Privacy Policy

Last Updated: June 10, 2022.

Welcome to https://www.clockworkrecruiting.com/ (“Site”), a website owned and operated by Clockwork ESE, Inc. dba Clockwork Recruiting (“Clockwork,” “we,” “us” or “our”). This Privacy Policy, along with our Cookie Disclosure, explains how we collect, use, share and protect personal information processed in relation to the Site and the services that we offer (“Services”) (collectively, “Platform”) and other interactions (e.g., customer service inquiries, team collaboration etc.) that you may have with Clockwork. It also tells you about your choices with respect to our collection, use and disclosure of your personal information.

We recommend that you read this Privacy Policy carefully as it provides important information about your personal information and your rights under the law.

IF YOU ARE AN INDIVIDUAL LOCATED IN THE EEA OR THE U.K.: If you are located in the European Economic Area (“EEA”) or the United Kingdom (“U.K.”), this entire Privacy Policy applies to you. However, please see the section titled Additional Information for Users in the EEA and the U.K., which provides more information about which rights you have regarding the processing of your personal data.

IF YOU ARE A NEVADA RESIDENT: If you are a resident of Nevada, please see the section titled Additional Information for Nevada Residents below, which will inform you in detail about our information collection practices and your specific rights.

If you have any questions, comments, or concerns regarding this Privacy Policy, our Cookie Disclosure and/or our data practices, or would like to exercise your rights, do not hesitate to contact us at privacy@clockworkrecruiting.com or see our information below.

Who We Are and How to Contact Us

Clockwork is a Delaware Corporation with the following contact information:
4357 Cedarhurst Circle
Los Angeles, CA 90027United States
privacy@clockworkrecruiting.com

Changes to This Privacy Policy

This Privacy Policy was last updated on the date indicated above. Our business and/or the Platform may change from time to time, and as a result, at times it may be necessary for Clockwork to make changes to this Privacy Policy. Clockwork reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. However, if we make changes that we believe will materially impact this Privacy Policy or your rights, we will promptly notify you of those changes. We encourage you to review this Privacy Policy from time to time. Your continued use of the Platform after any changes or revisions to this Privacy Policy will indicate your agreement to the terms of any such revised Privacy Policy.

Children’s Privacy

Clockwork does not knowingly collect information from children under the age of 18. If you are under the age of 18, please do not submit any personal data through the Platform. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal data on our Platform without their permission.

If you have reason to believe that a child under the age of 16 has provided personal data to Clockwork through the Platform, please contact privacy@clockworkrecruiting.com and we will endeavor to delete that information from our databases.

To Whom Does This Policy Apply

Throughout this Privacy Policy, “personal information” (or “personal data” as used interchangeably) refers to any information that is unique to an individual, such as name, address, email address, phone number, IP address and other information that can reasonably identify an individual. This Privacy Policy applies to personal information (that we collect, store, disclose or otherwise process) from or about:

  • Site Visitors means visitors to our Site, including those who do not register for our Services (“Site Visitors”)
  • Customers means any individual who registers individually or on behalf of an entity or organization in order to use the Services (“Customer”)
  • Executive Profiles – our business is to help people connect professionally, and for this we collect and compile business information about individuals. As a processor for our Customers, we store and process personal information to create Executive Profiles of individuals as part of our Services. Please see below for more information on how this information is collected.

Personal Information That We Collect

What personal information we collect and process depends on a number of factors. As explained in more detail below, we process personal information that we receive directly from you when you provide it to us, such as when you sign up for our Services, or indirectly, such as through automated technologies (e.g., cookies) or from third parties. We also collect personal information for Executive Profiles in a variety of ways, as explained below.

We use the terms ‘controller’ and ‘processor’ or ‘service provider’ as they are commonly understood under applicable privacy laws. With respect to its collection and processing of personal information, Clockwork generally acts as a ‘data processor’ and ‘service provider’ when it collects and processes personal information on behalf of its Customers in order to provide the Services. We also act as a ‘data controller’ when we collect personal information on our own behalf and for our own commercial and business purposes, such as from Site Visitors or to register Customers, to improve our Services or send marketing.

Please note that how you exercise certain rights will depend on whether Clockwork is processing your personal information as a ‘data controller’ or as a ‘data processor’ – as further explained throughout this Privacy Policy.

Information We Collect Directly From You

You can generally visit our Site without having to submit any personal information. However, if you wish to use our Services, you will be asked to provide information about yourself.

