at the end of this document. If you are unsure what any of these defined terms means, you can simply click on the term and a hyperlink will take you to the relevant part of the glossary.

THE PRIVACY POLICY

How do we collect your personal data?

• When you use the Hays App, we collect your personal data in the following ways:
  • Directly from you: We ask you to provide personal data as part of the registration process (although we may already hold some of this data where you have previously registered with Hays, as further described below). Then, depending on how you want to use the Hays App, we may need to ask you for further personal data to provide these services to you (for example, to enable you to create a profile, or so that we can send you assignment alerts).
  • From your use of the Hays App/from our profile of you: As you use the Hays App we will gather information about you to form a profile of you based on your use of our services (see "Profiling" below).
  • From third parties: We may also gather information about you from your profile on other social media and professional networking platforms, and from other third parties, such as assignment boards. We may also gather information about you from third parties who provide certain functionalities of the Hays App. For example, we may be provided with information by these third parties in order to manage your assignment, or if you access training resources via the Hays App which are provided by third parties, we may collect information about you and any feedback given by you or about you from those training providers. If you access discounts provided by third parties, we may collect information about how much you have saved from those third parties. Please also see further the ‘Use of third parties’ section below. If you have worked for one of Hays' client organisation before or are currently working for a client organisation, we may also collect information about you from those client organisations (such as feedback and timesheet information).
  • From our internal Systems: Where you have previously registered with Hays on a digital platform previously provided by Hays (for example, Hays Hub or Hays Workspace) or otherwise previously interacted with us, then we may already have your details on our Systems. We may use this information we hold about you to enhance your experience of using the Hays App by doing things like pre-populating certain information fields when you complete our sign-up process.

What kind of personal data do we collect and how do we use it?

• We will need to use certain types of personal data about you in the course of providing you with services via the Hays App. We describe each of the situations in which we use your personal data (and the types of personal data that we use) below.

• Types of Work Seekers
• There are three different types of users who may use the Hays App. Which type of user you are will determine what services are available to you and what personal data we collect about you. These types of users are:

• Browsing Users: These are Work Seekers who have downloaded the Hays App but who have not signed up for an account. The services/ functionalities available to a Browsing User are more limited. If you apply for an assignment as a Browsing User, an account will be created for you and you will be invited to login to the Hays App as a Registered User.
• Registered Users: These are Work Seekers who have downloaded the Hays App, created an account (or had one created) and logged in to the Hays App.
• Fast Assignment User: These are Work Seekers who are invited to use the Hays App as a Fast Assignment User. These individuals are invited to become Fast Assignment User as they are suitable for assignments that require quick fulfilment (known as fast assignments), e.g. where compliance checks on these individuals have already been carried out. Fast Assignment Users may also apply for other assignments, and so all services and functionalities on the Hays App are available to Fast Assignment Users.

Unless otherwise stated in this Privacy Policy or the context requires otherwise, references to assignments includes references to fast assignments.

• Sign-up process
• Where you are registering with the Hays App as a Work Seeker, we collect data that you provide during the sign-up process such as name, email address, phone number and home address (or we may obtain certain elements of this from our Systems as described above).

 Provision of Hays App Services

• Depending on how you want to use the Hays App we may also need you to provide additional information. In particular, you will need to provide additional personal data which may include your employment-related information in order for us to provide these services to you.
• We also collect and otherwise process technical information about the devices that you use to access the Hays App and related software, hardware and peripherals, in each case to improve the Hays App and the related services. This technical information includes your IP address (including approximate location data (e.g. country/ locale) using geographic information from your IP address), device identifiers, device name/type, MAC address, and mobile carrier information.
• In addition to the above location data, we may also collect information about your location for certain Hays App services which make use of location data sent from your devices. You can turn off this functionality at any time by turning off the location services settings for the Hays App on the device. If you use these services, you acknowledge our and our affiliates' and licensees' transmission, collection, retention, maintenance, processing and use of your location data and queries to provide and improve location-based products and services, such as alerting you to local assignment opportunities, the location of the nearest Hays' office or nearby places where you can use your discounts. You may stop us collecting such data at any time by turning off the location services settings on for the Hays App on the device. If you do so, this might preclude your use of some functionality of the Hays App

