Effective from 1^st April 2021

www.hospitaityconnect.org is operated by Hospitality Associates International LLC (“HAI”). Hospitality Associates International is a limited liability company registered in Kenya and under companies Act. Certificate No. C04269861.

Hospitality Connect is a global online job board business that operates online job portals to accurately match candidates with companies.

We take data protection very seriously and understand the importance of protecting your privacy and Personal Information. “Personal Information” is information that identifies you as an individual such as your name, date of birth, email address, IP address and CV.

How do we collect information from you?

We collect and use your Personal Information in accordance with this our Privacy Policy. The majority of the Personal Information you provide to us when you give us your CV or job cover letter to a job application.

Please do not submit such Personal Information to us if you do not wish us to collect it.

Please be aware that we may also infer certain information about you from your expressed search preferences. We also collect from:

• our websites (the “Websites”);
• the software applications made available by us for use on or through computers and mobile devices (the “Apps”);
• cookies (“Cookies”);
• publicly available information; and,
• other tools and applications (our “Online Content”).

What Personal Information do we collect?

Personal Information we collect about you may include the following:

• General identification and contact information: your name; address; email; IP address; telephone details; gender; marital status; family status; date and place of birth; physical attributes including photos.
• Other sensitive information: trade union membership, religious beliefs, political opinions or racial or ethical origin, and criminal record.
• Information enabling us to provide products and services: age, location, whether or not you hold a driving license that enable identification of job search (for example, post code or job role).
• Marketing preferences: enter a contest or prize draw or other sales promotion, or respond to a voluntary customer satisfaction survey.
• Statistical information: aggregate statistical information about site visitors and users for internal use and for other lawful purposes e.g. Salary averages. We provide this information to customers, advertisers, suppliers and other reputable third parties. Where we provide such information, we will provide this in an anonymous format and not include any Personal Information.
• Information from Apps: submit comments to the Site, participate in message boards, blogs, send us emails or any other user generated content facility.
• Publicly available information in relation to professional history: educational background; employment history; skills and experience; professional licenses and affiliations; educational and professional qualifications.

What legal basis do we rely on to process your Personal Information?

Consent

On some occasions, Hospitality Associates International LLC processes your data with your consent. For example, we rely on consent when we send promotional material or when you link your Hospitality Associates International LLC account to your Social Network account. We also obtain your consent prior to using your location data to target specific job advertisements at underrepresented communities (i.e. profiling) when recruiters opt to use our Equality boost product. You have the right to withdraw consent at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn.

The processing is necessary to fulfil a contract

Hospitality Associates International LLC may process your data when we need to do this to fulfil a contract with you, such as to send your CV to an employer or recruiter for a specific job application.

Legitimate Interest

Hospitality Associates International LLC also processes your data when it is in our legitimate interests to do this and when these interests are not overridden by your data protection rights.

Our legitimate interests include:

• ensuring the security and integrity of our Services and in ensuring that our Websites and Apps operate effectively;
• selling and supplying goods and services to our customers;
• protecting customers, employees and other individuals and maintaining their safety, health and welfare;
• promoting, marketing and advertising our products and services;
• sending promotional communications which are relevant and tailored to individual customers;
• understanding our customers’ behaviour, activities, preferences, and needs;
• improving existing products and services and developing new products and services;
• handling customer contacts, queries, complaints or disputes; and,
• fulfilling our duties to our customers, colleagues, shareholders and other stakeholders.

The processing is necessary because of a legal obligation that applies

Hospitality Associates International LLC may process your data to comply with our legal and regulatory obligations, e.g. preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies.

Who do we share your Personal Information with?

Our group companies

We may share your personal data with certain members of our group companies which also operate online job portals. Where they have access to your personal data, they will use it only for the purposes set out in this Privacy Policy. Hospitality Associates International LLC will remain responsible for the management and security of jointly used Personal Information. Access to Personal Information within Hospitality Associates International LLC and our group of companies, is restricted to those individuals who have a need to access the information for our business purposes.

Recruiters and other agents

During our business to help you search for and get a job, Hospitality Connect may make Personal Information available to third parties such as recruiters and other intermediaries and agents and other business partners. The amount of information we share with recruiters will depend on the options you select when you create or update your account. If you choose to make your profile public, recruiters will be able to see and your Last Active date (this is the date you most recently updated your profile or CV, or searched or applied for jobs using the Services). Depending on your preferences, we may also share your application history (jobs you have applied for and when you applied for them). You can change the information recruiters can see about you at any time by updating your details and preferences in your profile.

