We respect the privacy of everyone who visits this website https://onecirclehr.com/. As a result we would like to inform you regarding the way we would use your Personal data. We recommend you read this Privacy Notice so that you understand our approach towards the use of your Personal data. By submitting your Personal data to us, you will be treated as having given your permission – where necessary and appropriate – for disclosures referred to in this notice. By using this web site https://onecirclehr.com/, you acknowledge that you have reviewed the terms of this Privacy Notice and Consent to Use of Personal data (the “Privacy Notice and Consent”) and agree that we may collect, use and transfer your Personal data in accordance therewith.
If you do not agree with these terms, you may choose not to provide any personal data, but this may impact on our ability to support you as a customer or supplier. This Privacy Notice and Consent forms part of our Terms and Conditions of Use and such shall be governed by and construed in accordance with the relevant laws. This Notice explains how we obtain, use and disclose your personal data, as is required by the General Data Protection Regulation. At One Circle HR we are committed to protecting your privacy impact and to ensure that your Personal data is collected and used properly, lawfully and openly.
2. Who we are
We are a technology platform connecting businesses directly with HR consultants virtually and on-demand.
3. The data we collect
Collection of Personal data
We collect and process your Personal data mainly to provide you with access to our services and products, to help us improve our offerings to you, to support our contractual relationship with you and for certain other purposes explained below. The type of data we collect will depend on the purpose for which it is collected and used. We will only collect data that we need for that purpose.
We collect data directly from you where you provide us with your personal details, for example when you purchase or supply a product or services to or from us or when you submit enquiries to us or contact us. Where possible, we will inform you what data you are required to provide to us and what data is optional.
Examples of data we collect from you are:
- email address
- telephone/cell number
- user-generated content, posts and other content you submit to our web site
We also collect data about you from other sources as explained below.
With your consent, we may also supplement the data that you provide to us with data we receive from other companies in our industry in order to offer you a more consistent and personalized experience in your interactions with One Circle.
If you are registering as a Consultant or a Company with One Circle, please see Appendix A which covers information relevant to you and the personal data you provide.
Collection of Non-Personal data
We may automatically collect non-Personal data about you such as the type of internet browsers you use or the website from which you linked to our website. We may also aggregate details which you have submitted to the site (for example, the products or services you are interested in). You cannot be identified from this data and it is only used to assist us in providing an effective service on this web site. We may from time to time supply third parties with this non-personal or aggregated data for uses in connection with this website.
4. Cookies policy
We use the term “cookies” to refer to cookies and other similar technologies covered by the GDPR & POPI Act (South Africa only) on privacy in electronic communications.
- What is a cookie?
Cookies are small data files that your browser places on your computer or device. Cookies help your browser navigate a website and the cookies themselves cannot collect any data stored on your computer or your files. When a server uses a web browser to read cookies they can help a website deliver a more user-friendly service. To protect your privacy, your browser only gives a website access to the cookies it has already sent to you.
- How are third party cookies used?
- How do I reject and delete cookies?
5. How we use your data
We will use your Personal and Non-Personal data only for the purposes for which it was collected or agreed with you, for example:
- Analyse the effectiveness of our advertisements, competitions and promotions
- Collect data about the device you are using to view the site, such as your IP address or the type of Internet browser or operating system you are using, and link this to your Personal data so as to ensure that the site presents the best web experience for you
- Evaluate the use of the site, products and services
- For market research purposes
- For monitoring and auditing site usage
- Help speed up your future activities and experience on the site. For example, a site can recognise that you have provided your Personal data and will not request the same data a second time.
- In connection with legal proceedings
- Make the site easier to use and to better tailor the site and our products to your interests and needs
- Offer you the opportunity to take part in competitions or promotions
- Personalise your website experience, as well as to evaluate (anonymously and in the aggregate) statistics on website activity, such as what time you visited it, whether you’ve visited it before and what site referred you to it
- Suggest products or services (including those of relevant third parties) which we think may be of interest to you
- To assist with business development
- To carry out our obligations arising from any contracts entered into between you and us
- To conduct market or customer satisfaction research or for statistical analysis
- To confirm and verify your identity or to verify that you are an authorised consultant or company for security purposes
- To contact you regarding products and services which may be of interest to you, provided you have given us consent to do so or you have previously requested a product or service from us and the communication is relevant or related to that prior request and made within any timeframes established by applicable laws.
- To notify you about changes to our service
- To respond to your queries or comments
- We will also use your Personal data to comply with legal and regulatory requirements or industry codes to which we subscribe or which apply to us, or when it is otherwise allowed by law.
- Where we collect Personal data for a specific purpose, we will not keep it for longer than is necessary to fulfil that purpose, unless we have to keep it for legitimate business or legal reasons. In order to protect data from accidental or malicious destruction, when we delete data from our services we may not immediately delete residual copies from our servers or remove data from our backup systems.
- You can opt out of receiving communications from us at any time. Any direct marketing communications that we send to you will provide you with the data and means necessary to opt out.