• We also collect additional types of data in respect of different Hays App services and your interactions with them, as set out in the following tables, where you can also find the legal basis that we rely upon to process this data. See also the section headed Our legal bases for processing your data below to find out more about these legal bases.
• Please note that certain services set out in the tables below might not be available to you when you use the Hays App. This is because certain services are only made available to:

• • certain types of Work Seeker e.g. certain services are only available to Registered Users and Fast Assignment Users but not Browsing Users.
  • Work Seekers who have secured an assignment and are currently working in a role; and/or
  • Work Seekers who are working in or are interested in a certain type of role to which the service is relevant.

• There are also a number of services listed below which relate to upcoming functionality that Hays has planned for the Hays App so these might not be available when you open the Hays App.

Please note that certain services may only be available to Work Seekers who are currently working in a role.

• We also collect other personal data about you not listed above in connection with a Client's use of services or platforms related to the Hays App, such as any information a Client may tell us about you in connection with an assignment or otherwise. The legal basis that we rely upon to process this personal data will depend on the nature of the personal data provided to us. However, this will usually be the legitimate interests lawful basis as further described in the section headed "Our legal bases for processing your data"
• For completeness, the Hays App also provides a link to the relevant app store to download the Hays Timesheets app for those users to submit timesheets and carry out other related activities where applicable. The details of processing of personal data in connection with this Hays Timesheets app is governed by the relevant privacy policy set out in the Hays Timesheets app.

• Provision of other services
  • As described above, where you have registered for, or use, the Hays App, as a Work Seeker, we may also use your personal data to deliver other services to you outside of the Hays App in accordance with the Hays General Privacy Policy.

• To help us establish, exercise or defend legal claims
  • In more unusual circumstances, we will use your personal data to help us to establish, exercise or defend legal claims. The personal data that we will process will depend upon the nature of the legal claim in question but will include your name and details of the claim as they relate to you. The legal basis that we rely upon for this processing is the 'establishing, exercising or defending legal claims' lawful basis as further described in the section headed "Our legal bases for processing your data"

• Marketing
  • We will periodically send you information which we think you may be interested in, either via Hays App messages and notifications, or by e-mail. This may include information about:
    • the Hays App such as new services;
    • other Hays products and services which you may be interested in;
    • third party products and services which you may be interested in, such as training courses; and
    • details of reports, promotions, offers, networking and client events, and general information about the industry sectors which we think might be of interest to you.
  • This usually involves the processing of your name, email address, telephone number and details of your marketing preferences.
  • We need your consent for some aspects of these activities which are not covered by our legitimate interests (in particular, the delivery of direct e-marketing of our services to you via e-mail). We will sometimes ask for this consent via soft opt-in, which means we will take your consent as given when you sign-up for the Hays App unless you object or opt out (and we will remind you of your right to do this in each e-marketing message that we send to you). For other types of e-marketing, we are required to obtain your explicit consent. Consent is further described below in in the section headed "Our legal bases for processing your data".
  • We may also send you marketing materials in accordance with the processes set out in the Hays General Privacy Policy.

