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Personal Data Processing Declaration

Effective as of April 14, 2025

Thank you for using the Jooble platform. We respect your privacy and are committed to providing transparent explanations of how your personal data is processed.

This Privacy Policy (hereinafter referred to as the "Policy") describes what personal data we collect, how we use it, to whom we may disclose it, and what rights you have regarding this data.

Ladoburn Europe LTD is the controller of your personal data when you use the Jooble platform (website or mobile version), hereinafter referred to as Jooble.

By personal data, we mean any information that directly or indirectly allows us to identify you as an individual, for example, your name, email address, phone number, IP address, workplace, resume data, and similar information.

What This Policy Covers and How to Use It

In this policy, we explain what personal data we collect, why it is necessary, how we store, transfer, and protect it, as well as what rights you have and how to exercise them.

We process your personal data only on the basis of appropriate legal grounds, in accordance with the legislation of the European Union (GDPR), the United Kingdom (UK GDPR), the United States (including California state laws), and Brazil (LGPD).

Legal Bases for Processing Personal Data

Below are the main legal bases on which the processing of your personal data is founded:

User Consent

Where necessary, we process your personal data based on your explicit consent. For example:

  • Sending personalised job recommendations;
  • Using your resume to generate recommendations;
  • Using cookies for analytics, retargeting, and personalised advertising (see Cookie Policy for details);
  • Sending promotional communications (email, SMS).

You have the right to withdraw your consent at any time without affecting the lawfulness of processing prior to withdrawal.

Legitimate Interest of the Company

We process your personal data when it is necessary for the pursuit of our legitimate interests, provided this does not override your rights and freedoms. For example:

  • Sending updates to Terms of Use or changes to services;
  • Ensuring cybersecurity and preventing fraud;
  • Conducting analytics on Platform usage;
  • Sending communications about similar services to customers.

Performance of Contract

Your personal data may be processed to perform the terms of a contract with you or to take steps prior to entering into a contract, for example:

  • Account registration;
  • Processing paid subscriptions or orders;
  • Sending your resume to employers;
  • Storing job search history.

Legal Obligation

In certain cases, we have a legal obligation to process your personal data. For example:

  • Maintaining records of financial transactions;
  • Retaining access registration logs;
  • Complying with the requirements of government authorities or courts.

Processing on Behalf of Third Parties

In certain cases, Jooble acts as a data processor rather than a data controller. This applies, for example, to situations where:

  • Data is transferred to us by partners (e.g., job search websites or ATS systems);
  • We act on behalf of a third party that has your authorisation for the transfer.

In such cases, processing is governed by the contract between you and that third party, and Jooble undertakes to comply with processor requirements under GDPR / UK GDPR / LGPD.

If you provided personal data through a third-party platform that uses Jooble to process data, any requests (such as access, correction, or deletion of data) should be sent directly to the relevant data controller (the third party). We will provide you with their contact information upon request if necessary.

In exceptional circumstances, where possible and necessary, Jooble may assist you in exercising your rights, provided that the data controller agrees.

We may transfer your personal data to subcontractors who assist us in providing services. Such transfers are carried out in accordance with agreements with the data controller and fully comply with applicable data protection legislation.

Jooble retains personal data that it processes on behalf of a controller only for the period specified in the agreement, or as necessary to fulfil legal obligations, resolve disputes, or ensure contract compliance.

Note regarding US laws (CPRA/CCPA):

Under US state legislation, we may rely on "Business Purpose" as a lawful basis for processing if:

  • It is necessary to provide the services that you have requested.
  • We act as a Service Provider.

You have the right to opt out of the sale or sharing of your personal data, as described in the relevant section "Additional Information for California (US) Residents"

To help you find the information you need, here is a list of the main sections:

  1. What Data We Collect and Why
  2. Processing of Data of Minor Users
  3. Sign-in Through Google and Other Accounts.
  4. How We Use Cookies, Trackers, and Analytics
  5. To Whom and Under What Circumstances We Transfer Your Data
  6. Engaging Service Providers and Cross-Border Data Transfers
  7. Personal Information Retention Period
  8. How We Protect Your Personal Data
  9. What We Do with Anonymised or Aggregated Data
  10. Your Rights and Choices
  11. How We Update This Policy
  12. How to Contact Us Regarding Privacy

We encourage you to read this policy carefully. If you disagree with its provisions, please do not use our platform.

