Privacy Notice

1. Summary of principal terms

This summary forms part of the Notice and is qualified by the sections that follow.

• Tracking. The Site uses cookies, pixels, tags, software development kits, session-recording and comparable technologies, operated by us and by third parties, for analytics, personalisation, attribution and interest-based advertising (Section 5).
• Candidates. Where you apply to, register with, or are sourced by Contractanaut, we compile a Candidate Profile about you, disclose it to clients and prospective clients, retain it in our talent pool for future engagements, and use it, ordinarily in de-identified form, to promote our services (Section 6).
• Sourcing. We are a headhunting business. We obtain information about prospective candidates and client contacts from third-party and publicly available sources, and not only from the individuals themselves (Section 4.3).
• Disclosure. We disclose personal information to clients, service providers, advertising and analytics partners, affiliates and successors (Section 8).
• Your rights. You may access, correct, delete, restrict or object to our processing, withdraw consent and opt out of marketing and of interest-based advertising at any time (Section 11).

2. Controller and scope

2.1 The Site located at contractanaut.com, together with its subdomains, forms, candidate and client portals, shared candidate links and associated communications (collectively, the "Services"), is operated by Contractanaut LLC, a company organised under the laws of the Republic of Kosovo, trading as Contractanaut ("Contractanaut", "we", "us", "our"). For the purposes of applicable data protection legislation, Contractanaut is the controller of the personal information described in this Notice, save where Section 8.2 provides otherwise.

2.2 This Notice applies to: (a) visitors to and users of the Services ("Visitors"); (b) individuals acting for actual or prospective clients ("Client Contacts"); and (c) individuals who apply to, register with, are referred to, or are identified and approached by Contractanaut in connection with actual or potential engagements ("Candidates").

2.3 This Notice does not govern the processing of personal information by any client to whom a Candidate is introduced or with whom a Candidate is placed. Each such client acts as an independent controller in respect of the information it receives and is responsible for its own compliance.

3. Definitions

3.1 "Personal information" means any information relating to an identified or identifiable natural person, and includes "personal data" and analogous terms as defined under applicable law.

3.2 "Candidate Materials" means any curriculum vitae, résumé, cover letter, portfolio, work sample, photograph, audio or video recording, assessment response, reference, certification or other content submitted by or on behalf of a Candidate, or generated in the course of our evaluation of a Candidate.

3.3 "Candidate Profile" means the record that we compile in respect of a Candidate, comprising Candidate Materials together with our own notes, scores, summaries, availability data, compensation expectations and any derived or inferred attributes.

3.4 "Tracking Technologies" has the meaning given in Section 5.1.

4. Personal information we collect

4.1 Information you provide

Identification and contact particulars (name, email address, telephone number, postal address, time zone, social and professional profile identifiers); employer, title and business particulars; the content of enquiries, bookings, calls, messages and correspondence, including recordings and transcripts of calls and interviews where you have been notified that recording is taking place; Candidate Materials; nationality, work authorisation status, language proficiency, education and employment history, compensation history and expectations, availability, equipment and connectivity particulars; identity and background verification information where an engagement so requires; payment and payout particulars; and any other information you elect to furnish.

4.2 Information collected automatically

Internet Protocol address and the approximate geolocation derived from it; device, browser and operating system type, version and configuration; unique device, cookie, advertising and other online identifiers; referring and exit pages, campaign and attribution parameters; pages and content viewed, links and controls activated, scroll depth, cursor movement, form interaction, time on page, and the date, time, frequency and sequence of visits; interaction with our emails, including delivery, opening, link activation and forwarding; and diagnostic, performance and error data.

4.3 Information obtained from other sources

We obtain personal information about Candidates and Client Contacts from professional networking platforms, job boards, publicly accessible websites, registers and publications, recruiters, referrers and referees, former and current employers, educational institutions, background and credential verification providers, data enrichment and lead-generation providers, advertising and analytics partners, and our clients. We may combine information obtained from any source described in this Section 4 into a single record.

4.4 Sensitive information

We do not request information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, or sexual orientation, and ask that you not include it in Candidate Materials. Where such information is nonetheless furnished, or is apparent from a photograph or recording, it is processed solely as an incident of the purposes set out in Section 6 and is not used to make decisions about you.