Contacting Us

If you contact us through our “Contact” form on the Site or otherwise send us an email, we process any personal information contained in those communications, including name, contact information, company and any other information that you submit to us.

Signing up for our Services

If you sign up for our Services, whether as a Basic or Pro plan, we or our third party processors will collect personal information as follows:

  • First and last name
  • Company name
  • Email address
  • Username
  • Password
  • Job title
  • Preferences
  • Phone number
  • Billing address

If you are a Customer, we use PCI-compliant third-party processors, as explained in Payment Processing. Payment information is processed by our payment service providers, and we receive a confirmation of payment, which we then associate with your account and any relevant transactions.

Customer Reviews

Customer reviews may contain names, company names, photos and contact information. If you submit a Customer review, with your consent, it may be posted on the Site and publicly visible. We may also share it with strategic partners.

Information We Collect Indirectly

Automatically Collected Information

If you are browsing or interacting with the Site, we collect the same basic information that many other websites collect. Even if you do not have an account, we, or authorized third parties engaged by us, automatically collect information about your use of the Site, which consists of:

  • Device Information means information about the devices and software you use to access the Site (“Device Information”) – primarily the internet browser or mobile device that you use, the website or source that linked or referred you to the Site, your device ID (or other persistent identifier that uniquely identifies your computer or mobile device on the Internet), the operating system of your computer or mobile device, device screen size and other similar hardware and software information, and language preference
  • Usage Information means information about your interactions with the Site (“Usage Information”), including access dates and times, device event information, log data, crash data, and cookie data. This information allows us to understand the screens that you view, how you’ve used the Site and/or our Services (which may include administrative and support communications with us), and other actions on the Site. We, or our authorized third parties, automatically collect log data when you access and use the Site for all Site Visitors, even if you have not created an account or logged in. We use this information to administer and improve the Services, analyze trends, track users’ use of the Site, and gather broad demographic information for aggregate use

We (and certain authorized third parties) use cookies and similar technologies in order to collect Device Information and Usage Information. Some cookies are necessary to make the Site and our content available to you, while others are meant to improve the Site and enable us to analyze and measure audience and traffic. For more information on our use of cookies and the data that they collect, see our Cookie Disclosure.

Executive Profile Data

As a processor for our Customers, Clockwork processes information about individuals with whom it does not have a direct relationship on behalf of its Customers. We receive these Executive Profiles on behalf of our Customers from third parties. This information is provided to our Customers as part of the Services. Information that we collect and store to create Executive Profiles (“Executive Profile Data”) consists of business or professional information and includes personal and non-personal data.

Please contact the relevant Customer controller to access or have their Executive Profile Data updated, rectified or deleted.

Google Analytics and Hubspot

We use third-party analytics services, such as Google Analytics, to generate and process statistical or demographic data. These third parties use cookies to compile reports on the Site’s activity and Site Visitors, and provide other services related to Site activity and usage. The technologies used by Google may collect information such as time of visit, whether you are a return visitor, and any referring website. To learn more about how to opt-out of tracking by Google Analytics, please click here.

We also use Hubspot on our Platform. You can read about Hubspot's use of personal data at https://legal.hubspot.com/product-privacy-policy.

Payment Processing

We collect payments from Customers only and do not directly collect or store payment information. We use third-party, PCI-compliant, payment processors, which collect payment information on our behalf in order to complete transactions with our Customers. While our administrators are able to view and track actual transactions via the client portals of the payment processors, we do not have access to, or process, credit card information. We currently use Stripe to process certain payments and you can read more about Stripe’s collection of personal information at https://stripe.com/privacy.

Social Media

We use social media plug-ins (e.g., Facebook, Twitter). These features may collect your IP address and/or other information as set forth in each social platform’s privacy policy, which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Clockwork also has a presence on some social media platforms, including Twitter and LinkedIn. Through our accounts on social medial platforms, we may in some instances collect personal information when you interact with the Clockwork accounts or otherwise communicate with us through those accounts. Any information that you post on social media is governed by each social platform’s privacy notices, and any personal information that we collect via our social media accounts will be processed in accordance with this Privacy Policy.

How Do We Use Personal Information We Collect

We use your personal information for a number of different reasons, as further explained below.