1. What Data We Collect and Why

Jooble collects personal data in three main ways:

  • You provide it to us directly (for example, during registration);
  • We obtain it automatically from your device during interaction with the platform.
  • In some cases, from external providers if you have given consent (for example, when signing in through Google).

We describe these categories below, along with the corresponding legal bases that enable us to process your data in accordance with the GDPR and other applicable data protection laws.

1.1. Data You Provide Directly

During registration or profile creation:

  • Name, surname, email, password, phone number, city/country of residence
  • Date of birth, gender (if added to profile or resume)
  • Resume, work experience, education, skills, social media profiles, photo, citizenship

While using the service:

  • Creating a resume through our builder or uploading a ready CV
  • Responses to questionnaire questions posed by employers when submitting applications

Communication:

  • Support service requests
  • Participation in marketing surveys (optional)
  • Feedback requests for service improvement

Notification settings:

  • Email for job vacancy newsletter subscription (with consent)

If you do not provide the personal data necessary for us to provide our services (for example, an email address for creating an account), we will be unable to enter into or perform a contract (or provide the relevant platform functions). In such cases, we may be forced to decline providing the relevant service.

We do not request or require the provision of special categories of personal data (for example, about your health, racial or ethnic origin, religious beliefs, or sexual orientation). Please refrain from providing us with such information unless it is directly required by the service functionality.

1.2. Data We Collect Automatically

During your interaction with the Jooble platform, we automatically collect technical and behavioural data from your device. This occurs to ensure the platform operates correctly and securely, as well as for analytics and marketing purposes.

We typically collect:

  • Your IP address;
  • Browser type, version, and characteristics;
  • Device type and model;
  • Operating system;
  • Browser or system language;
  • Approximate geolocation (based on IP);
  • Pages you visit on our platform;
  • Time spent on pages;
  • Your clicks, job views, and application submissions;
  • URL from which you arrived.

This data is collected using cookies, analytics services, and third-party pixels, including Google Analytics, Hotjar, Meta Pixel, and other analytics and retargeting tools.

We use this data for the following purposes:

  • Analytics and Platform Improvement: Analysing which pages are most useful, where problems occur, how we can improve UX/UI, filters, and job relevance.
  • Security and Stability: Detecting suspicious activity (bots, spam), protecting servers, and preventing abuse.
  • Personalised Content and Recommendations: Based on your behaviour (for example, viewed jobs), we can provide relevant suggestions.
  • Marketing and Advertising (with your consent): Using Meta Pixel and other tools to show you advertising related to your interests. You can always opt out or change cookie settings in the banner. For more details about cookies, types, and retention periods, please see our Cookie Policy.

1.3. Data We Obtain from Third-Party Sources

We may obtain certain information about you from external providers with whom Jooble collaborates in providing services. This occurs only when such transfer is technically necessary, agreed upon by contract, or you have given explicit consent.

Notifications and Service Emails

To send confirmations, service changes, or updates, we may use email services that act as processors and send system emails on behalf of Jooble. We do not receive feedback about you beyond what was provided during registration.

Payments (for Paid Services)

If you use paid features, payment processing is handled by an external provider. Jooble does not store or process payment cards directly. From the provider, we may receive only basic transaction information: buyer's name and email, billing address (if applicable), transaction ID, date and amount.

Payment providers act as separate personal data controllers, so for complete information, we recommend reviewing their privacy policies (for example, Stripe, PayPal, Google Pay, Apple Pay).

Jooble may receive limited information from partner sources—only if you initiated such interaction yourself, agreed to the transfer, or if it is necessary for service functionality.

Marketing Communications

In cases where you have agreed to receive marketing materials from Jooble, our verified partners (for example, email platforms or job advertising agencies) may transfer lead data or information about your interaction with them, such as:

  • Email address
  • Jobs that interest you
  • Pages from which you arrived
  • Search region or category

This information is used so we can send you relevant recommendations (for example, job collections) or analyse the effectiveness of marketing campaigns.