Our service providers

This includes external third-party service providers, such as accountants, auditors, experts, lawyers and other outside professional advisors; IT systems, support and hosting service providers; printing, advertising, marketing and market research and analysis service providers; document and records management providers; technical engineers; data storage and cloud providers and similar third-party vendors and outsourced service providers that assist us in carrying out business activities.

Governmental authorities and third parties involved in court action

Hospitality Associates International LLC may share Personal Information with governmental or other public authorities (including, but not limited to, workers’ compensation boards, courts, law enforcement, tax authorities and criminal investigations agencies); and third-party civil legal process participants and their accountants, auditors, lawyers and other advisors and representatives as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our group companies; (f) to protect our rights, privacy, safety or property, and that of our group companies, you or others; and (g) to allow us to pursue available remedies or limit our damages.

Other third parties

Occasionally, we may share Personal Information with other third parties. We will always do this under contract and in accordance with your instructions.

How we use Personal Information?

We use Personal Information to do some or all of the following:

• Communicate with you as part of our business;
• Send you important information regarding changes to our policies, other terms and conditions, the Hospitality Connect Website and App and other administrative information.
• Provide improved quality, training and security and manage other commercial risks;
• Carry out market research and analysis, including satisfaction surveys;
• To understand and analyze customer engagement with our Site, content and emails;
• Provide marketing information to you (including information about other products and services offered by selected third-party partners) in accordance with preferences you have expressed. Please be aware you can always change these in your account;
• Personalize your experience on the Hospitality Connect Website and App by presenting information and advertisements tailored to you and by providing you access to selected services of our group companies.
• Develop and improve our Website, App and Services (where possible we will anonymize your information before we do this);
• The CV used to apply is evaluated automatically against the job advert using real recruiters’ assessments on various candidates as a point of reference. We may highlight applications evaluated as a significant match. All Applications, regardless of this evaluation, are delivered to the recruiter for them to review;
• Allow you to participate in contests, prize draws and similar promotions, and to administer these activities. Some of these activities have additional terms and conditions, which could contain additional information about how we use and disclose your Personal Information, so we suggest that you read these carefully;
• Facilitate social media sharing functionality;
• Manage our infrastructure and business operations, and comply with internal policies and procedures, including those relating to auditing; finance and accounting; billing and collections; IT systems; data and website hosting; business continuity; and records, document and print management;
• Resolve complaints, and handle requests for data access or correction;
• Comply with applicable laws and regulatory obligations (including laws outside your country of residence), such as those relating to anti-money laundering and anti-terrorism; comply with legal process; and respond to requests from public and governmental authorities (including those outside your country of residence);
• Establish and defend legal rights; protect our operations or those of any of our group companies or insurance business partners, our rights, privacy, safety or property, and/or that of our group companies, you or others; and pursue available remedies or limit our damages.

International Transfers of Personal Information

Personal Information which you supply to us is generally stored and kept inside the European Economic Area.

However, due to the nature of our global business and the technologies required, your Personal Information may be transferred to third party service providers outside the EEA, in countries where there may be a lower legal level of data protection. Therefore, as far as you make your profile searchable to recruiters, a recruiter could also be located outside of the EU/EEA. That means that as part of the contract between you and us, it might be necessary that your profile is accessed from a country that does not have the same level of data protection as the EU or EEA. In such situations, we transfer the minimum amount of data necessary, anonymize it where possible and enter legal contracts to aim to ensure these third parties handle your Personal Information in accordance with this Privacy Policy and the European levels of data protection.

How can you manage or delete Personal Information?

When you access our website online, we store some information about you. This is anonymous and used for statistical purposes.

When you create an account and log-in to your “My Account” area, it is protected by your password and may only be accessed by you. You can manage the content and information in your Account at any time, by logging in to your “My Account”.

Your CV can be viewed by Hospitality Connect customers, if you have consented to this within the profile section. This is the default setting. Further, when your profile is searchable your application activity (e.g. number of applications, job titles, locations & salaries) will be visible to Hospitality Connect customers. Such visibility can also be provided through browser plugins or other software that we offer if our customers visit certain social media websites about you. This is also the default setting

Please note that Hospitality Connect reserves the right to remove from our database, CVs which include any content that we consider to be illegal or offensive. We will respect the choices you make to limit sharing or visibility settings in your “My Account”.

You can de-activate or delete your account at any time, make your profile anonymous or choose to not make your profile searchable. To de-activate, please go to your “My Account”.

