Bullhorn Privacy and Cookies Policy
Version: April 12, 2018
This Privacy and Cookies Policy applies to all data collections and other data processing of Bullhorn, Inc., in particular through www.bullhorn.com and through its service platforms www.bullhornstaffing.com, https://bbo.bullhornstaffing.com, https://www.salesduel.com, and https://prod.vms-express.com (each referred to herein as a “Site”) owned and operated by it. For purposes of this Privacy Policy any reference to “Bullhorn” (or “our” or “us” or “we”) shall mean Bullhorn, Inc., Bullhorn, International Limited, Bullhorn International, Inc. and /or their subsidiaries, as applicable. This Privacy Policy describes how Bullhorn collects, uses, shares and safeguards the personal information (or in the EU/Switzerland: “personal data”) you provide to us. It also describes your choices regarding use, access and correction of your personal information. The use of information collected through our service shall be limited to the purpose of providing the Bullhorn Service (“Service”) for which the customer has engaged Bullhorn as set out in the Master Subscription Agreement, Terms of Service, and other agreements with the customer and this Privacy Policy.
Bullhorn, Inc. participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. Bullhorn, Inc. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield programs, and to view our certification, please visit https://www.privacyshield.gov/. Bullhorn, Inc. is committed to subjecting all personal data it receives from data exporters in any European Union (EU), Switzerland or European Economic Areas (EEA) member state, under the Privacy Shield Framework, to its applicable Privacy Shield Principles. To learn more about the Privacy Shield Framework and the Privacy Shield Principles, please visit the U.S. Department of Commerce’s Privacy Shield website at https://www.privacyshield.gov.
Bullhorn, Inc. is responsible for the processing of personal data it receives from data exporters under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Bullhorn fully complies with the Privacy Shield Principles. The Company adheres to the Privacy Shield Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access and recourse, and enforcement and liability as described in more detail in our “Commitment to the Privacy Shield Principles” in Section 14 below. With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Bullhorn, Inc. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Bullhorn, Inc. may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Under certain conditions which are more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may be entitled to invoke binding arbitration for an unresolved dispute you may have with us.
2.1. We collect the following categories of personal information from our customers, customers’ candidates and Site visitors:
2.2. We use the personal information collected from these individuals only for the following purposes:
2.3. We will only share your personal information with third parties (our agents) in the ways that are described in our customer agreements and this Privacy Policy. We do not sell your personal information to third parties.
2.4. We may email information regarding updates to the Service or additional service offerings to our customers in accordance with the terms and conditions of each customer’s agreements with us.
2.5. Other third parties, such as content or third party service providers, may provide content or services through the Service and may need access to your personal information to provide their services to you. Customers will be using a Service to host data and information. Bullhorn will not use or disclose your personal information, except (i) to the extent necessary to provide the Service to you or as requested by you, or (ii) pursuant to law, as determined by Bullhorn in its sole discretion, or (iii) by a court order, or (iv) as described in Section 3.3.5 of this Privacy Policy. Individual customer or customer candidate records may at times be viewed or accessed by Bullhorn’s authorized employees or agents only for the purpose(s) of (i) providing the Service and related professional services to customer or customer candidates, (ii) resolving a support issue affecting any of them, (iii) to inspect and resolve a suspected violation of customer agreements with a customer, or (iv) as may be required by law, as determined by Bullhorn in its sole discretion, judicial proceeding, subpoena, legal process or binding court order. We also reserve the right to disclose your personal information as required by law and when we believe, in our sole discretion, that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, subpoena, binding court order, or legal process.
2.6. Personal information may be disclosed or distributed to another party with which Bullhorn enters, or may enter, into a corporation transaction. If Bullhorn is acquired in a merger, acquisition, or sale of all or substantially all its assets, you will be notified via email, on our Site and/or by a prominent notice on our Service of any change in the uses of your personal information, as well as any choices you may have regarding your personal information. In the unlikely event of a bankruptcy, insolvency or liquidation, the database containing personal information may be treated as an asset of Bullhorn and may be subject to transfer to a third party.
2.7. Bullhorn may disclose personal information to companies that assist us in providing our Services or that partner with us to provide you their services or content. In this context, any such transfers to third parties are governed by our vendor agreements with them, which provide standards of care for the protection for personal and confidential information that are not less stringent than the standards contained in our customer agreements, and in no event, less than a reasonable standard of care. Such third-party companies are authorized to use your personal information only as necessary to provide these services to us and/or you and for the purposes for which the personal information were collected. In the case of partners with whom you contract directly, their policies regarding personal information will govern your relationship with them as stated in the applicable agreement between you and the partner and we will not be responsible for any actions or omission of these partners.