In addition, for users located in the EEA and the U.K., we must have a valid legal basis in order to process your personal data. Generally speaking, the main legal bases under the European Union’s General Data Protection Regulation (GDPR) that justify our collection and use of your personal data are:

  • Performance of a contract – When your personal data is necessary to enter into or perform our contract with you
  • Consent – When you have consented to our use of your personal data via a consent form (online or offline)
  • Legal obligation – When we need to use your personal data to comply with our legal obligations
  • Legal claims – When your personal data is necessary for us to defend, prosecute or make a claim
  • Legitimate interests – When we use your personal data to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.
  • Clockwork provides adequate notice, access and choice.

Below are the general purposes and corresponding legal bases (in italics) for which we may use your personal data:

  • Providing, updating and maintaining the Platform – In particular, we will use your data to ensure that the Site loads and works for you, to set-up an account, or provide you with notices regarding purchases or other important information. Depending on the context, performance of a contract, legitimate interests, and in some cases, legal claims
  • Collecting Executive Profile Data to create and disclose Executive Profiles for use by our Customers – See description above.
  • Processing and completing transactions, and sending you related information, including purchase confirmations and invoices – In particular, we will use your data to complete any purchases for the Services, set up billing and resolve any issues with respect to the foregoing. Performance of a contract
  • Responding to your queries and requests, including to respond to rights requests and customer support requests – In particular, if you contact our support team we may use the information that you provide to us in order to help us respond to your enquiry. Our use of your personal data in this way is necessary to perform our customer service obligations to you, under our Terms of Use. If you are a Site Visitor, Customer, or are an individual with an Executive Profile, we may process your personal data for these purposes where it is in our legitimate interests to do so for customer services purposes. Depending on the context, performance of a contract, legitimate interests, and in some cases, legal claims
  • To otherwise communicate directly with you – In particular, if you contact us or otherwise send as a communication, we may process your personal data. Depending on the context, performance of a contract, legitimate interests, and in some cases, legal claims
  • Improving the content and general administration of the Platform, including to perform system maintenance and upgrades – In particular, we may use Device and Usage to make changes to certain features or improve the Site, or use other information derived from personal data to offer new Services or make upgrades to the Platform. Legitimate interests
  • Detecting fraud, illegal activities or security breaches – In particular, we may use information to help us prevent abuse of the Platform and investigate any potential unauthorized use of the Platform or other security breaches. Legitimate Interests
  • Interacting with individuals on social media via our social media accounts and marketing our Platform – This includes any data we collect when you interact with our social media handles, and any advertising or re-targeting that we may undertake as set forth in this Privacy Policy. Consent where required (e.g., third-party cookies) or legitimate interests
  • Conducting statistical analyses and analytics by monitoring and analyzing trends, usage, and activities in connection with the Platform – In particular, we do this internally or via third parties such as Google Analytics, Hubspot, and other partners. Consent where required (e.g., third-party cookies) or legitimate interests
  • Sending marketing communications, in line with your communication preferences. Consent (depending on location and Customer relationship) or legitimate interests
  • As required by applicable law, legal process or regulation – We may use your information to comply with valid court orders and similar legal or regulatory obligations which apply to us. This may include where we reasonably consider it is in our legitimate interests (or the legitimate interests of others) to comply, as well as where we are legally required to do so. Legal obligations or claims

Disclosure of Personal Data

We disclose your personal data as described below.

Third-Parties and Service Providers

Clockwork discloses users’ information to our third party agents, contractors or service providers who are hired to perform services on our behalf. These companies do things to help us provide the Platform, and in some cases collect information directly, for example as explained in Payment Processing above. Below is an illustrative list of functions for which we may use third-party service providers:

  • Hosting and content delivery network services
  • Analytics services
  • Lead generation partners
  • Marketing and social media partners
  • Customer support services
  • Payment processors
  • Hosting and content delivery network services
  • Functionality and debugging services
  • Professional service providers, such as auditors, lawyers, consultants, accountants and insurers
Customers

Executive Profile Data is disclosed to our Customers that are the controllers of such personal data in connection with our Services. To exercise your rights with respect to personal information contained in your Executive Profile, please see the Executive Profile Data section above.

Business Transfers

As we continue to grow, we may purchase websites, applications, subsidiaries, other businesses or business units. Alternatively, we may sell businesses or business units, merge with other entities and/or sell assets or stock, in some cases as part of a reorganization or liquidation in bankruptcy. In order to evaluate or as part of these transactions, we may transfer your personal information to a successor entity upon a merger, consolidation or other corporate reorganization in which Clockwork participates, or to a purchaser or acquirer of all or a portion of Clockwork’s assets, bankruptcy included.

