Privacy Policy for English Skills Portfolio (ESP) -- Summary
1. Public Nature of ESP
- The English Skills Portfolio (ESP) is a public web page.
- Any information included in the ESP, such as resumes, documents, social media links, and video links, will be accessible to anyone with the URL.
- Users are advised to consider this public visibility when adding personal information.
2. Hide Contact Information Option
- Users have the option to "hide contact information," which will suppress the display of their name, location, and contact details on the ESP.
- If this information is visible in any attached documents (e.g., resumes, letters of recommendation) or linked social media accounts (e.g., LinkedIn), it will still be publicly accessible.
3. Primary Use and Linking to Resumes
- The ESP is designed primarily as a complement to a resume rather than a standalone web page.
- Users may link their ESP URL in their resumes.
- This allows employers to access the ESP for additional information, supporting the user's English proficiency and professional skills without necessitating the repetition of information
already provided in the resume.
4. Content Guidelines
- Users can include various types of content in their ESP, such as:
- Resumes in English or other languages
- Up to four additional documents (e.g., letters of recommendation, certificates, transcripts, work samples)
- Social media links (with a preference for LinkedIn)
- YouTube video links (e.g., elevator pitch videos demonstrating English proficiency and professional background)
- Users are responsible for ensuring that the content they upload does not contain sensitive or private information they do not wish to make public.
5. User Responsibility
- Users must ensure that any content they add to their ESP does not violate any third-party rights or applicable laws.
- Users should regularly review their ESP to ensure all information is accurate and up-to-date.
6. Deleting or Disabling Display of ESP
- Users may delete or disable the display of their ESP whenever they like.
- Assistance is available if users need help with deleting or disabling their ESP. Just send us an email.
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Privacy Policy for English Career Network -- Details
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1. Introduction
1.1 Commitment to Privacy
English Career Network ("we," "our," "us") is committed to safeguarding the privacy of our website visitors and service users ("you," "your"). This Privacy Policy outlines how we collect, use, disclose, and protect your personal data in compliance with the General Data Protection Regulation (GDPR) and Brazil's Lei Geral de Proteção de Dados (LGPD).
1.2 Scope of Policy
This policy applies when we act as a data controller with respect to your personal data. We determine the purposes and means of processing your personal data through our website and services.
1.3 Use of Cookies
We use cookies on our website to enhance your user experience. Except for strictly necessary cookies, we will seek your consent before placing other types of cookies on your device. For more details, refer to Section 9.
1.4 Privacy Controls
1.5 Data Protection Contact Point
For any data protection inquiries, please contact:
Thomas McCutchen
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2. Personal Data We Collect
We process various categories of personal data based on the services you use. You can manage which personal data you display via your customer dashboard.
2.1 Categories of Personal Data
2.1.1 Usage Data
- Includes: IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, website navigation paths, timing, frequency, and pattern of service use.
- Source: Our analytics tracking system.
- Purpose: Analyzing website and service usage.
- Legal Basis: Consent or legitimate interests (monitoring and improving our website and services).
2.1.2 Account Data
- Includes: Name, email address.
- Source: You.
- Purpose: Operating our website, providing services, ensuring security, maintaining backups, and communicating with you.
- Legal Basis: Consent or legitimate interests (proper administration of our website and business).
2.1.3 Profile Data
- Includes: Name, address, telephone number, email address, profile pictures, date of birth, interests and hobbies, educational details, employment details.
- Purpose: Enabling and monitoring your use of our website and services.
- Legal Basis: Consent or legitimate interests (proper administration of our website and business or performance of a contract).
2.1.4 Service Data
- Includes: Information provided during the use of our services.
- Source: You.
- Purpose: Operating our website, providing services, ensuring security, maintaining backups, and communicating with you.
- Legal Basis: Consent or legitimate interests (proper administration of our website and business).
2.1.5 Publication Data
- Includes: Information you post for publication on our website or through our services.
- Purpose: Enabling publication and administering our website and services.
- Legal Basis: Consent or legitimate interests (proper administration of our website and business or performance of a contract).
2.1.6 Enquiry Data
- Includes: Information contained in any enquiry you submit regarding goods and/or services.
- Purpose: Offering, marketing, and selling relevant goods and/or services to you.
- Legal Basis: Consent.