However, if you would like to permanently delete your account, you can send an email to our Data Protection Officer (DPO) (see below) with the subject line “Permanently delete my information and account”. Please do not forget to tell us who you are.

It is important for you to protect against unauthorized access to your password and to your computers, devices, and applications. Be sure to sign off when you finish using a shared computer.

As a registered user of the Website you may opt to receive Job Alerts by email. To facilitate your ease of use of the Website across multiple devices, Job Alerts by email include a personalized link which will recognize you when you visit the Website by clicking on a link in the email. This makes it easy for you to apply for jobs as your name, email address, and link to your last used CV will automatically be populated in the Job application form. As Job Alert emails are personalized to you, it is important that you do not share these email links with other people or post them on social media. You are responsible for maintaining the security of these personal Job Alert email links. Sharing personalized Job Alerts could result in a somebody inadvertently applying for a job in your name.

Security

Hospitality Associates International LLC is committed to keeping your personal data safe and secure from unauthorized access to or unauthorized alterations, disclosure or destruction of information that we hold.

Our security measures include:

• encryption of our services and data;
• review our information collection, storage and processing practices, including physical security measures;
• restrict access to personal access to personal information to Hospitality Connect employees, contractors and agents who need to know that information in order to process it for us and who are subject to contractual confidentiality and processing obligations. They may be disciplined or their contract terminated if they fail to meet these obligations; and
• internal policies setting out our data security approach and training for employees.

Additional Services for Website and App

Location based services

If you use the Hospitality Connect App, we will ask you if you want to use our geolocation service. This service is provided by Adobe Systems Software Ireland Limited. Based on your mobile phone GPS signal it allows us to identify your location. We will use this information to provide you with job offers close to you and to improve our Products and Services. In no case will we merge such information with any personally identifiable information. We will at no times be able to connect you personally in connection with the respective location. You may at any stage opt out of location tracking by changing the App settings. However, you will also lose the location supported product functionality as well.

For further information about Adobe and their service please visit:  www.adobe.com/privacy.html.

 Push notifications

If you use the Hospitality Connect Website or App, you may also consent to push notifications, text messages, alerts, emails or other types of messages directly sent to you outside or inside of the Hospitality Connect App to your mobile device or desktop browser. If you declare your consent to receive such messages a device token will be generated, which will be associated with your device.

These device tokens will be stored on our behalf by Notice Software, Inc d.b.a Roost, 234 5th Ave, New York, NY 10001. See their Privacy Policy at www.getroost.com/privacy/. You can opt out from receiving such messages by changing the settings of your device.

Online drives

If you enable us, we access the following Services for the limited purpose of helping us to upload or otherwise access your CV, cover letters or any other documents you provide us to assist you apply for jobs. The Services we use are:

• Google Cloud
• OneDrive
• DropBox
• Box

We will ask for your consent before using information for any purpose other.

Mahiba

This Mahiba Privacy Statement describes which personal data is collected through the Mahiba browser extension (“Software”). We understand the importance of maintaining the confidentiality of your personal data. We thus make every effort to comply with our obligations under the Data Protection Act 2018 and where and when applicable the General Data Protection Regulation.

The browser extension is used for recruiters to have the option to extract pertinent contact details, publicly available, of candidates who are interested and/or looking for a career opportunity. Such software is used on well-respected websites, including but not limited to LinkedIn.

The Candidates will insert contact details on social platforms namely LinkedIn with the intention to connect with recruiters. If the candidate is one of our registered candidates and the recruiter searches for the candidate on LinkedIn the Software will make visible the candidate’s contact information, such as email address and telephone number. For the avoidance of doubt, the contact information that is made available are those of the candidates who set their profile “searchable” with us.

Data which we collect about your use of the Software or which you supply to us may be transferred to third party service providers to be stored or processed on our behalf, including third parties located outside of the European Economic Area in countries where there may be a lower legal level of data protection. However, we will always endeavor to handle your information in accordance with this privacy policy, wherever it is processed.

Like many websites, we store small data files or letters and numbers on your hard drive or in device memory of your computer. The purpose of this is to improve our services and your experience using the software, please read our cookie policy to understand further.

Log-In Details for Additional Services to use all Features of the Software

In order to use all features of Mahiba, the Software, you might be required to purchase additional services, which might require provision of a password and a login in the Software. If you login to such services via the Software, we will store when you have logged in.

Statistical information

We provide aggregate statistical information about users of the Software and their use. We may provide this information to customers, advertisers, suppliers and other reputable third parties. This will not include any information that enables them to identify individuals.