• Profiling
• Profiling is a type of processing activity which involves our use of information that we collect about you in order to build a "profile" about you. In the tables above we explain what personal data we collect to build a "profile" about you. This helps us to get a better idea of what you're like and your interests, likes and dislikes, all of which enable us to provide the best possible service to you. We rely on the legitimate interests legal basis to carry out this processing, namely we consider it is in our and your legitimate interests to provide you the best possible service that is relevant to you. This legal basis is further described below in in the section headed "Our legal bases for processing your data".
• Here's how we use profiling:
• Personalisation
• We want to ensure we communicate with you in the best way possible, and to optimise the information we provide to you through our services, website and online presence. In order to do this, we use profiling methods which involve analysing your personal data in order to better understand you and your interests, habits and preferences. An example of how we might do this is that when you click on something on our website, we take note of this as perhaps an indication of what you are interested in looking at. We use profiling methods to place you and your user profile into groups or segments with other Hays App users, based on your interests, habits, attributes and/or preferences so that we can:
• send you personalised emails (which, for example, might reflect what we think are your preferences);
• make recommendations for editorial content that we think may be of interest to you (e.g. reports about developments in your industry);
• send you tailored or more relevant marketing communications (the contents of which may, for example, reflect how you have responded to or interacted with previous marketing communications from us); and
• recommend relevant third party training courses to you based on your assignment interests.

• Improving your experience of our services outside of the Hays App

We may want to use information that we find out about you when you use the Hays App in order to improve your experience of the services that we provide to you outside of the Hays App.

As referred to above, where you use the Hays App we may also use your data for services outside of the Hays App, as a Work Seeker, we carry out a number of profiling activities that are set out in our Hays General Privacy Policy and we will use information that we collect about you via the Hays App as part of these profiling activities.

Our legal bases for processing your data

• Legitimate interests
  • Article 6(1)(f) of the GDPR is the one that is relevant here – it says that we can process your data where it "is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data".
  • We don't think that any of the following activities prejudice individuals in any way – in fact, they help us to offer you a more tailored and efficient service, (for example, by using profiling methods to personalise your experience with us and our communications with you) so everyone's a winner! However, you do have the right to object to us processing your personal data on this basis. If you would like to know more about how to do so, please refer to the right to erasure.
  • We consider the following to be non-exhaustive examples of processing activities that are in our legitimate interests to carry out in the context of the Hays App:
• facilitating sign-up to the Hays App;
• facilitating the provision of Hays App services to Work Seeker; and
• for our internal administrative purposes, such as facilitating payroll and invoicing processes.
• Consent
• In certain circumstances, we are required to obtain your consent to the processing of your personal data in relation to certain activities. Depending on exactly what we are doing with your information, this consent will be opt-in consent or soft opt-in consent.
• Article 4(11) of the GDPR states that (opt-in) consent is "any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her". In plain language, this means that:
• you have to give us your consent freely, without us putting you under any type of pressure;
• you have to know what you are consenting to – so we'll make sure we give you enough information;
• you should have control over which processing activities you consent to and which you don’t. We provide these finer controls within our privacy preference centre; and
• you need to take positive and affirmative action in giving us your consent – we're likely to provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion.
• We will keep records of the consents that you have given in this way.
• We have already mentioned that, in some cases, we will be able to rely on soft opt-in consent in order to market products or services to you which are related to the Hays App services or services outside of the Hays App that we provide to you unless you actively opt-out from these communications. We will, at other times, obtain your explicit consent in relation to our marketing activities in connection with the Hays App or otherwise.
• As we have mentioned, you have the right to withdraw your consent to these activities. You can do so at any time, and details of how to do so can be found here.
• Establishing, exercising or defending legal claims
• Sometimes it will be necessary for us to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in connection with exercising or defending legal claims. Article 9(2)(f) of the GDPR allows this where the processing "is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity".
• This will arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.

Use of and links to third parties

• Certain of the Hays App services and functionalities listed above are provided or supported by third parties and subject to those third party terms and conditions of use and privacy policies (if any). These include:

• The Hays App and its services may contain links to other independent websites and to third party services which are not provided by us, including training resources offered by external providers, and to services offered by external advisors. Such independent sites and third parties are not under our control, and we are not responsible for and have not checked and approved their content or their privacy policies (if any). You will need to make your own independent judgement about whether to use any such independent sites, including whether to buy any products or services offered by them.
• Where you are using the Hays App via an app, the ways in which you can use the Hays App may also be controlled by the rules and policies of the app store from which you download the Hays App. Where there are difference between the app store's rules and policies and this Privacy Policy, the app store's rules and policies will apply.
• Please also see below "Who do we share your personal data with".