2.1.7 Customer Relationship Data
- Includes: Your name, employer, job title or role, contact details, information from communications.
- Source: You.
- Purpose: Managing relationships with customers, communicating, record-keeping, and promoting products and services.
- Legal Basis: Consent or legitimate interests (proper management of customer relationships).
2.1.8 Transaction Data
- Includes: Contact details, card details, transaction details.
- Purpose: Supplying purchased goods and services, keeping transaction records.
- Legal Basis: Performance of a contract and legitimate interests (proper administration of our website and business).
2.1.9 Notification Data
- Includes: Information provided for subscribing to email notifications and/or newsletters.
- Purpose: Sending relevant notifications and/or newsletters.
- Legal Basis: Consent or performance of a contract.
2.1.10 Correspondence Data
- Includes: Content and metadata of any communication you send to us.
- Purpose: Communicating with you and record-keeping.
- Legal Basis: Legitimate interests (proper administration of our website and business and communications with users).
2.1.11 Job Application History
- Includes: Your job application details.
- Source: You.
- Purpose: Communicating with you and record-keeping.
- Legal Basis: Consent or performance of a contract.
2.1.12 Legal Claims Data
- Includes: Any personal data necessary for legal claims.
- Purpose: Establishment, exercise, or defense of legal claims.
- Legal Basis: Legitimate interests (protection and assertion of legal rights).
2.1.13 Insurance and Risk Management Data
- Includes: Personal data necessary for insurance coverage, risk management, or professional advice.
- Purpose: Protecting our business against risks.
- Legal Basis: Legitimate interests.
2.1.14 Compliance Data
- Includes: Personal data necessary for compliance with legal obligations or to protect vital interests.
- Purpose: Compliance with legal obligations, protection of vital interests.
- Legal Basis: Compliance with legal obligations or protection of vital interests.
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3. How We Use Your Personal Data
3.1 Overview
This section outlines:
- The categories of personal data we process.
- The sources of personal data not obtained directly from you.
- The purposes for which we process personal data.
- The legal bases for processing.
3.2 Detailed Uses and Legal Bases
3.2.1 Usage Data
- Purpose: Analyzing website and service usage.
- Legal Basis: Consent or legitimate interests.
3.2.2 Account Data
- Purpose: Operating our website, providing services, ensuring security, maintaining backups, and communicating with you.
- Legal Basis: Consent or legitimate interests.
3.2.3 Profile Data
- Purpose: Enabling and monitoring your use of our website and services.
- Legal Basis: Consent or legitimate interests.
3.2.4 Service Data
- Purpose: Operating our website, providing services, ensuring security, maintaining backups, and communicating with you.
- Legal Basis: Consent or legitimate interests.
3.2.5 Publication Data
- Purpose: Enabling publication and administering our website and services.
- Legal Basis: Consent or legitimate interests.
3.2.6 Enquiry Data
- Purpose: Offering, marketing, and selling relevant goods and/or services to you.
- Legal Basis: Consent.
3.2.7 Customer Relationship Data
- Purpose: Managing relationships with customers, communicating, record-keeping, and promoting products and services.
- Legal Basis: Consent or legitimate interests.
3.2.8 Transaction Data
- Purpose: Supplying purchased goods and services, keeping transaction records.
- Legal Basis: Performance of a contract and legitimate interests.
3.2.9 Notification Data
- Purpose: Sending relevant notifications and/or newsletters.
- Legal Basis: Consent or performance of a contract.
3.2.10 Correspondence Data
- Purpose: Communicating with you and record-keeping.
- Legal Basis: Legitimate interests.
3.2.11 Job Application History
- Purpose: Communicating with you and record-keeping.
- Legal Basis: Consent or performance of a contract.
3.2.12 Legal Claims Data
- Purpose: Establishment, exercise, or defense of legal claims.
- Legal Basis: Legitimate interests.
3.2.13 Insurance and Risk Management Data
- Purpose: Protecting our business against risks.
- Legal Basis: Legitimate interests.
3.2.14 Compliance Data
- Purpose: Compliance with legal obligations, protection of vital interests.
- Legal Basis: Compliance with legal obligations or protection of vital interests.