Anonymized Information

We share aggregated, automatically-collected or otherwise non-personal information with third parties for various purposes, including (i) compliance with reporting obligations; (ii) for business or marketing purposes; (iii) to assist us and other parties in understanding our users’ interests, habits and usage patterns for certain programs, content, services, marketing and/or functionality available through the Platform. We do not share personal information about you in this case.

Legal Obligations and Security

In addition, Clockwork will preserve or disclose your personal information in limited circumstances (other than as set forth in this Privacy Policy), including: (i) with your consent; (ii) when we have a good faith belief it is required by law, such as pursuant to a subpoena, warrant or other judicial or administrative order (as further explained below); (iii) to protect the safety of any person and to protect the safety or security of our Platform or to prevent spam, abuse, or other malicious activity of actors with respect to the Platform; or (iv) to protect our rights or property, or the rights or property of those who use the Platform.

If we are required to disclose personal information by law, such as pursuant to a subpoena, warrant or other judicial or administrative order, our policy is to respond to requests that are properly issued by law enforcement within the United States or via mutual legal assistance mechanism (such as a treaty). However, if we receive information that provides us with a good faith belief that there is an exigent emergency involving the danger of death or serious physical injury to a person, we may provide information to law enforcement trying to prevent or mitigate the danger (if we have it), to be determined on a case-by-case basis.

Advertising & Marketing

Information We Use for Advertising and Marketing

We advertise our Platform by targeting (and measuring the performance of) ads to Site Visitors, Customers on other websites and platforms directly or through a variety of partners, including third party advertisers, ad server companies, social networks and ad networks (collectively, “External Ad Partners”). In order to advertise our Services, we or our External Ad Partners use the following information, whether separately or combined:

  • Device Information collected via cookies and similar technologies on our Site
  • Information provided directly by Customers or individuals who reach out to us directly
  • Usage Information from your use of the Platform
  • Information from External Ad Partners
  • Information inferred the categories of information described above.

When we serve ads based on the foregoing information, it is referred to as “targeted advertising” because External Ad Partners track your activity on and off the Site in order to deliver targeted advertising based on your activity, such as one of your visits to the Site. In addition, as noted above, the information that External Ad Partners collect from our Services may be combined with other information from other sources and be used to build profiles on you and other individuals for the purposes of delivering targeted advertising.

In addition to advertising our Services, we use Customer data and content to market our Services, promote additional features or encourage Customers to share our Platform.

Ad Choices

For more information about interest-based advertising, please visit the Network Advertising Initiative website and/or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising website. To learn more about interest-based advertising and to opt-out of this type of advertising by third parties that participate in the DAA’s AppChoices tool, please use this link. Please note that any opt-out choice you exercise through these programs will apply to interest-based advertising by the third parties you select, but will still allow the collection of data for other purposes, including research, analytics, and internal operations. You may also continue to receive advertising, but that advertising may be less relevant to your interests. You may have more options depending on your mobile device and operating system. For example, most device operating systems (e.g., iOS for Apple phones, Android for Android devices) provide their own instructions on how to limit or prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems to learn more about these features and how they apply to tailored in-app advertisements.

Please visit our Cookie Disclosure for more information on the types of cookies that are used by us and our External Ad Partners within the Services, as well as information on your choices and how to opt -out.

For users in the EEA and U.K., we provide opt-in mechanisms with respect to non-essential cookies. If you opt-in and subsequently change your mind, you may withdraw your consent at any time by contacting us or clicking 'COOKIE SETTINGS' at the bottom of any of our webpages.

Links to Third Party Sites

This Privacy Policy applies only to the Platform. The Platform may contain links to other websites owned and operated by third parties – and therefore not controlled by Clockwork (“Third Party Sites”). To the extent that Third Party Sites collect any personal data when you click on a link to their Third Party Sites, they are responsible for informing you of their data collection and privacy practices, among other things. When you click on a link that takes you to a Third Party Site, we suggest reviewing their privacy policies to understand what information they collect and how they collect it.

“Do Not Track”

Some browsers have incorporated Do Not Track (“DNT”) preferences. Most of these features, when turned on, send signals to the website you are visiting that you do not wish to have information about your online searching and browsing activities collected and used. As there is not yet a common agreement or industry standard about how to interpret DNT signals, Clockwork does not honor DNT signals from web browsers at this time. However, you may refuse or delete cookies as described above. For more information on DNT settings generally, please visit https://allaboutdnt.com.

How to Change Your Communication Preferences

To keep your information accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update any information in our possession that you have previously submitted via the Platform. Note that you may also manage your communications preferences and the receipt of any commercial communication by clicking the “unsubscribe” link included at the bottom of all emails from Clockwork. You may also adjust your preferences through your account settings if you have a Clockwork account, or send an email to privacy@clockworkrecruiting.com.

Your Choices

You have choices about how to protect and limit the collection, use, and sharing of information about you. Note that in order to protect your privacy and security, we will also take reasonable steps to verify your identity before granting you access or enabling you to make corrections or delete your information.

Accessing and Changing Your Information

You can access and change certain information through the Platform if you are a Customer, or by contacting us as privacy@clockworkrecruiting.com.

Controlling the Use of Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject first and third-party cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services. For more information on controlling how cookies and similar technologies are used on the Site, see our Cookie Disclosure.

For users in the EEA and U.K., we provide opt-in mechanisms with respect to non-essential cookies. If you opt-in and subsequently change your mind, you may withdraw your consent at any time.

Controlling Advertising and Analytics

Some analytics providers we partner with may provide specific opt-out mechanisms. For example, you may manage the use and collection of certain information by Google Analytics via the Google Analytics Opt-out Browser Add-on.

You may also generally opt-out of receiving personalized advertisements from certain third-party advertisers and ad networks. To learn more about these advertisements or to opt-out, please visit the sites of the Digital Advertising Alliance and the Network Advertising Initiative, or if you are a user in the European Economic Area, Your Online Choices.

For users in the EEA and U.K., we provide opt-in mechanisms with respect to non-essential cookies. If you opt-in and subsequently change your mind, you may withdraw your consent at any time.

Controlling Promotional Communications

You may opt-out of receiving some or all categories of promotional communications from Clockwork by following the instructions/link contained in those communications or, if you are a Customer, by updating your email options in your account preferences. If you opt-out of promotional communications, we may still send you non-promotional communications, such as information about your account and/or transactions, or your use of the Services.

How Long Do We Keep Your Personal information?

General Retention Periods

We use the following criteria to determine our retention periods: the amount, nature and sensitivity of your information, the reasons for which we collect and process your personal data, the length of time we have an ongoing relationship with you and provide you with access to our Platform, and applicable legal requirements. We will retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to comply with applicable legal, tax or accounting requirements). Additionally, we cannot delete information when it is needed for the establishment, exercise or defense of legal claims (also known as a “litigation hold”). In this case, the information must be retained as long as needed for exercising respective potential legal claims.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible.

For any questions about data retention, please contact privacy@clockworkrecruiting.com.

Anonymization

In some instances, we may choose to anonymize your personal data instead of deleting it, for statistical use, for instance. When we choose to anonymize, we make sure that there is no way that the personal data can be linked back to you or any specific user.

Data Security and Integrity

We take steps that are reasonably necessary to securely provide our Platform. We have put in place reasonably appropriate security measures designed to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We limit access to personal data only to those employees, agents, contractors and the third parties who have a business need-to-know.

We also have procedures in place to deal with any suspected data security breach. If required, we will notify you and any applicable regulator of a suspected data security breach. We also require those parties to whom we transfer your personal information to provide acceptable standards of security.

Notwithstanding, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Platform may not be secure. Therefore, take special care in deciding what information you send to us via email. For any questions about the security of your information, please contact privacy@clockworkrecruiting.com.

Notice to Nevada Consumers

We do not sell your personal information within the scope of, and according to the defined meaning of, a “sale” under NRS 603A.

International Transfers

We are located in the United States, and the personal information that we collect is stored on servers located in the United States. This means that your personal information will be collected, processed and stored in the United States, which may have data protection laws that are different from (and sometimes less protective than) the laws of your country or region, such as the GDPR.

By sending us personal information, you agree and consent to the processing of your personal information in the United States, which may not offer an equivalent level of protection to that required in other countries (particularly the European Union), and to the processing of that information by us on servers located in the United States, as described in this Privacy Policy.