Who do we share your personal data with?

• Where appropriate and in accordance with local laws and requirements, we will share personal data set out in the section headed "What kind of personal data do we collect and how do we use it?" with the following categories of people:

• Any of our group companies;
• Appropriate colleagues within Hays (this may include colleagues in overseas offices);
• Client organisations that you work for or prospective employers;
• Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);
• Third party service providers who perform services or functions on our behalf (including external suppliers and consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology Systems);
• Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
• Third party aggregators;
• Third party service providers who provide services to you via the Hays App;
• Third party training providers, who will receive some limited personal data about you by way of a unique identifier, to make it quicker and easier for you to sign up to training courses;
• Marketing technology platforms and suppliers; or
• If Hays merges with or is acquired by another business or company in the future, (or is in meaningful discussions about such a possibility) we may share your personal data with the (prospective) new owners of the business or company.

• In most circumstances, we consider it to be in our legitimate interests to share your personal data with these categories of people or, where applicable, we do so in furtherance of establishing, exercising or defending legal claims. Each of these legal bases as further described in the section above headed "Our legal bases for processing your data".

How do we safeguard your personal data?

• We are committed to taking all reasonable and appropriate steps to protect the personal data that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach.
• If you suspect any misuse or loss of or unauthorised access to your personal data please let us know immediately. Details of how to contact us can be found here.

How long do we keep your personal data for?

• We will Delete your personal data processed in connection with the Hays App from our Systems if we have not had any meaningful contact with you for two years (or for such longer period as we believe in good faith that the law or relevant regulators require us to preserve your data). After this period, it is likely your data will no longer be relevant for the purposes for which it was collected.
• When we refer to "meaningful contact", we mean your active use of the Hays App or more generally as a Work Seeker (or a Candidate under our Hays General Privacy Policy) even if not related to the Hays App (for example, if you use other services provided outside of the Hays App). Your receipt, opening or reading of an email or other digital message from us, will not count as meaningful contact – this will only occur in cases where you sign into the Hays App or any other service through which you interact with us, where you have asked us to keep you signed-in, access and interact with the Hays App or such other service.
• In determining the appropriate retention period for different types of personal data, we always consider the amount, nature, and sensitivity of the personal data in question, the potential risk of harm from unauthorised use or disclosure of that personal data, the purposes for which we need to process it and whether we can achieve those purposes by other means (in addition of course to ensuring that we comply with our legal, regulatory and risk-management obligations, as described above).

How can you access, amend or take back the personal data that you have given to us?

One of the GDPR's main objectives is to protect and clarify the rights of EU and UK citizens and individuals in the EU and UK with regards to data privacy. This means that you retain various rights in respect of your data, even once you have given it to us. These are described in more detail below.

To get in touch about these rights, please contact us. We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled). Please note that we will, where necessary, keep a record of your communications to help us resolve any issues which you raise. Please also note that where you make a request, we will action your request in relation to your personal data that we have collected and otherwise processed in connection with the Hays App and all other personal data that we may hold about you on our internal Systems as someone who has previously registered with Hays. By way of illustration, if you request for your personal data to be erased, we will erase all personal data that we hold about you, not just personal data that we have collected and otherwise processed in connection with your use of the Hays App.