3.3 Additional Uses
3.3.1 Future Sharing with Employers
We may share user portfolios with employers. Job seekers can hide or exclude personal information from their portfolios, remaining contactable through the 'Contact' button without revealing their email addresses. Employers can send messages to users without accessing their personal contact details.
3.3.2 Targeted Communications
Unless you explicitly opt out, we may send you periodic messages related to job fairs, new opportunities, or other relevant announcements. We are committed to sending only pertinent messages to our user community.
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4. Providing Your Personal Data to Others
4.1 Group Companies
We may disclose your personal data to any member of our group of companies (subsidiaries, ultimate holding company, and all its subsidiaries) as necessary for the purposes and on the legal bases set out in this policy.
4.2 Insurers and Professional Advisers
We may disclose your personal data to our insurers and/or professional advisers for purposes such as obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or establishing, exercising, or defending legal claims.
4.3 Suppliers or Subcontractors
We may disclose personal data to our suppliers or subcontractors as necessary for the performance of a contract between you and us or to take steps at your request to enter into such a contract.
4.4 Payment Services Providers
4.5 Third-Party Suppliers for Enquiry Data
We may disclose your enquiry data to selected third-party suppliers of goods and services identified on our website to enable them to contact you with relevant offers, marketing, and sales. Each third party acts as a data controller for the enquiry data we supply and must provide you with their own privacy policy governing their use of your personal data.
4.6 Legal Obligations and Vital Interests
We may disclose your personal data where necessary for compliance with legal obligations, protection of vital interests, or for the establishment, exercise, or defense of legal claims.
4.7 International Data Transfers
Your data may be transferred and stored on servers located outside of Brazil and the European Economic Area (EEA). We ensure that all international transfers comply with applicable data protection laws, providing the same level of protection to your data through contracts or international safeguards such as standard data protection clauses adopted or approved by the European Commission.
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5. International Transfers of Your Personal Data
5.1 Overview
This section provides information about the circumstances under which your personal data may be transferred to countries outside the European Economic Area (EEA) and Brazil.
5.2 Adequacy Decisions
The European Commission has made an "adequacy decision" with respect to the data protection laws of certain countries. Transfers to these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
5.3 Hosting Facilities
Our website is hosted in the USA. The European Commission has not made an adequacy decision for the USA. Therefore, transfers to the USA are protected by standard data protection clauses to ensure your data remains secure.
5.4 Public Availability of Data
Personal data submitted for publication through our website or services may be accessible worldwide via the internet. We cannot prevent the use or misuse of such personal data by others.
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6. Retaining and Deleting Personal Data
6.1 Data Retention Policies
Our data retention policies and procedures are designed to ensure compliance with legal obligations regarding the retention and deletion of personal data.
6.2 Retention Periods
Personal data processed for any purpose will be retained indefinitely unless deleted by the user.
6.3 Specific Retention Details
- Registered Users:
- Data Retained: Name, contact details, profile, usage data, communication data.
- Retention Period: Indefinitely while the account is active.
- Job Listings Responses:
- Data Retained: Application data.
- Retention Period: 12 months after the job listing has been archived. After 12 months, the application copy will be deleted. Users wishing to delete their data earlier can contact us under their Legal Rights to request removal.
- Published Resumes:
- Data Retained: Resumes published on Employee.ie.
- Retention Period: As long as the user decides to keep it in our system. Users can delete or change their personal data via their user dashboard.
6.4 Legal Obligations and Vital Interests
We may retain your personal data where necessary for compliance with legal obligations or to protect vital interests.
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7. Amendments
7.1 Policy Updates
We may update this policy from time to time by publishing a new version on our website.
7.2 Notification of Changes
You should check this page occasionally to ensure you are happy with any changes to this policy. We will notify you of significant changes to this policy by email or through the private messaging system on our website.
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8. Your Rights
8.1 Overview
This section summarizes the rights you have under data protection laws, including both GDPR and LGPD. Some rights are complex, and not all details are included in these summaries. Please refer to relevant laws and guidance from regulatory authorities for a full explanation.
8.2 Principal Rights
You have the following rights under data protection laws:
- (a) Right to Access: Obtain confirmation whether we process your personal data and access to your personal data, including details of processing purposes, data categories, and recipients.
- (b) Right to Rectification: Have inaccurate personal data corrected and incomplete data completed.