Targeted Advertising

We may collaborate with advertising platforms (for example, Meta, Google Ads) to show personalised job advertisements or Jooble features. Within this framework, we may (with your consent) use:

  • Cookies, IP address, device type;
  • Information about which jobs you viewed;
  • Data provided by advertising platforms (for example, if you were already subscribed to our campaigns).

You can always change or withdraw your consent through the cookie banner or in your profile settings.

Does Jooble Sell Your Data to Third Parties?

No. We do not sell, transfer, or exchange your data with advertising brokers or other companies. Candidate data may only be transferred to:

  • The employer for whose vacancy you applied.
  • A job aggregator through which you initiated the application.

1.4. Other Purposes for Which We May Use Your Data

In addition to core functions (registration, job applications, connecting with employers), we may process your personal data for the following purposes:

Platform Improvement

We continuously analyse how users interact with the Jooble website to improve functionality, search efficiency, recommendation logic, and application convenience. In some cases, these processes may also include the use of anonymized or aggregated data for testing new features (including those based on automation or AI).

We may apply machine learning or other artificial intelligence (AI) tools to provide job recommendations, personalise search results, or provide feedback on your resume. These actions are performed only with your consent, which you can withdraw at any time.

Security, Stability, and Monitoring

We may process your personal data for internal audit purposes, compliance assessment with company policies, and ensuring the effective operation of our infrastructure. We may process technical and profile data to detect bots, spam, suspicious activity, or violations of terms of use. This includes:

  • Monitoring system logins;
  • Analysing behavioural patterns;
  • Protecting users from abuse.

Compliance with Legal Requirements

If Jooble receives an official request (for example, from a government authority, court, or regulator), we are obligated to review and, if necessary, provide the relevant information.

Business Analysis and Statistics

We may use your data in aggregate or de-identified form for:

  • Analysing job popularity;
  • Studying behavioural patterns;
  • Evaluating marketing campaigns;
  • Strategic planning for service improvement.

We may transfer anonymised and aggregated data to third-party companies under licensing agreements, for example, for market analysis, improving our services, or researching employment trends.

2. Do We Collect Data from Minors?

The Jooble platform is not intended for use by persons under 16 years of age or any other age of majority established by applicable law in your country. We do not knowingly collect personal data from persons under the age of majority and do not transfer such data to third parties.

We recommend that parents and legal guardians monitor their children's digital activity to prevent accidental entry or transmission of personal data on the site without their involvement.

If you believe that your child has registered on the Jooble platform and provided personal data without your consent, please contact us immediately at: [email protected]

We will promptly delete or de-identify this data in accordance with applicable law.

3. Google Sign-In

The Jooble platform allows you to simplify the registration or sign-in process by using your Google account. If you choose this option, we will receive only basic public information from your Google profile, namely:

  • Your name (first name or full name, depending on settings);
  • Your email address.

This data is used exclusively for:

  • Creating a Jooble account;
  • Authorization;
  • Identifying you as a user.

Jooble does not have access to your password, search history, contacts, or any other elements of your Google account. We do not transfer this data to any third-party companies and use it exclusively in accordance with this Policy.

Please note: Jooble does not control and is not responsible for how Google or any other social media platform processes your personal data. We recommend reviewing Google's Privacy Policy to learn how they collect and use your data.

4. Use of Cookies and Tracking Technologies

Like most online services, Jooble uses cookies and similar technologies (for example, pixels or web beacons) to:

  • Ensure platform operation;
  • Store your preferences;
  • Analyse how you use the site;
  • Improve personalisation;
  • Show advertising that may genuinely interest you.

What Cookies Do We Use?

We apply several categories of cookies:

  • Essential (Required): Necessary for basic site functions (sign-in, navigation, security). Always enabled.
  • Analytics: Help us understand how users interact with the platform (using tools like Google Analytics and Hotjar).
  • Marketing/Advertising: Used to show personalised advertising (Meta Pixel, Google Ads, etc.).

How Can You Manage Cookies?