5. Cookies and tracking technologies

5.1 We, and third parties acting on our behalf or on their own account, deploy cookies, pixel tags, web beacons, scripts, local and session storage, software development kits, server-side event interfaces, device and browser fingerprinting, session-recording and replay tools, and comparable technologies (together, "Tracking Technologies") on the Services and in our electronic communications.

5.2 Tracking Technologies are used for the following purposes:

• Strictly necessary. Operation, security, load distribution, fraud and abuse prevention, and the retention of your preferences.
• Analytics and performance. Measurement of traffic and usage, reconstruction of individual browsing sessions (including cursor movement, clicks, scrolling and form interaction, but excluding the content of password and payment fields), experimentation and multivariate testing, and diagnostics.
• Functionality and personalisation. Recognition of returning Visitors and the tailoring of content, including by reference to inferred company, industry, location and interests.
• Advertising, attribution and audience-building. Delivery and measurement of interest-based advertising on and off the Services; creation of retargeting, custom, matched and lookalike audiences, including by the transmission of hashed identifiers such as email addresses to advertising platforms; conversion tracking; and cross-device and cross-context linkage.
• Identification of business visitors. Association of a visit with an organisation by reference to IP address and third-party datasets, and the enrichment of that association with business contact information.

5.3 Providers of Tracking Technologies that we use or may use include providers of web analytics, tag management, session recording, customer relationship management, marketing automation, email delivery, scheduling, and advertising platforms operated by, among others, Google, Meta, LinkedIn and Microsoft. Those providers may collect information directly from your device, may combine it with information collected across other websites and services over time, and process it in accordance with their own privacy notices as independent controllers. A current list of providers is available on request.

5.4 Consent and control. Where applicable law requires consent to the placement of, or access to, non-essential Tracking Technologies, we deploy them only once that consent has been given, and it may be withdrawn at any time through the preference controls made available on the Site or by contacting us. In addition, you may: configure your browser to refuse or delete cookies; enable a recognised opt-out preference signal such as Global Privacy Control, which we treat as a valid request to opt out of the sale and sharing of personal information and of targeted advertising in respect of that browser; and use the opt-out mechanisms maintained by the Digital Advertising Alliance (optout.aboutads.info), the Network Advertising Initiative (optout.networkadvertising.org) and the European Interactive Digital Advertising Alliance (youronlinechoices.eu). Refusal of strictly necessary technologies may impair the Services. We do not otherwise respond to browser "Do Not Track" signals, for which no common standard has been adopted.

6. Candidates

This Section applies to Candidates in addition to the remainder of this Notice. Please read it before submitting Candidate Materials.

6.1 Compilation. We compile and maintain a Candidate Profile in respect of each Candidate, drawing on the sources described in Section 4, and we evaluate, score, rank, categorise and summarise Candidates, including with the assistance of automated and artificial-intelligence tools operated by us or by our service providers. No decision producing legal or similarly significant effects is taken solely by automated means; a member of our staff reviews every decision to advance or decline a Candidate.

6.2 Disclosure to clients. We disclose Candidate Profiles, in whole or in part, to clients and prospective clients, in any jurisdiction, whom we consider may have a present or future requirement for which the Candidate may be suited, whether or not the Candidate applied for, or was informed in advance of, the particular requirement. Disclosure may be made by means of the Services, shared links, email, presentations or calls.

6.3 Talent pool. We retain Candidate Profiles in our talent pool, and may contact Candidates regarding future opportunities, for the period described in Section 10, irrespective of the outcome of any particular application.

6.4 Promotional use. We use Candidate Profiles to market and promote our services, including on the Site (for example, on availability boards and in sample or illustrative candidate cards), in sales materials, proposals, advertisements, social media, case studies and communications to prospective clients. Such use is ordinarily made in a form from which surname, contact particulars and current employer have been removed, and may include first name, role, seniority, country or region, skills, experience, language proficiency, rate band, availability and our evaluative summary. Use in promotional material of a Candidate's photograph, video, voice or full name is made only with that Candidate's consent, which may be given at registration or subsequently and may be withdrawn in accordance with Section 6.7.