- (c) Right to Erasure: Request deletion of personal data under certain conditions.
- (d) Right to Restrict Processing: Request limitation of processing under specific circumstances.
- (e) Right to Object: Object to processing based on legitimate interests or public tasks.
- (f) Right to Data Portability: Receive your personal data in a structured, commonly used, and machine-readable format.
- (g) Right to Complain: Lodge a complaint with a supervisory authority if you believe our processing infringes data protection laws.
- (h) Right to Withdraw Consent: Withdraw consent at any time without affecting the lawfulness of processing before withdrawal.
8.3 Access Rights
8.4 Right to Rectification
You have the right to have any inaccurate personal data about you rectified and to have incomplete personal data completed, considering the purposes of processing.
8.5 Right to Erasure
Under certain circumstances, you have the right to request the deletion of your personal data without undue delay. These circumstances include:
- Personal data is no longer necessary for the purposes it was collected.
- Withdrawal of consent for consent-based processing.
- Objection to processing under certain conditions.
- Processing is for direct marketing purposes.
- Personal data has been unlawfully processed.
Exclusions: The right to erasure does not apply if processing is necessary for freedom of expression, compliance with legal obligations, or the establishment, exercise, or defense of legal claims.
8.6 Right to Restrict Processing
You have the right to restrict processing if:
- You contest the accuracy of your personal data.
- Processing is unlawful, but you oppose erasure.
- We no longer need the personal data for processing, but you require it for legal claims.
- You have objected to processing pending verification.
Restricted data may continue to be stored but will only be processed with your consent, for legal claims, for protecting rights, or for important public interests.
8.7 Right to Object
You can object to our processing of your personal data based on:
- Public interest or official authority tasks.
- Legitimate interests pursued by us or a third party.
If you object, we will cease processing your data unless we can demonstrate compelling legitimate grounds for processing that override your interests, rights, and freedoms, or the processing is for legal claims.
8.8 Right to Object to Direct Marketing
You can object to our processing of your personal data for direct marketing purposes, including profiling. If you object, we will stop processing your data for these purposes.
8.9 Right to Object to Research or Statistical Purposes
You can object to processing for scientific, historical research, or statistical purposes unless necessary for public interest tasks.
8.10 Right to Data Portability
If processing is based on consent or contract performance and carried out by automated means, you can receive your personal data in a structured, commonly used, and machine-readable format. This right does not apply if it adversely affects others' rights and freedoms.
8.11 Right to Lodge a Complaint
If you believe our processing infringes data protection laws, you have the right to lodge a complaint with a supervisory authority in your EU member state of habitual residence, place of work, or place of the alleged infringement.
8.12 Right to Withdraw Consent
If processing is based on consent, you can withdraw your consent at any time by deleting your portfolio. For assistance or complete account deletion, please email [
info@english-career-network.com](mailto:
info@english-career-network.com). Withdrawal of consent does not affect the lawfulness of processing before withdrawal.
8.13 Exercising Your Rights
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9. About Cookies
9.1 What Are Cookies?
A cookie is a file containing an identifier (a string of letters and numbers) sent by a web server to a web browser and stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
9.2 Types of Cookies
- Persistent Cookies: Stored by a web browser and remain valid until their set expiry date unless deleted by the user.
- Session Cookies: Expire at the end of the user session when the web browser is closed.
9.3 Personal Information and Cookies
Cookies do not typically contain personally identifiable information. However, personal information stored about you may be linked to information obtained from cookies.
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10. Cookies That We Use
We use cookies for the following purposes:
- (a) Authentication: Identify you when you visit our website and as you navigate our website.
- (b) Status: Determine if you are logged into our website.
- (c) Personalization: Store information about your preferences and personalize the website for you.
- (d) Security: Protect user accounts, prevent fraudulent use of login credentials, and protect our website and services.
- (e) Advertising: Display advertisements relevant to you.
- (f) Analysis: Analyze the use and performance of our website and services.
- (g) Cookie Consent: Store your preferences regarding the use of cookies.
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11. Cookies Used by Our Service Providers
11.1 Service Providers and Cookies
Our service providers use cookies, which may be stored on your computer when you visit our website.