• Right to object
• This right enables you to object to us processing your personal data where we do so for one of the following four reasons: (i) our legitimate interests ; (ii) to enable us to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials; and (iv) for scientific, historical, research, or statistical purposes.
• The "legitimate interests" and "direct marketing" categories above are the ones most likely to apply to users of our Hays App. If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless:
  • we can show that we have compelling legitimate grounds for processing which overrides your interests; or
  • we are processing your data for the establishment, exercise or defence of a legal claim.
• If your objection relates to direct marketing, we must act on your objection by ceasing this activity.
• Right to withdraw consent
• Where we have obtained your consent to process your personal data for certain activities (including soft opt-in for marketing purposes), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.
• Data Subject Access Requests (DSAR)
• You may ask us to confirm what information we hold about you at any time, and request us to modify, update or Delete such information. We may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is "manifestly unfounded or excessive". If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.
• Please note that in certain jurisdictions in which we operate, we comply with additional local law requirements regarding data subject access requests and may refuse your request in accordance with such laws.
• Right to erasure
• You have the right to request that we erase your personal data in certain circumstances. Normally, the information must meet one of the following criteria:
  • the data are no longer necessary for the purpose for which we originally collected and/or processed them;
  • where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;
  • the data has been processed unlawfully (i.e. in a manner which does not comply with the UK GDPR);
  • it is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller; or
  • if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.
• We would only be entitled to refuse to comply with your request for one of the following reasons:
  • to exercise the right of freedom of expression and information;
  • to comply with legal obligations or for the performance of a public interest task or exercise of official authority;
  • for public health reasons in the public interest;
  • for archival, research or statistical purposes; or
  • to exercise or defend a legal claim.
• When complying with a valid request for the erasure of data we will Delete the relevant data.
• Right to restrict processing
• You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either one of the circumstances listed below is resolved: (i) you consent is obtained; or (ii) further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important United Kingdom, EU or Member State public interest.
• The circumstances in which you are entitled to request that we restrict the processing of your personal data are:
• where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;
• where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data;
• where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and
• where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims.
• If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.
• Right to rectification
  • You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
• Right of data portability
  • If you wish, you have the right to transfer your personal data between data controllers. In effect, this means that you are able to transfer your Hays account details to another online platform. To allow you to do so, we will provide you with your data in a commonly used machine-readable format that is password-protected so that you can transfer the data to another online platform. Alternatively, we will directly transfer the data for you. This right of data portability applies to: (i) personal data that we process automatically (i.e. without any human intervention); (ii) personal data provided by you; and (iii) personal data that we process based on your consent or in order to fulfil a contract.
• Right to lodge a complaint with a supervisory authority
  • You also have the right to lodge a complaint with your local supervisory authority. Details of how to contact them can be found here.
  • If you would like to exercise any of these rights, or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), details of how to contact us can be found here. Please note that we will, where necessary, keep a record of your communications to help us resolve any issues which you raise.
  • You may ask to unsubscribe from temporary assignment alerts and other marketing communications from us at any time. Details of how to do so can be found here.
  • It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold your data.

How do we store and transfer your data internationally?

• So you want to know more about how we store and transfer your data internationally? In order to provide you with the best service and to carry out the purposes described in this Privacy Policy, your data will be transferred:
• between and within Hays entities; and
• to the third parties referred to in the "Who do we share your personal data with" section.
• Some of the data that we hold about you in connection with the Hays App will be stored on, and synced with, our internal Systems that we also use to provide you our other services outside of the Hays App. We refer to this data, which includes contact information such as your name, email address, phone number and home address as "core data". This means that if, for instance, you update an item of your "core data" via the Hays App, it will also be updated on our wider Systems. We will process this data in accordance with both the terms of this Privacy Policy and the Hays General Privacy Policy.

• Some of the other data that we hold about you in connection with the Hays App will only be maintained in the Hays App. We refer to this data, which includes information such as the types of assignments you are looking for and your availability as "operational data". This will not be synced with our wider Systems. We will process this "operational data" in accordance with the terms of this Privacy Policy alone.