2.8. Customers are solely responsible for maintaining the confidentiality and security of their user registration and password. Customers or Site visitors may opt-out of receiving advertisement or promotional emails from us by selecting the opt-out link located in the message body of all our electronic communications. Customers or Site visitors may also email privacy@bullhorn.com directly with a request to be removed from such communications. We may also track and analyze information that doesn’t directly identify you as a person and aggregate usage and volume statistical information from our Site visitors, candidate customers and customers and provide such information in aggregated form to third parties.
2.9. We are a service provider to our customers and have no direct relationship with the customer candidate or any individual whose personal information a customer processes. If you are a candidate or individual of one of our customers and would no longer like to be contacted by a person or entity that uses our Service, please contact the customer that you interact with directly. If you are a customer and would like to update your account, please contact us at privacy@bullhorn.com.
2.10. Marketing: Bullhorn may also ask visitors who register for the Bullhorn Community, to provide certain information, such as email addresses to use and receive content from the site. Bullhorn will provide these visitors with the ability to opt-in or opt-out of future communications from the company. If you would like to discontinue receiving this information, you may update your email preferences by using the “Unsubscribe” link found in emails we send to you or at your member profile on our Site or by contacting us at privacy@bullhorn.com.
3.1. Technologies such as cookies or similar technologies are used by Bullhorn and our partners, affiliates, or our service providers. These technologies are used in analyzing trends, administering the site, tracking users' movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
3.2. Log in files: We gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream data, the files viewed on our site (e.g., HTML pages, graphics, etc.), to analyze trends in the aggregate and administer the Site. We do link these automatically-collected data sets to personal information of you that we may have already stored.
3.3. Cookies: We use cookies to remember users' settings (e.g. language preference), and for your authentication when you visit the Site or use the Service, as the case may be. The following information will help you to understand the different types of cookies used:
3.3.1. Strictly necessary cookies are required for the operation of the Site. These include, for example, cookies which are necessary for users to create an account or login to secure areas of the Site, and cookies that are required to show error or success messages to users.
3.3.2. Session cookies containing encrypted information to allow the system to uniquely identify you while you are logged in. Session cookies exist only during an online session. They disappear from your computer when you close your browser software or turn off your computer. This information allows Bullhorn to process your transactions and requests. Session cookies help us make sure you are who you say you are after you’ve logged in and are required to use the Bullhorn application.
3.3.3. Persistent cookies that only Bullhorn can read and use, to identify the fact that you are a Bullhorn customer or a visitor, who has registered for the Bullhorn Community, to identify and maintain your preferences such as language, country and last check out or to receive certain types of content. Persistent cookies remain on your computer after you’ve closed your browser or turned off your computer. They include such information as a unique identifier for your browser. We are especially careful about the security and confidentiality of the information stored in persistent cookies. For example, we do not store account numbers or passwords in persistent cookies. Users or visitors who disable their Web browsers’ ability to accept cookies will be unable to use all aspects of our service or the Bullhorn Community.
3.3.4 Targeting cookies which store a user’s username, the referring user if using the referral network and the referral source to the Site.
3.3.5. The following third party cookies could be used:
Please note that other third parties may also use cookies. These cookies are likely to be analytical/performance cookies or targeting cookies and include, for example, those from advertising networks or providers of external services.
3.4. Opt-out: You can control the use of cookies at the individual browser level. If you reject cookies, you may still use our Site, but your ability to use some features or areas of our Site may be limited. Many browsers allow a private mode to be activated through which the cookies are always erased after the visit. Depending on each browser, this private mode can have different names. The following is a list of the most common browsers that support the minimum recommended level of encryption TLS 1.2. Each browser type has a different name for “private mode”:
3.5. Targeted Advertisement: We partner with third parties to either display advertising on our Site or to manage our advertising on other sites. Our third-party partners may use cookies or similar technologies to gather information about your activities on this Site and other websites to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking http://preferences-mgr.truste.com (or if located in the European Union click or http://www.youronlinechoices.eu). Please note this does not opt you out of generic ads. You will continue to receive generic ads.
3.6. Social Media (Features) and Widgets: Our Site includes social media features, such as LinkedIn. These features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy statement of the company providing it.
3.7. Blogs: Our Site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at privacy@bullhorn.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. Alternatively, if you used a third-party application to post such information, you can remove it, either by logging into the application and removing the information, or by contacting the appropriate third party application.
4.1. Upon request and within 45 days, Bullhorn will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. In addition, Bullhorn will take reasonable steps to permit customers to correct, amend, or delete their personal information. To request this access, please contact privacy@bullhorn.com.