6.5 Licence. To the extent that Candidate Materials are protected by copyright or other intellectual property rights, you grant Contractanaut a non-exclusive, worldwide, royalty-free, sub-licensable (to our clients, affiliates and service providers) and transferable (to any successor to our business) licence to use, reproduce, store, adapt, reformat, translate, summarise, excerpt, display and distribute the Candidate Materials for the purposes set out in this Section 6, for so long as we retain them. You warrant that you are entitled to grant that licence and that the Candidate Materials are accurate and do not infringe the rights of any third party, including any duty of confidence owed to a current or former employer.

6.6 De-identified and aggregated information. We create de-identified and aggregated information from Candidate Profiles (for example, compensation benchmarks, market availability statistics and time-to-fill metrics) and use and disclose it for any lawful purpose, including research, product development and marketing. We maintain such information in de-identified form and do not attempt to re-identify it.

6.7 Withdrawal and objection. A Candidate may at any time, by notice given in accordance with Section 11.3: withdraw from consideration for any requirement; object to promotional use under Section 6.4; withdraw any consent given; or require removal from the talent pool and deletion of the Candidate Profile. We shall give effect to such a request without undue delay, subject to Section 10.3. Withdrawal does not affect the lawfulness of processing, or recall disclosures made, before it took effect, and we cannot compel the deletion of information already held by a client as independent controller, although we shall on request notify that client of the Candidate's wishes.

6.8 No fee. Candidates are never charged a fee by Contractanaut, and the provision of personal information is not a condition of any payment. Failure to provide information reasonably required for evaluation may mean that we are unable to consider a Candidate.

7. Purposes and legal bases

7.1 We process personal information for the following purposes: (a) providing, operating, securing and improving the Services; (b) sourcing, evaluating, presenting, placing and administering Candidates, and the purposes set out in Section 6; (c) responding to enquiries, scheduling and conducting calls, and negotiating and performing contracts; (d) identifying, profiling, scoring and contacting prospective clients and Candidates, including by email, telephone, messaging and professional networking platforms; (e) direct marketing, advertising, audience-building, attribution and the measurement of their effectiveness; (f) analytics, research, benchmarking, the training and evaluation of models and tools used within our business, and the development of new services; (g) billing, payment, payout, accounting, tax and audit; (h) the detection and prevention of fraud, abuse and security incidents; (i) the establishment, exercise or defence of legal claims and compliance with legal obligations; and (j) the planning and execution of any transaction described in Section 8.1(f).

7.2 Where applicable law requires a legal basis, we rely upon: performance of a contract, or steps taken at your request prior to entering into one (purposes (a), (b), (c) and (g)); our legitimate interests in operating, promoting and growing a recruitment business, in maintaining a talent pool, and in securing the Services, which we have assessed as not overridden by your interests, rights and freedoms having regard to the safeguards and rights described in this Notice (purposes (a), (b), (d), (e), (f), (h) and (j)); your consent, where required (including for non-essential Tracking Technologies, certain electronic marketing, and the promotional use of image, voice or full name under Section 6.4); and compliance with legal obligations (purposes (g) and (i)).

8. Disclosure of personal information

8.1 We disclose personal information to: (a) clients and prospective clients, as described in Section 6.2; (b) service providers and processors acting on our instructions, including providers of hosting, database, storage, communications, scheduling, customer relationship management, applicant tracking, analytics, session recording, artificial-intelligence, transcription, verification, payment and payout, and professional services; (c) advertising, analytics and data partners, as described in Section 5; (d) our affiliates, being any entity that controls, is controlled by or is under common control with us, now or in future; (e) referees, verification providers and other parties whom it is necessary to contact in order to evaluate a Candidate; (f) any actual or prospective purchaser, investor, lender, assignee or successor, and their advisers, in connection with any merger, acquisition, financing, reorganisation, assignment of contracts to an affiliate or successor entity, insolvency, or sale or transfer of all or any part of our business or assets, in which event personal information may be among the assets transferred; (g) courts, regulators, law enforcement and other public authorities, and other third parties, where we consider disclosure necessary to comply with law or legal process, to protect the rights, property or safety of any person, or to enforce our agreements; and (h) any other person with your consent or at your direction.

8.2 Where we process personal information on behalf of a client under a written agreement, that client is the controller and its privacy notice governs.