When you first visit the site, you see a cookie banner where you can:

  • Accept all categories.
  • Decline optional cookies;
  • Configure your choice manually.

You can also change your choice at any time in cookie settings or through your browser. For more information about cookie types, their retention periods, and your options, please refer to our Cookie Policy.

Do We Support "Do Not Track" (US Only)?

Some browsers and mobile devices support the "Do Not Track" (DNT) feature, which allows users to signal to websites that they do not want their online activity to be tracked. However, currently:

  • There is no unified technical standard that regulates how websites should respond to such signals.
  • The Jooble platform does not yet support automatic processing of browser DNT signals. We continue to monitor developments in standards in this area and will update this policy as needed.

5. How We Transfer Your Personal Data

Jooble does not sell or transfer your personal data to advertising brokers or third-party marketing platforms without your explicit consent. We transfer data only when necessary to provide services or as required by law.

To Whom We May Transfer Data:

5.1. Service Providers (Data Processors):

We collaborate with trusted external companies that help us operate efficiently. These may include:

  • Hosting providers;
  • Analytics platforms (Google Analytics, Hotjar);
  • Email services (for sending messages, for example, about new job openings);
  • Advertising platforms (Meta, Google Ads);
  • Technical integrators (API connections with ATS/CRM);
  • Secure authorisation providers (Google Login);
  • Personalisation or A/B testing tools.

All these partners operate under contract and have no right to use your data for any purpose other than as specified in their contract.

5.2. Employers and Third-Party Job Aggregators:

We may transfer your resume, application form, cover letter, or other information only to those employers or platforms to which you submit applications.

Transfer may occur via email or through API integration with their systems (ATS/CRM). Each employer or platform receives data only through your direct action and consent. We enter into appropriate confidentiality and processing agreements (DPA) with such parties.

After transferring your data to such parties, they may act as separate controllers. This means they are independently responsible for further processing of your personal data.

If you submitted an application through Jooble and subsequently requested to delete your profile or resume, we will make all reasonable efforts to notify the relevant employer or platform to which your data was transferred about your deletion request. However, we cannot guarantee complete or timely deletion on their part, as Jooble has no technical or legal control over external resources.

Therefore, we also recommend contacting that party directly if you wish to withdraw your consent, delete your data, or exercise other rights provided by data protection legislation.

5.3. As Required by Law:

In the event of receiving a substantiated legal request (for example, from a court, government authority, or regulator), we may transfer personal data in accordance with applicable legislation. In such cases, we try to limit the scope of data to the minimum necessary.

5.4. In Case of Change of Ownership:

If Jooble is fully or partially acquired, merged, or reorganised, we may transfer your personal data to the new legal successor.

6. Processors and International Data Transfers

Jooble engages external service providers (data processors) who help us ensure platform operation, process requests, deliver emails, provide analytics, hosting, and more.

We enter into Data Processing Agreements (DPAs) with such providers who process personal data on our behalf. This ensures that processing occurs exclusively according to our instructions, with compliance to security, confidentiality requirements, and your rights as a user.

Data Transfers Outside the European Economic Area (EEA)

Since some of our partners (for example, hosting services, analytics, or email services) are located outside the EU/EEA, personal data may be transferred to countries where the level of data protection may differ from European standards.

We transfer data outside the EEA only in cases where:

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  • There is an adequacy decision from the European Commission — for example, for countries such as Switzerland, the United Kingdom, Canada (for commercial organisations), and Japan, among others.
  • If personal data is transferred to countries not recognised as providing adequate data protection, we implement appropriate safeguards, including entering into Standard Contractual Clauses (SCCs), or other permitted mechanisms (for example, UK IDTA or additional safeguards in accordance with Schrems II).
  • You have provided explicit consent for such transfer, in cases where other legal mechanisms are not applicable.

7. How Long Do We Retain Your Data

We retain personal data only for the time necessary to achieve the purposes defined in this Policy, or in accordance with your consent or legal requirements.

Main Retention Periods

User profile, resume, viewing history, and submitted applications are retained for up to 36 months from the last activity in your account. If you do not access the platform during this time, your account may be automatically deactivated, and your personal data may be deleted or anonymised.