4.2. We may retain your information for as long as your account is active or as needed to provide you with our Services, comply with our contractual and/or legal obligations, resolve disputes and enforce our agreements.
Bullhorn acknowledges that you have the right to access your personal information. In most cases, Bullhorn has no direct relationship with the individuals whose personal information it processes. We recommend that an individual who seeks access, or who seeks to correct, amend, or delete personal information should direct his query to the Bullhorn's customer (the data controller). If requested to remove data by our customer, we will respond within 45 days. Individuals may also submit such inquiries or requests directly to Bullhorn at no cost for them by contacting privacy@bullhorn.com.
We will retain personal information we process on behalf of our Customers for as long as needed to provide Services to our customer and as required under customer agreements. We will also retain this personal information as necessary to comply with our legal and/or contractual obligations, resolve disputes, and enforce our agreements. When the purpose for which Bullhorn is processing, the personal information is fulfilled, expires or is terminated, Bullhorn will, upon request, provide our customers with a copy of their personal information stored by us, and Bullhorn will then either delete or pseudonymize any remaining personal information in accordance with our customer agreements.
Bullhorn employs reasonable and appropriate security measures to protect against the loss, misuse, and alteration of the personal information it processes. When the Service is accessed using Microsoft Internet Explorer versions 8.0 or higher, Transport Layer Security (TSL) technology protects information using both server authentication and data encryption to help provide that personal information is safe, and secure while in transit. Bullhorn also implements an advanced security method based on dynamic data and encoded session identifications, and hosts the Service in a secure server environment that uses a firewall and other advanced technology to protect against interference or access from outside intruders. Finally, Bullhorn provides individual usernames and passwords that must be entered each time a customer logs on. These safeguards help protect against unauthorized access, maintain data accuracy, and provide for the appropriate use of personal information. Nevertheless, no method of transmission over the Internet, or method of electronic storage, is one hundred percent (100%) secure, however. Therefore, we cannot guarantee absolute security. If you have any questions about security on our Service, please contact us at privacy@bullhorn.com.
We may retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements.
Our Service includes links to other Web sites whose privacy practices may differ from those at www.bullhornstaffing.com and https://bbo.bullhornstaffing.com. If you submit personal information to any of these sites, your information is governed by the applicable third-party’s privacy policies and we are not responsible for it. We therefore encourage you to carefully read the privacy policy of any Web site you visit and raise questions directly with these other providers.
We do not knowingly collect information from minors. To use the Site, you must be the age of legal majority in your place of residence. By using the Site, you hereby represent that you are at least the age of legal majority in your place of residence. We do not use an application or other mechanism to determine the age of users of the Site. All information provided to us will be treated as if it was provided by an adult. We will use commercially reasonable efforts to delete information associated with a minor as soon as practicable if we learn that a minor has submitted information about himself/herself to us.
California law permits California residents who provide us with personal information to request certain information regarding our disclosure of such information to third parties for their direct marketing purposes. We do not, at this time, disclose such information to third parties for their direct marketing purposes. If we change this policy, we will update this provision and provide instructions on how you may make a request for details
There are many methods where web browser signals and similar mechanisms can indicate your choice to disable tracking. But we may not be aware of or able to honor every such mechanism. Because there is not yet a common understanding of how to interpret web browser-based “Do Not Track” (DNT) signals other than cookies, we may not respond to undefined DNT signals to our Sites or online services. More information about “do not track” is available at www.allaboutdnt.org concerning such information.
The invalidity or unenforceability of any provisions of this Privacy Policy in any country shall not affect the validity or enforceability of any other provision of this Privacy Policy, which shall remain in full force and effect.
We may update this privacy statement to reflect changes to our information practices that will become effective upon posting. If we make material changes to this policy, we will notify you here, by email, or by means of a notice through the Service prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
Any questions or complaints concerning Bullhorn's Privacy Policy or handling of personal information can be directed to:
privacy@bullhorn.com or Office of Information Security & Compliance Bullhorn, Inc. 100 Summer Street 17th Floor Boston, MA 02110 Main Number: 1-617-478-9100
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Executive Vice President of Corporate Development and International
Peter oversees Bullhorn’s international operations outside North America in his role as Executive Vice President of Corporate Development and International. Peter joined Bullhorn in 2009 and was responsible for its highly successful UK launch and continued expansion internationally. Peter has grown the international team to over 100 staff, established Bullhorn as the UK’s market leading recruitment software and has expanded Bullhorn’s reach into EMEA and APAC, achieving a user base of more than 30,000 international users. Prior to taking on the launch of Bullhorn International, Peter spent 20 years working in the recruitment industry and held a number of senior director roles before moving into the technology space.