11.2 Google Analytics
11.3 Google AdSense
We publish Google AdSense advertisements on our website. Google tracks your behavior on our website and others using cookies to tailor advertisements to your interests. You can manage your interest categories at [https://adssettings.google.com](https://adssettings.google.com) and opt out of the AdSense partner network cookie via [https://optout.networkadvertising.org](https://optout.networkadvertising.org). Note that these opt-out mechanisms use cookies, and clearing your browser cookies may remove your opt-out. For persistent opt-out, consider using Google browser plug-ins available at [
https://support.google.com/ads/answer/7395996](
https://support.google.com/ads/answer/7395996).
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12. Managing Cookies
12.1 Blocking and Deleting Cookies
Most browsers allow you to refuse or delete cookies. Methods vary by browser and version. Up-to-date information can be found at:
12.2 Impact of Blocking Cookies
Blocking all cookies may negatively impact the usability of many websites.
12.3 Website Features
If you block cookies, you may not be able to use all the features on our website.
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13. User Responsibilities
13.1 Public Nature of ESP
- The English Skills Portfolio (ESP) is a public web page.
- Information in the ESP, such as resumes, documents, social media links, and video links, is accessible to anyone with the URL.
- Users should consider public visibility when adding personal information.
13.2 Hide Contact Information Option
- Users can choose to "hide contact information," suppressing the display of their name, location, and contact details on the ESP.
- If such information is visible in attached documents or linked social media accounts, it remains publicly accessible.
13.3 Primary Use and Linking to Resumes
- The ESP complements a resume rather than serving as a standalone web page.
- Users can link their ESP URL in their resumes, allowing employers to access additional information without repeating resume content.
13.4 Content Guidelines
Users can include:
- Resumes in English or other languages.
- Up to four additional documents (e.g., letters of recommendation, certificates, transcripts, work samples).
- Social media links (preferably LinkedIn).
- YouTube video links (e.g., elevator pitch videos demonstrating English proficiency and professional background).
Responsibility: Users must ensure that uploaded content does not contain sensitive or private information they do not wish to make public.
13.5 User Responsibility
- Ensure that content added does not violate third-party rights or applicable laws.
- Regularly review the ESP to ensure information is accurate and up-to-date.
13.6 Deleting or Disabling Display of ESP
- Users can delete or disable their ESP at any time.
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14. Security Measures
14.1 Data Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:
- Encryption: Protecting data during transmission and storage.
- Access Controls: Limiting access to personal data to authorized personnel only.
- Regular Audits: Conducting security assessments to identify and mitigate risks.
- Data Anonymization and Pseudonymization: Reducing the risk associated with personal data processing.
14.2 No Guarantee of Absolute Security
While we strive to protect your data, no method of transmission over the Internet or electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security.
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15. Children's Data
15.1 Protection of Minors
Our services are not directed to children under the age of 16. We do not knowingly collect personal data from children under 16. If we become aware that we have inadvertently received personal data from a child under 16, we will delete such information promptly.
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16. Contact Us
You can contact us:
- (a) Using our website contact form.
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17. Additional Information for LGPD Compliance
17.1 Legal Basis for Processing
Under LGPD, we process your personal data based on:
- Consent: When you create a portfolio or subscribe to our services.
- Legitimate Interest: Such as improving our services and sharing relevant opportunities with you.
- Performance of a Contract: Providing and managing our services as per your requests.
17.2 User Rights Under LGPD
In addition to GDPR rights, LGPD grants you the right to:
- Confirmation of Processing: Obtain confirmation of whether we process your personal data.
- Anonymization, Blocking, or Elimination: Request the anonymization, blocking, or elimination of unnecessary or excessive data.
- Correction of Inaccurate or Outdated Information: Ensure your data is accurate and up-to-date.
17.3 Data Controller in Brazil
17.4 Data Transfer Outside Brazil
If your data is processed or stored outside Brazil, we ensure compliance with LGPD by implementing appropriate safeguards such as standard data protection clauses and ensuring the same level of protection as required under LGPD.
17.5 Data Protection Impact Assessments (DPIA)
We conduct data protection impact assessments when engaging in activities that pose a high risk to user privacy, such as sharing user data with third parties like employers.
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By using English Career Network, you agree to the terms outlined in this Privacy Policy. We encourage you to review this policy periodically to stay informed about how we protect your personal data.
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