Exceptions

We may retain certain data longer if it is:

  • Required by tax, accounting, or other legislation;
  • Necessary for protection against legal claims (for example, in case of disputes, requests from regulatory authorities);
  • Related to paid services for which the law requires document retention.

If you provided consent for CV data processing, we retain it until you withdraw your consent, unless otherwise required by law.

8. How do we ensure the security of your data

Jooble pays special attention to the security of your personal data. We apply comprehensive technical and organisational protection measures that comply with international and European data protection legislation requirements (including GDPR and UK GDPR).

What We Do to Protect Data

  • Use encryption of transmitted data (HTTPS, SSL/TLS);
  • Protect databases and infrastructure using firewalls, antivirus, and intrusion detection systems;
  • Implement access restrictions to personal data (only authorised employees);
  • Regularly conduct security audits and vulnerability testing;
  • Store data on cloud platforms that have appropriate security guarantees.

We assess all risks associated with processing and adapt protection according to:

  • Nature of data;
  • Processing volumes;
  • Technical capabilities and implementation costs;
  • Probability and consequences of violating your rights.

Security on Your Part

To ensure an additional level of protection, please:

  • Use a strong password;
  • Do not share login credentials with third parties.
  • Log out of your account after completing sessions, especially on shared devices.

If you suspect your account has been compromised or notice suspicious activity, please contact us immediately at: [email protected]

De-identified and Aggregated Data

What is De-identified Data?

This is data that:

  • Does not contain name, email, IP, or user identifier;
  • Cannot reasonably be used to determine who it belongs to;
  • It is used for statistical, technical, or research purposes.

Jooble may anonymise or aggregate certain data. Jooble does not perform any actions aimed at re-identifying users from such data.

How We Use Such Data:

  • To improve platform functionality, conduct technical analysis, or ensure service security. Such data does not allow identification of specific individuals and is not considered personal under applicable data protection legislation.
  • For user behaviour analytics (without personal attribution);
  • For testing new features;
  • For improving platform stability and security;
  • For internal reports and service efficiency evaluation.

9. Your Rights and Choices Regarding Personal Data

Jooble respects your right to privacy and ensures that you can exercise all legally provided rights regarding your personal data. These rights may vary depending on the country where you are located; however, we ensure the implementation of the following fundamental rights:

Right to Access and Information: You have the right to obtain information about:

  • What specific personal data do we collect about you
  • With which third parties this data may be shared;
  • for what purposes the processing is carried out.

Right to Rectification: You may independently update or modify your personal data in your account or contact us with a request to correct inaccurate or incomplete data.

Right to Data Portability: You have the right to receive your personal data in a machine-readable format (e.g., CSV, JSON) or to transfer it to another controller. This can be done by submitting a request to email: [email protected]

Notice of Rectification or Deletion: You may submit a request for correction or complete deletion of your profile and all associated personal data. Please note: some data may be retained longer if required by:

  • law (tax documents, complaints, etc.);
  • protection against potential legal claims;
  • fulfilment of prior contractual obligations.

Right to Restriction of Processing: You may demand temporary cessation of processing your data if:

  • You contest their accuracy;
  • The processing is unlawful;
  • The data is no longer needed by us, but is needed by you for the protection of rights.

We notify all recipients of your personal data about any rectification, deletion, or restriction of processing, if technically feasible and does not require disproportionate efforts. However, we cannot guarantee that every such recipient will fulfil this request in full, as we have no control over their internal processes or legal obligations.

Right Not to Be Subject to Solely Automated Decision-Making Jooble does not apply fully automated decision-making mechanisms (including candidate selection) that could have legal consequences for you without human involvement.

Right to Object You have the right to object to data processing based on the company's legitimate interests, including use for marketing purposes. We will cease processing if we do not have compelling legitimate grounds to continue it.

Right to Withdraw Consent If you have provided consent (for example, for email communications), you may withdraw it at any time through:

  • settings in your personal account;
  • the "Unsubscribe" link in the email;
  • or by sending an email to [email protected]

Withdrawal of consent does not affect the lawfulness of processing that was already carried out prior to that moment.

Opt-Out from Sale or Profiling (for US Residents) Jooble does not sell personal data to third parties, does not transfer it to advertising brokers, and does not conduct behavioural profiling for advertising purposes.

No Discrimination Jooble does not discriminate against users who exercise their rights, specifically:

  • does not deny services;
  • does not change the cost or quality of services;
  • does not impose restrictions or penalties due to the exercise of user rights.

10. How to Submit a Request to Exercise Your Rights

You can exercise your rights regarding personal data by submitting a request through one of the following methods:

  • Email: Write to us at [email protected]. In the email, please specify:
    • Your full name;
    • the email address associated with your registered account;
    • The nature of your request (for example, "delete my profile," "obtain a copy of data," "unsubscribe from mailing list").
  • Postal Address: Ladoburn Europe LTD (Jooble) Arch. Makariou III, 205 VICTORY HOUSE, Flat/Office 212, 3030, Limassol, Cyprus (marked "Data Privacy")

To protect your data, we may request additional information to verify your identity, such as your first and last name, email address associated with the account, and other verification details (e.g., date of last login). This is necessary to ensure that data will not be provided or deleted upon request from an unauthorised person.

Requests from Authorised Representatives You may authorise another person (for example, a lawyer or relative) to submit a request on your behalf. In such cases, we may require confirmation of your identity and documentary evidence of the representative's authority.

Response Time for Requests: We will provide a response to your request within one calendar month from the date of its receipt. If your request is complex or the volume of data is substantial, the timeframe may be extended by an additional month; however, we will notify you of this in advance.

Cost of Request Processing: Processing requests for exercising your rights is free of charge. However, in cases of repeated, excessive, or clearly unfounded requests, we reserve the right to charge a reasonable administrative fee or refuse to process the request.

Account Settings and Communication Preferences

Updating or Deleting Profile Data: Jooble users can independently correct or delete personal data in their profile. Log in to your account settings on our platform.

You can edit, supplement, or delete any information you previously provided. It is your responsibility to ensure the relevance and accuracy of the data you maintain in our system.

Please note that some personal data cannot be immediately deleted if we are required to retain it in accordance with applicable legislation (for example, to fulfil financial, tax, or legal obligations). After the completion of the respective retention period, we will delete or anonymise this data in accordance with our policy.

Unsubscribing from Mailings If you have agreed to receive email newsletters about news, services, updates, or job vacancies from Jooble, you can change your choice at any time by clicking "Unsubscribe" at the bottom of any of our emails or accessing your profile settings and disabling the respective mailing list.

In such cases, we may still send you important service notifications related to account security or service provision (for example, action confirmations, changes in terms, etc.).

SMS Messages Jooble does not send marketing SMS or messenger notifications. SMS may be used only for one-time authentication (2FA) if you provided your own phone number during login or account creation.

Notice for California Residents (Shine the Light) In accordance with California's "Shine the Light" law (Section §1798.83 of the Civil Code), California residents have the right to:

  • learn whether we transfer their personal data to third parties (non-affiliated companies) for direct marketing;
  • withdraw previously given consent for such transfer.

Jooble does not transfer personal data to third parties for their own marketing purposes without your direct consent.

If you are a California resident, you may: submit a request for information about compliance with the "Shine the Light" law or withdraw previously given consent.

To do this, please contact us through one of the methods specified in the section "How to Submit a Request to Exercise Your Rights," and be sure to include in the subject line or body of the email the phrase: "California Direct Marketing Privacy Request." We are obligated to respond to such requests no more than once per year per user, and only through the specified official channels (email or postal address).

11. Updates to This Policy

We reserve the right to update this Privacy Policy from time to time. The date of the last update is always indicated at the top of the document.

Updates take effect from the moment of their publication, unless otherwise explicitly stated. If we make significant changes, we will notify you through a notice on our website or via email, if you have provided an email address in your settings.

We recommend periodically reviewing this Policy to stay informed of current changes regarding the processing of your personal data.

12. How to Contact Us

If you have questions, comments, or wish to exercise your rights regarding personal data, contact us: Email for privacy inquiries: [email protected] We respond to requests as quickly as possible, but no later than within one calendar month.