• We want to make sure that your data are stored and transferred in a way which is secure. We will therefore only transfer data outside of the European Economic Area or EEA (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein) or the United Kingdom where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:

• by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission or approved under the laws of the United Kingdom for the transfer of personal data by data controllers to data controllers and processors in jurisdictions without adequate data protection laws;

• transferring your data to a country where there has been a finding of adequacy by the United Kingdom under UK adequacy regulations in respect of that country's levels of data protection via its legislation;
• where it is necessary for the conclusion or performance of a contract between ourselves and a third party and the transfer is in your interests for the purposes of that contract; or
• where you have consented to the data transfer.
• To ensure that your personal data receives an adequate level of protection, we have put in place appropriate procedures with the third parties we share your personal data with to ensure that your personal data is treated by those third parties in a way that is consistent with and which respects the law on data protection.

Who is responsible for processing your personal data when you access the Hays App?

• You can find out which Hays entity is responsible for processing your personal data and where it is located by following this link.
• If you have any comments or suggestions concerning this Privacy Policy please follow this link. We take privacy seriously so we'll get back to you as soon as possible.

What are cookies and how do we use them?

• The following section is relevant only where you are using the Hays App to access a web browser (for example, where you click on a link in the app taking you to the Hays website or third party website), and not more generally to your use of the app.
• What's a cookie?
• A "cookie" is a piece of information that is stored on your device's hard drive and which records your navigation of a mobile app so that, when you revisit that app, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes.
• Cookies are used by nearly all mobile apps (and websites), and do not harm your system. If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings on your device.
• If you do not want to receive cookies that are not strictly necessary to perform basic features of our Hays App, you may choose to opt-out by changing your browser settings on your device.
• Most browsers will accept cookies but if you would rather we didn’t collect data in this way you can choose to accept all or some, or reject cookies in your device's privacy settings. However, rejecting all cookies means that you may not be able to take full advantage of all our Hays App's features. Each device is different, so check your device settings to learn how to change your cookie preferences.
• For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your device.
• How do we use cookies?
• We use cookies to:
  • ensure the Hays App and its features run properly, such as allowing you to apply for a role via the Hays App;
  • remember your previous visits or choices you have made to help personalise your return visits and improve your experience using the Hays App; and
  • help us track your use of the Hays App. This enables us to understand how you use the Hays App and track any patterns that emerge individually or from larger groups. This helps us to develop and improve the Hays App and services in response to what our users want and need.
• Cookies are either:
  • Session cookies: these are only stored on your deviceduring your browsing session and are automatically deleted when you close your mobile app – they usually store an anonymous session ID allowing you to browse a mobile app without having to log in to each page but they do not collect any information from your device; or
  • Persistent cookies: a persistent cookie is stored as a file on your device and it remains there when you close your mobile app . The cookie can be read by the website or app that created it when you visit that app again. We use persistent cookies for Google Analytics and for personalisation (see below).
• Cookies can also be categorised as follows:
  • Strictly necessary cookies:These cookies are essential to enable you to use the Hays App effectively, such as when applying for a role, and therefore cannot be turned off. Without these cookies, the services available to you on our Hays App cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
  • Performance cookies: These cookies enable us to monitor and improve the performance of our Hays App. For example, they allow us to count visits, identify traffic sources and see which parts of the Hays App are most popular.
  • Functionality cookies: These cookies allow our Hays App to remember choices you make (such as your user name, language or the region you are in) and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. These cookies can also be used to remember changes you have made to text size, font and other parts of the Hays App that you can customise. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.
  • Personalisation cookies:These cookies help us to advertise details of potential assignment opportunities that we think may be of interest. These cookies are persistent (for as long as you are registered with us) and mean that when you log in or return to the Hays App, you may see advertising for assignments that are similar to assignments that you have previously browsed.
• The table at Annex 3 lists the cookies we use in your jurisdiction, why we use them and what types of cookies they are.
• Third party cookies
• The Hays App may contain links to other independent websites and to third party services which are not provided by us, including training and other resources offered by external providers, and to services offered by external advisors.
• If you access any of these third party websites, the relevant third party may drop cookies onto your device. The cookies used by these third parties are not under our control, and we have not verified as to whether the relevant third party that use them have complied with applicable legislation in respect of their use of such cookies.