6. Disclosure of Personal data
We may disclose your Personal data to our business partners who are involved in the delivery of products or services to you. We have agreements in place to ensure that they comply with these privacy terms.
We may share your Personal data with, and obtain data about you from:
- Third parties for the purposes listed above;
- Other companies in our industry when we believe it will enhance the services and products we can offer to you, but only where you have not objected to such sharing;
- Other third parties from whom you have chosen to receive marketing data.
We may also disclose your data:
- Where we have a duty or a right to disclose in terms of law or industry codes;
- Where we believe it is necessary to protect our rights.
7. Personal data security
We are legally obliged to provide adequate protection for the Personal data we hold and to stop unauthorised access and use of personal data. We will, on an on-going basis, continue to review our security controls and related processes to ensure that your Personal data is secure.
When we contract with third parties, we impose appropriate security, privacy and confidentiality obligations on them to ensure that Personal data that we remain responsible for, is kept secure.
These arrangements may from time to time involve the holding or transfer of your personal data outside the European Union based on the legitimate interests of One Circle HR in terms of service provider agreements.
We will ensure that anyone to whom we pass your Personal data agrees to treat your data with the same level of protection as we are obliged to.
8. Access to your Personal data
You have the right to request a copy of the personal data we hold about you. To do this, simply contact us at the numbers/addresses listed on our Contact Us page https://onecirclehr.com/contact-us and specify what data you would like. We will take all reasonable steps to confirm your identity before providing details of your personal data.
Please note that any such access request may be subject to a payment of a legally allowable fee, as laid down in our GDPR & POPI Act (South Africa only) Policy.
9. Correction of your Personal data
You have the right to ask us to update, correct or delete your personal data. We will take all reasonable steps to confirm your identity before making changes to Personal data we may hold about you. We would appreciate it if you would take the necessary steps to keep your Personal data accurate and up-to-date by notifying us of any changes we need to be aware of.
10. Definition of Personal data
According to the POPI Act (South Africa only) ‘‘Personal information’’ means data relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person. The POPI Act (South Africa only), which has more specific examples if you need them, can be found at the following link: www.gov.za/documents/download.php?f=204368
For the definition of “Personal data” as used in the GDPR please see the text of the GDPR, Article 4 available from https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.L_.2016.119.01.0001.01.ENG&toc=OJ%3AL%3A2016%3A119%3ATOC
11. Retention of Personal data
One Circle HR will retain your data in compliance with the GDPR & POPI Act and in compliance with other applicable legislation.
12. Automated Decision Making
One Circle HR does not use Automated Decision Making in connection with your personal data.
13. Changes to this notice
Please note that we may amend this notice from time to time. Please check our website periodically to inform yourself of any changes.
14. Lodging a complaint
You are entitled to lodge a complaint with the data protection authority in your relevant European Union or European Economic Area state. The list of contacts is available at https://edpb.europa.eu/about-edpb/board/members_en
In South Africa please contact the Information Regulator South Africa at firstname.lastname@example.org or visit https://www.justice.gov.za/inforeg/index.html for more information.
15. How to contact us
If you have any queries about this notice or believe we have not adhered to it, or need further data about our privacy practices or wish to give or withdraw consent, exercise preferences or access or correct your personal data, please contact us at the numbers/addresses listed on our website https://onecirclehr.com/contact-us and the One Circle HR PAIA Manual found at https://onecirclehr.com/.
One Circle HR contact details: email@example.com
One Circle HR Data Protection Officer contact details:
Name: Emma El-Karout
Email address: firstname.lastname@example.org
APPENDIX: Obtaining consent from general users
One Circle HR collects personal data from when you register with us for business purposes. We will only use this data to carry out the processes for the purpose for which you registered with us. We will protect your personal data in accordance with our Privacy Notice and the provisions of the GDPR & POPI Act (South Africa only). If you agree, we will use your data to send marketing data to you.
One Circle HR will not share your personal data with external companies without your approval.
Personal data will be protected in accordance with the conditions contained in the GDPR.
For more data explaining how we use your personal data, please see our Privacy Notice available at https://onecirclehr.com/.
The specific details of the Personal data we process are contained in the One Circle HR online Consultant registration application form (https://onecirclehr.com/register) or Company registration application form https://onecirclehr.com/company/register. Failure to provide the personal data requested may result in One Circle HR not being able to provide you with the products or services requested.
You have the right to withdraw consent for the processing of your personal data at any time by sending a request to email@example.com
One Circle HR will ensure that you, as the data subject, are made aware of data being collected. If the data has not been collected directly from the data subject, the source of collection will be provided together with name and address of the party. The purpose of collection will be provided.
Data relating to the following will also be provided where relevant:
- Whether the supply of data by the data subject is voluntary or mandatory;
- The consequences of failing to provide data
- The legislation requiring the collection of data
- If data is to be transferred to another country, data relating to the laws that will protect the data.