Services provided by Group Companies

As part of our websites or apps, we may provide you access to selected services of our group companies. In this context we may:

Send an identifier (which is initially non-personal data) to Good&Co, which is operated by Good&Co Labs, Inc., 74 Langton St, San Francisco, CA 94103, USA. Good&Co is a service that develops psychometric profiles based on user responses to personality quizzes and lets users compare such profiles with certain job and company requirements, i.e. to evaluate how well a user fits to a specific job. If you have created a Good&Co account through Hospitality Connect or link your Good&Co account to your Good&Co account we will provide your email address to Good&Co so that Good&Co can make the identifier personal data and link it to your Good&Co account and re-identify you on any further access to Good&Co via our Platform. The legal basis is the contract we have with you about the use of our services and the use of Good&Co through our platform in particular.

Marketing and Advertising

Online Behavioral Advertising

We partner with third-party advertising networks so that we and other advertisers can display advertising which is more relevant to you and your interests on our Web site or on other sites that you visit and assess the performance of that advertising. We and our ad network partners may utilize cookies or web beacons along with other codes such as your Identifier for Advertising (IFA) or Android ID for your phone to better understand your interests from the web pages you interact with and the search terms you use on our site to build a picture of the category of interests or preferences you have and to provide advertisements about goods and services that may be of interest to you. Our ad network partners do not collect and do not have access to any information from which you can be directly identified such as your real name or address or email. They may, however, anonymously track your Internet usage across other websites in their networks beyond these Sites. To learn more about the use of this information or to choose not to receive tailored advertising by opting out, you can visit either the Network Advertising Initiative at  networkadvertising.org or the European Interactive Digital Advertising Alliance (EDAA) at www.youronlinechoices.com or visit the privacy statements of our partners: Google, Adobe and Tealium. You can control the types of adverts we display here. You can also learn more about our use of cookies and similar technologies and your choices by reading our Cookies policy. Please note that if you opt-out you will continue to receive generic advertising that has not been targeted to you and your interests.

We also use tracking pixels in our marketing emails. These pixels tell us if, and when, you opened an email from us. We use this information to better understand how customers engage with our content and to analyze the effectiveness of our marketing campaigns. You can disable tracking pixels by changing your email settings to block the loading or display of external images.

Your Rights

You have the following rights:

• the right to ask what personal data that we hold about you at any time, subject to a fee specified by law;
• the right to ask us to update and correct any out-of-date or incorrect personal data that we hold about you free of charge; and
• (as set out above) the right to opt out of any marketing communications that we may send you.

If you wish to exercise any of the above rights, please contact us using the contact details set out below.

Children and minors

Hotels Careers Online is not directed towards individuals under the age of eighteen (18), however we are aware due to the nature of some of the job offerings, those between 14 and 18 may use the Services.
Individuals under the age of thirteen (13) are expressly prohibited from using Hospitality Connect Website and App, unless parental consent is provided and we are notified.

Third Party Privacy Practices

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties to which the Hospitality Connect website and App link. The inclusion of a link on the Website or App does not imply endorsement of the linked site or service by us or Hospitality Associates International LLC. Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations or any other software application developer or provider, social media platform, operating system or wireless service provider, or device manufacturer, including any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.

Please note that although we require customers who use our services, such as employers seeking to recruit staff, to agree to use the information made available solely for recruitment-related purposes, we do not control their use of any information that they have access to as part of receiving our services. Please be aware your current employer may be a customer of Hospitality Connect. Although it is a requirement of our Contract and Terms and Conditions of Hospitality Connect not to use Personal Information for any purpose other than to obtain a job, we cannot restrict the customers who access profiles on our database and cannot be held responsible for any eventuality. As part of the registration process Hospitality Connect offers you the option of remaining anonymous.

Who to contact about your Personal Information?

The data controller responsible for your information is Hospitality Connect.

If you have any questions about this policy or our use of your Personal Information you can email: dataprotection@hotelcareers.online

If you do not think we are handling your Personal Information adequately, you have the right to lodge a complaint with the Information Commissioner’s Office. Further information.

Changes to Privacy Policy

We review this Privacy Policy regularly and reserve the right to make changes at any time to take account of changes in our business and legal requirements. We will place updates on our website.

Please view the “Effective from” date at the top of these terms to see when it was last revised.

The Site is operated by Hospitality Associates International LLC (“We”, “Our” or “Us”). We are registered in Kenya certificate of incorporation No. C