8.3 Sale and sharing. We do not sell personal information for monetary consideration. The disclosure of online identifiers and internet activity information to advertising and analytics partners described in Section 5 may constitute a "sale", "sharing" or processing for "targeted advertising" under certain United States state laws; you may opt out as described in Sections 5.4 and 11. We do not knowingly sell or share the personal information of individuals under sixteen years of age.

9. International transfers

Contractanaut operates from the Republic of Kosovo, serves clients in the United States of America, and engages Candidates and service providers in numerous jurisdictions. Personal information is accordingly transferred to, stored in and processed in countries other than your own, including countries whose laws may afford a lower standard of protection and in which public authorities may obtain access in accordance with local law. Where applicable law so requires, we implement appropriate safeguards for such transfers, such as standard contractual clauses approved by the competent authority, a copy of which may be obtained on request.

10. Retention

10.1 We retain personal information for so long as is reasonably necessary for the purposes for which it was collected, and thereafter for so long as is required or permitted by law, including for the duration of applicable limitation periods.

10.2 Subject to Section 6.7, Candidate Profiles are retained in our talent pool for [five (5)] years from the date of our last substantive contact with the Candidate, and are then deleted or de-identified unless the Candidate has agreed to a longer period. Information collected by Tracking Technologies is retained for the periods determined by the relevant technology, ordinarily not exceeding twenty-six (26) months.

10.3 Following a deletion request we may retain the minimum information necessary to record and honour the request (including suppression lists), to comply with legal obligations and to establish, exercise or defend legal claims.

11. Your rights

11.1 Subject to the conditions and exceptions of applicable law, you may: (a) obtain confirmation of whether we process personal information about you, and access to it; (b) be informed of the source of information that we did not obtain from you; (c) require the correction of inaccurate information; (d) require deletion; (e) require the restriction of processing; (f) object to processing founded on legitimate interests, and object at any time and without giving reasons to processing for direct marketing, including profiling related to it; (g) receive information you provided in a portable format; (h) withdraw consent at any time, without affecting prior processing; (i) not be subject to a decision based solely on automated processing that produces legal or similarly significant effects; and (j) lodge a complaint with a supervisory authority, which in Kosovo is the Information and Privacy Agency (Agjencia për Informim dhe Privatësi), or with the authority of your place of habitual residence.

11.2 United States residents. Depending on your state of residence, you may additionally have the right to know the categories and specific pieces of personal information collected, the categories of sources, purposes and recipients; to correct and delete; to opt out of sale, sharing, targeted advertising and certain profiling; to limit the use of sensitive personal information; to appeal a refusal of your request; and not to suffer discrimination or retaliation for exercising any right. The categories of personal information that we collect, and have collected in the preceding twelve months, are identifiers; professional and employment-related information; education information; commercial information; internet and network activity information; approximate geolocation; audio and visual information; inferences; and, where applicable, government identifiers furnished for verification. Each is collected from the sources in Section 4, used for the purposes in Section 7 and disclosed to the recipients in Section 8.

11.3 Exercising your rights. Requests may be made through the contact form at contractanaut.com/contact. Every marketing email contains an unsubscribe mechanism. We may require information sufficient to verify your identity, and shall respond within the period prescribed by applicable law. An authorised agent may act on your behalf upon proof of authority.

12. Security

We maintain technical and organisational measures designed to protect personal information against accidental or unlawful destruction, loss, alteration, and unauthorised disclosure or access, including encryption in transit, access controls and the contractual obligation of service providers. No method of transmission or storage is wholly secure, and we do not warrant absolute security. We shall notify affected individuals and authorities of a personal data breach where applicable law so requires.

13. Children

The Services are directed to business users and to professionals of working age. They are not directed to, and we do not knowingly collect personal information from, individuals under eighteen years of age. Information that we learn has been so collected will be deleted.

14. Third-party services and changes to this Notice

14.1 The Services may link to, or embed, websites and services operated by third parties, which are governed by their own terms and privacy notices and for which we are not responsible.

14.2 We may amend this Notice from time to time. The amended Notice takes effect upon publication on the Site with a revised effective date. Where an amendment materially affects the manner in which we process personal information previously collected, we shall give prominent notice on the Site or by email before it takes effect and, where applicable law requires, seek your consent.