We have implemented safeguards designed to ensure that the personal information we process remains protected in accordance with this Privacy Policy. Safeguards we may take in our discretion include, for instance, entering into standard contractual clauses in connection with any onward transfers of personal information. You may make a request from Clockwork for standard contractual clauses and/or a data processing agreement. We may implement other mechanisms and take similar appropriate safeguards with our third-party service providers and partners. Further details can be provided upon request.

Note: Customers are considered controllers of Executive Profile Data that they receive in connection with the Services and we are the processors of such Executive Profile Data. As such, for Customers that are not located in the EEA, the U.K or a third country deemed adequate by the European Union and that access and create a back-up copy of Executive Profile Data must enter into and adhere a data protection addendum with us.

Additional Information for Users in the EEA and the U.K.

If you are in the EEA or the U.K., please read this section for more information.

Staying In Control of Your Information: Your Rights

If you are in the EEA or the U.K., you have certain rights in relation to your personal data:

  • The right to be informed – our obligation to inform you that we process your personal data (and that’s what we’re doing in this Privacy Policy);
  • The right of access – your right to request a copy of the personal data we hold about you (also known as a ‘data subject access request’);
  • The right to rectification – your right to request that we correct personal data about you if it is incomplete or inaccurate (though we generally recommend first making any changes in your account settings);
  • The right to erasure (also known as the ‘right to be forgotten’) – under certain circumstances, you may ask us to delete the personal data we have about you (unless it remains necessary for us to continue processing your personal data for a legitimate business need or to comply with a legal obligation as permitted under the GDPR, in which case we will inform you). Note that your data may be deleted by emailing us at privacy@clockworkrecruiting.com;
  • The right to restrict processing – your right, under certain circumstances, to ask us to suspend our processing of your personal data;
  • The right to data portability – your right to ask us for a copy of your personal data in a common format (for example, a .csv file);
  • The right to object – your right to object to us processing your personal data (for example, if you object to us processing your data for direct marketing); Rights in relation to automated decision-making and profiling – our obligation to be transparent about any profiling we do, or any automated decision-making; and
  • The right to lodge a complaint at any time to the supervisory authority for data protection issues in your country of residence – however, we ask that you please contact us first so that we can first address your concerns.

These rights are subject to certain rules around when you can exercise them.

If you are located in the EEA or the U.K. and wish to exercise any of the rights set out above, you may contact us at privacy@clockworkrecruiting.com. If you are in the EEA, you may contact our representative in the EU, as explained below.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights) unless your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request under those circumstances.

We may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. If we cannot reasonably verify your identity, we will not be able to comply with your request(s).

We will respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated as required by law.

Social Media and Joint Controllership for Individuals in the EEA

Sometimes, Clockwork acts as a ‘joint controller’ with certain third parties, namely certain social media sites, such as LinkedIn or Facebook. When Clockwork and a partner act as joint controllers, you (as a data subject) may exercise your rights against Clockwork and/or the third party. For a list of joint controller relationships, please contact us at privacy@clockworkrecruiting.com.

Facebook

In order to market our Platform and stay in touch with users, we maintain a Facebook page (“Facebook Products”). With respect to our use of these Facebook Products, we are jointly responsible with Facebook Ireland for the processing activities (“Joint Processing”):
Facebook Ireland Ltd.,
4 Grand Canal Square, Grand Canal Harbor
Dublin 2, Ireland

Information about the personal data that is collected from you by Facebook, as well as how and why it is processed by Facebook, can be found at https://www.facebook.com/about/privacy.

Please note that Facebook Ireland is responsible for enabling data subjects’ rights under Articles 15-20 of the GDPR with regard to the personal data stored by Facebook Ireland in connection with the Joint Processing, as further described in Facebook’s privacy policy. To exercise your rights, please go to your Facebook settings or contact Facebook as set forth in its privacy policy.

It cannot be excluded that some processing by Facebook Ireland Ltd. will also take place in the United States by Facebook Inc.

LinkedIn

With respect to our use of the “Page Insights”, we are joint controllers of your personal data with LinkedIn. You may find the joint controller addendum at https://legal.linkedin.com/pages-joint-controller-addendum.

Representative in the European Union and in the U.K.

General Data Protection Regulation (GDPR) – European Representative

Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Clockwork ESE, Inc. has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU.[KEG4] [CS5] You can contact EDPO regarding matters pertaining to the GDPR by:

UK General Data Protection Regulation (GDPR) – UK Representative

Pursuant to Article 27 of the UK GDPR, Clockwork ESE, Inc. has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR by: