Privacy Policy

Swipejobs LLC, and its subsidiaries, parents and affiliates (collectively, "Swipejobs", "we", "our", or "us") value your privacy. This Privacy Policy (the "Policy") describes how we may collect, use, store, disclose, and process your personal information, through your access to or use our websites (including https://www.swipejobs.com), apps and related online services (collectively, the "Services"). The Policy also explains how you can limit use of your personal information. The Policy describes your choices regarding use, access and correction of your personal information.

This Policy is incorporated into, and considered part of, the Terms of Service, and describes how we collect, use, and disclose personal information in connection with the Services. By using the Service, submitting information through the Service, or applying with Swipejobs, you acknowledge that your personal information will be processed as described in this Policy. Where applicable law requires a specific lawful basis for processing (including under the UK GDPR or EU GDPR), we rely on the bases described in the "Our Lawful Bases for Processing" section below, and not on consent bundled into these Terms.

Scope of this Policy

Swipejobs operates a real-time jobs exchange (the "Exchange"), part of the Services, that connects people looking for work with organisations that have work to fill. This Policy applies to Swipejobs LLC and its UK and other group affiliates, and covers the following participants, whose data we treat according to their role:

• Talent: individuals who register for an account on the Exchange to find and take up work. Where relevant, this Policy also refers to Talent as shift workers.
• Employers: organisations that enter into a relationship with Swipejobs to use the Exchange and / or receive Swipejobs services. Where relevant, this Policy also refers to Employers as Business Customers or Business Partners.
• Sourced Candidates: individuals whose publicly available professional information we have sourced to power our candidate-discovery product. Sourced Candidates are a separate, segregated group: they have no account, no relationship with us, and give no up-front consent. We process their publicly available professional data under our legitimate interests (see "Our Lawful Bases for Processing"), they can object or opt out at any time, and we keep their data segregated from Talent accounts and do not treat them as account holders.

Some parts of this Policy apply differently depending on where you live; those differences are noted in the relevant sections.

Our candidate-discovery product

Our candidate-discovery product operates as a discovery solution, helping Employers find and contact potentially relevant professionals from publicly available information. It is not an evaluation or scoring service; it does not rate, grade, or judge a candidate's suitability, and it does not make decisions about candidates.

To build and maintain this product, we collect professional information about Sourced Candidates from publicly available and lawfully obtained sources including publicly available professional profiles, company websites and press, public registries, and licensed third-party data providers. We collect only professional and occupational information and do not seek out special-category data from these sources.

If your professional information appears in our search results and you do not want it to, you can remove yourself at any time through the Privacy Center. You do not need an account with us, and you do not need to give a reason.

Information We Collect

The type of information we collect is dependent on how you use our service:

In general, we receive and collect all information you provide via the Services, including through website input fields (including advertisements), phone, email (including email campaigns), web chat, or in other such ways. This includes, but is not limited to, your full name, postal address, email address, telephone number, Social Security number, driver's license or passport, birth date, signature, credit card information, bank account information, username, and password. In addition, we may ask you to provide your job-related preferences, skills, hours of availability, certifications, transportation mode and interests and other information to set up your worker profile or Business profile. You have the choice on what information to share and the services you want to engage. You can choose not to provide information to us, but in general some information about you is required in order for you to access certain functionality of the Services, such as those mentioned above or for tracking your preferences, subscribing to a newsletter, or initiating other such actions.

Other information that users may specifically provide includes, but is not limited to, the content of emails, text messages, letters, phone calls, and comments you send, place, or post to Swipejobs or our employees, agents, affiliates, or representatives.

We may also obtain personal information and data about you through independent third parties, affiliated entities, and other users of the Service. For example, other users of the Service may provide us with information about you. This information helps us to update, expand and analyze our records. In addition, we may use this information to determine which employment opportunities may be a good match for you based on your skills, experience, or feedback from other users or other third parties. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.

In addition to your personal information described above, we may collect information automatically regarding your use of the Service, through means such as cookies, log files, web beacons, device identifiers, advertising identifiers and similar tracking technologies, including those from third-party service providers. This information includes but is not limited to, your IP address, browser, operating system, internet service provider, location, the type of cellular phone you use, unique device identifiers, and cellular service provider (collectively, "analytics information"). We may also collect and use information and statistics that describe the demographics, usage and/or characteristics of our users as part of the analytics information. In general, we do not use this analytics information to directly identify users of our services. The Services are not designed to recognize or respond to "do not track" signals received from browsers. You can control the information collected by such tracking technologies or be alerted when cookies are sent by adjusting the settings on your Internet browser or devices, but such adjustments may affect or disable certain functionality of the Services.

We expect you to provide accurate information to the best of your ability. However, we do not seek to collect any sensitive personal information such as information revealing sexual orientation, political opinions, religious or philosophical beliefs or trade-union membership. Please do not submit any such information.

• You may use the Exchange as Talent (also referred to as a job seeker or shift worker). This can mean we collect information needed to register and onboard you, verify your identity and run background or compliance checks, match and notify you of suitable jobs, keep you updated about those jobs, confirm your arrival at and departure from jobs, and coordinate payment to you for work performed.
• You may use the Exchange as an Employer (a Business Customer or Business Partner), which means we collect information needed to set you up on the Exchange, promote and fill your jobs with Talent, keep you updated about those jobs, and charge you for work performed.

Our Lawful Bases for Processing

Where the UK GDPR or EU GDPR applies, we process personal data only where we have a lawful basis. Consent bundled into our Terms of Service is not the basis on which we rely for that processing; instead, depending on the activity and the group, we rely on the following:

• Contract (Art. 6(1)(b)). To provide the Exchange and Services that Talent and Employers request and to administer their accounts and relationships.
• Legal obligation (Art. 6(1)(c)). To comply with laws that apply to us, such as tax, employment, right-to-work and records requirements.
• Legitimate interests (Art. 6(1)(f)). For our candidate-discovery product, we process the publicly available professional data of Sourced Candidates for the legitimate interests of helping Employers discover and engage potentially relevant professionals, and of operating and improving the product. We have weighed these interests against the rights and reasonable expectations of Sourced Candidates in a documented Legitimate Interests Assessment. Because the data is limited to publicly available professional information, is used to surface rather than to evaluate candidates, and is subject to the objection and opt-out rights described below, we consider these interests are not overridden by those rights. A Sourced Candidate may object at any time and use our opt-out and suppression mechanism in the Privacy Center or at privacy@swipejobs.com.
• Consent (Art. 6(1)(a) / Art. 9(2)(a)). For processing that requires it (including biometric identity verification and certain marketing) we rely on the explicit, freely-given consent of Talent or Employers, which may be withdrawn at any time.

How We Use It

We process your personal data only for the purposes described in this Policy and, where the UK GDPR or EU GDPR applies, only where we have a lawful basis (see "Our Lawful Bases for Processing"). Depending on the activity and your role, we process personal data to provide and improve the Exchange and Services, to comply with legal obligations, to protect vital interests, and for our legitimate interests as described in this Policy. We do not treat use of the Services as blanket consent to unrelated processing.

With respect to all users, we use the information we collect to provide, develop, test and improve our Service. We use analytics information we collect to track usage patterns so that we may enhance our Services and improve site navigation. We use this analytics information consistent with the purposes described in this Policy and applicable law, and may disclose it to service providers and other third parties as described in this Policy.

If you provide feedback on our services, we may use such feedback for any purpose, provided we will not associate such feedback with your personal information. We will collect any information contained in such communication and will treat personal information in such communication in accordance with this Policy.

AI-Assisted Sourcing, Automated Processing, and AI Governance

How candidate matching works

When an Employer runs a search, our product breaks the query into objective, observable match factors (for example, whether a talent or sourced candidate profile indicates work in the relevant area and prior experience in the searched job title). A profile is shown as matching a factor only where that factor is present, and results are ordered by the number of factors matched. This is a relevance ordering based on objective factors only, it does not score, rate, or evaluate a candidate's quality or suitability, and it does not filter candidates out on any other basis. We return a broad pool of matching professionals.

AI-assisted research

We offer optional, user-initiated research tools that can summarise or draw inferences from a matched professional's publicly available information. These run only when a human user requests them, and their outputs (with the underlying source material) are presented to that human user to review and validate. They are decision-support for a person, not automated decisions about the candidate.

No solely-automated decisions; AI governance

We do not use these features to make decisions producing legal or similarly significant effects on candidates without human involvement; hiring decisions are made by Employers, so Article 22 GDPR solely-automated decision-making does not apply. Where the EU AI Act applies to our AI functionality, Swipejobs acts as a provider of the relevant AI system and maintains its AI Act compliance materials (risk management, technical documentation, transparency and conformity steps) separately from this Policy as part of its AI governance program. For AI-system transparency information, contact privacy@swipejobs.com.

How We Share Your Information

Swipejobs may share your personal information with third parties and third-party service providers to provide specific services, such as performing background checks, processing payments, data analytics, hosting, storage and other infrastructure and providing support to you. The third parties may collect, store, or help us use personal information or analytics information, including, without limitation, in the ways described in this Policy. These third parties may have their own terms of use or privacy policies that may apply to you, and that describe how they collect, store, and use your personal information or analytics information. These terms of use, privacy policies, and practices by third parties are not described in this Policy.

We may also share portions of your personal information with other users of our services. For example, if you accept a shift through the Service, we may share your information with the Business Partner for communication purposes, confirming that you possess the skills necessary to complete the job you have accepted, or other similar bases.

Regardless of any choices you make regarding your personal information (as described below), Swipejobs may disclose personal information if it believes in good faith that such disclosure is necessary to:

1. In response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us;
2. When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, interests, or safety of our company or the Services, our Business, or others; or in connection with our Terms of Service and other agreements; or
3. In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

Location-Based Services

Swipejobs allows you to opt-in to Services that gather personally identifiable location-based information from your mobile phone. We use this information in providing our Services to you, for example to notify you of suitable jobs and to notify Swipejobs Business Partners when shift workers are arriving at or leaving the job site. We may receive updates to your location even when the Swipejobs application is running in the background. Changing your phone settings to prevent Swipejobs obtaining your location will limit our ability to notify you of suitable jobs.

Swipejobs may aggregate and use your location-based information for any legal purpose, which may include, without limitation, reporting usage, adoption of location-based services, and improvement of the services. Availability of location-based services will depend on your chosen wireless carrier in the United States.

Digital On-Boarding

When you apply for our services, we ask you to create a user profile. Your user profile will be used by Swipejobs to consider your qualifications for employment with Swipejobs or its Business Partners, or to promote jobs you have to shift workers. In addition, we will use your profile to communicate with you during your on-boarding including notifying you that you have successfully completed your registration and to communicate with you about the employment application process.

It is each user's responsibility to keep his or her information accurate, up-to-date and current at all times. If your information is not accurate, up-to-date and current, we may not be able to process your requests for information or contacts or provide our services to you effectively. To update or correct your personal information or other profile information, you may log into your account on the Service and follow the instructions. For information that cannot be updated through your account on the Service, please contact us at: privacy@swipejobs.com.

In some contexts, onboarding can include optional biometric identity verification. This includes a one-to-one check comparing a live selfie (with a liveness check) to the photograph on your identity document. We carry this out only with the Talent's explicit, upfront written consent; it is never required, and if you do not consent we verify your identity by other means. We use biometric data solely to verify identity, do not sell it, disclose it only to our verification provider (Amazon Web Services / Amazon Rekognition), and retain and destroy it in line with our published retention schedule and applicable law, including, for Illinois residents, the Biometric Information Privacy Act.

Your Choices

Swipejobs offers you choices about the collection, use and sharing of your personal information. The Privacy Center is where you make a request; the rest of this section explains what you can ask for.

You may request deletion of your account at any time by emailing us support@swipejobs.com. We will respond to your request for deletion within a reasonable timeframe. In some cases, your request for deletion may not be possible, for example, where Swipejobs is required to retain your information to comply with our legal obligations. In these cases, we will let you know if we are unable to do so and why.

Upon request, we will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information through the Privacy Center or by contacting us at privacy@swipejobs.com. We will respond to your request within a reasonable timeframe.

We may periodically send you e-mails or other communications that directly promote our Service, provide you with information regarding third party products, services or offers which we think may be of interest to you, or are in response to your request to receive such email. You may indicate a preference to stop receiving further communications from us and you will have the opportunity to opt-out by following the instructions provided in the e-mail or other communication you receive or by contacting us at privacy@swipejobs.com. You may opt out of certain other communications that we provide by following the instructions for opting-out in those communications.

You may object at any time to the use of your personal data by contacting us at privacy@swipejobs.com. If your complaint relates to alleged misuse of your personal data by a third party, it may result in suspension of that account in keeping with relevant law, public interest, our contractual obligations, and the rights of expression and access to information of others. Under EU law you have the right to lodge a complaint regarding the processing of your personal data by Swipejobs with the dedicated Supervisory Authority of your EU member state.

Privacy Rights and Choices

Depending on where you live and on applicable law, you may have rights over your personal data, including to: access a copy of your data; correct inaccurate data; delete data; obtain a portable copy; object to or restrict processing (including the right to object at any time to processing based on our legitimate interests, such as our candidate-discovery product); and withdraw consent where processing is based on consent.

If you are a US resident, you may also have the right to opt out of the "sale" or "sharing" of personal information and of certain targeted advertising or profiling. US privacy laws, including the CCPA, define "sale" and "sharing" broadly to include disclosing personal information to a third party for monetary or other valuable consideration, and our candidate-discovery product, which makes Candidate Information available to Employers, may fall within that definition regardless of whether payment flows directly for the data itself. Sourced Candidates can remove themselves from our search results at any time using the opt-out and suppression mechanism in the Privacy Center or at privacy@swipejobs.com.

To exercise a right, use the Privacy Center or contact privacy@swipejobs.com; where the law allows, you may use an authorized agent, and you may appeal a decision we make. We will respond within the timeframes required by law and will not discriminate against you for exercising your rights. The Privacy Center sets out how we handle a request, the response times we work to, and how to appeal. If you are in the UK or EEA, you may also lodge a complaint with a supervisory authority; in the UK, the Information Commissioner's Office (ICO); in the EEA, your local authority.

Our Use of Cookies and Other Information Gathering Techniques

Swipejobs uses "cookies", clear gifs, pixel tags, web beacons, log file information, and other tracking technologies (collectively, "Tracking Technologies") to obtain certain information when you use the Service, including, without limitation, understanding what pages you have viewed, what links you click, the searches you conduct on the Service and how frequently pages are visited. We link the information we store in tracking technologies to personally identifiable information. For example, when you log in to post a job order for shift workers, a session cookie is created while you are on the Service. This enables you to place multiple job orders without having to log back into the system each time. If you choose to disable these tracking technologies some functions of our services may not work properly.

Most web browsers automatically accept cookies. You may choose to decline cookies if your browser permits, but doing so may affect your ability to access or use certain features of the website or our services. Similarly, you may be able to adjust settings on your mobile device to limit the personal information it stores, and these adjustments may affect your ability to access or use certain features of the website or our services.

Third parties that work with the Service or related services may be using tracking technologies that create and maintain unique identifiers to collect information in connection with the service or services for which you've engaged Swipejobs.

Your selection of a "Do Not Track" option provided by your browser may not have any effect on the tracking technologies or the automatic collection of analytics information. This may be for a number of reasons. For example, not all tracking technologies can be controlled by browsers; unique aspects of your browser might be recognizable even if you disable a tracking technology; not all settings will necessarily last or be effective; even if a setting is effective for one purpose data still may be collected for another; and even if one website observes a "Do Not Track" signal, that website usually will not be able to control other websites.

Where required by applicable law, we honor the Global Privacy Control ("GPC") signal, and other similar universal opt-out signals, as a valid request to opt out of the sale or sharing of personal information and targeted advertising with respect to the browser or device sending the signal.

Information Protection Considerations

While no method of transmission or storage is completely secure, we maintain appropriate technical and organisational measures to protect personal data, and we will notify you and any relevant regulator of a personal data breach where required by applicable law.

By registering for our services or by using the Service, you hereby affirmatively consent to receiving our notification regarding any breach or compromise, or suspected breach or compromise, of the security of your personal information, by email, telephone whether through voice or text messages, posting on our website, or postal mail, as we deem appropriate, and as required by law.

It is your responsibility to keep your username, password and other account access information in a safe place and not to divulge it to anyone. We suggest that you log out of your account and close your browser window when you have finished using the Service. This is to ensure that others cannot access your account, especially if you are sharing a computer with someone else or are using a computer in a public place.

You use our services at your own risk, and you are responsible for taking reasonable measures to secure your account.

Retention and Deletion

If you have a user profile, you can access and modify some of your personal information by accessing your account through the Service. Swipejobs retains personal data associated with your account for the lifetime of your account. If you request to delete your account information, we may be required (by law or otherwise) to maintain some or all of this information for a period of time. You may request deletion of your account through the Privacy Center or by contacting us at privacy@swipejobs.com.

We keep personal data only for as long as necessary for the purposes described in this Policy. Retention periods are determined by criteria including the duration of our relationship with you, the purpose for which the data was collected, applicable legal, tax and regulatory requirements in each country where we operate, and the periods needed to establish, exercise or defend legal claims. Where the law of a country in which we operate prescribes a minimum or maximum retention period, we align to that requirement. Biometric data is subject to the specific retention and destruction schedule described where biometric verification is offered.

Payment Processors

Swipejobs provides services in conjunction with several payment processors through which users may pay for the Service or receive payment based on shift work. Those companies acting as payment processors may collect and store personal data related to your billing information and history in order to provide their services, and may collect and store personal data and business data to prevent fraud and other abuse.

To delete your payment or billing information, you will need to do so with your payment provider, as Swipejobs only has minimal secure access to those records as needed to provide the services.

Cross-border Transfers

The Service is hosted in the United States. Where your data is disclosed to our processors, it is subject by contract to at least the same level of data protection as that set out in this statement. We operate in the United States, the United Kingdom and elsewhere, and your personal data may be transferred to, stored in, and processed in countries other than your own, including the United States. Where we transfer personal data out of the UK or EEA, we rely on an appropriate safeguard recognised under applicable law (for example an adequacy decision, the UK International Data Transfer Agreement/Addendum, or the EU Standard Contractual Clauses), and apply additional protections where needed. You can request details of the safeguard used by contacting privacy@swipejobs.com.

Notice to California Residents – Your California Privacy Rights

This section supplements the "Privacy Rights and Choices" section above and applies to California residents whose personal information we collect, in accordance with the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the "CCPA").

Categories of Personal Information We Collect. In the preceding 12 months, we have collected the following categories of personal information, as defined by the CCPA: identifiers (such as name, address, email, phone number, Social Security number, and online identifiers); commercial information; internet or other electronic network activity information; geolocation data; professional or employment-related information; inferences drawn from the foregoing; and, where applicable and with consent, biometric information and government identification numbers. We do not knowingly collect sensitive personal information beyond what is described in this Policy.

Sources. We collect this information directly from you, automatically through your use of the Services, from other users, from Employers, and from publicly available and third-party sources as described in this Policy.

Purposes. We use and disclose this information for the business and commercial purposes described throughout this Policy, including providing the Services, matching Talent and Sourced Candidates to job opportunities, processing payments, verifying identity, complying with legal obligations, and improving our Services.

Disclosures and Sales/Sharing. We disclose personal information to the categories of third parties described in "How We Share Your Information." As described in "Privacy Rights and Choices," certain disclosures of Candidate Information to Employers may be considered a "sale" or "share" of personal information under the CCPA regardless of whether payment is made directly for the data. We do not sell or share the personal information of known minors under 16 years of age.

Retention. We retain each category of personal information for the periods described in "Retention and Deletion."

Your Rights and How to Exercise Them. California residents may exercise the rights described in "Privacy Rights and Choices," including the right to know, delete, correct, and opt out of sale or sharing, and the right to limit use of sensitive personal information, through the Privacy Center or by contacting privacy@swipejobs.com. You will not receive discriminatory treatment for exercising these rights, and you may designate an authorized agent to make a request on your behalf. This section also serves as our disclosure under California Civil Code Section 1798.83 regarding disclosures of personal information to third parties for their direct marketing purposes; to make a request under that section specifically, contact privacy@swipejobs.com.

Do Not Sell or Share My Personal Information

California residents have the right under the California Consumer Privacy Act (CCPA) to opt out of the sale or sharing of their personal information. Swipejobs uses cookies and similar technologies to personalize content and analyze traffic. If you would like to opt out, use the button below. We will revoke any tracking consent currently held for your browser and remove non-essential cookies. We also honour Global Privacy Control and other recognised universal opt-out signals sent by your browser, without you having to do anything further.

This button covers tracking on this website. To opt out of the sale or sharing of your personal information more broadly, or to remove yourself from our candidate search results, use the Privacy Center. Anyone can submit a request there, wherever they live.

Children

The Services are intended for use by persons who are 18 years of age or older. We do not knowingly collect personal information from persons under the age of 18. If we become aware or suspect that you are under the age of 18, any information you submit will be subject to our reasonable efforts to destroy such information, except as necessary for verifying your age or as required by law. No information should be submitted to Swipejobs by underage persons.

Changes in the Policy

This Policy may be updated from time to time. If we make material changes, we will provide notice by email to the address you have given us and/or by prominent notice on the Service before the change takes effect. New processing described in an updated Policy applies only from the date it takes effect; we will not apply materially different processing to previously collected personal data on the basis of your continued use alone, and where the law requires consent for a new use, we will obtain it.

Business Transfers

If Swipejobs is involved in a merger, acquisition, reorganization or sale of all or a portion of its assets, such that your information would be transferred or become subject to a different privacy policy, you will be notified via email and/or a prominent notice on the Service, so you can opt out of any such new policy.

Contact Us

Data Controller and Representatives

The controller of your personal data is Swipejobs LLC, together with our UK establishment Talent International UK Ltd. Our EU representative under Article 27 GDPR is the Swipejobs DPO, who can be contacted at DPO@swipejobs.com.

Contact Details

Please feel free to contact us with any comments or questions regarding this Policy at privacy@swipejobs.com or: