This Privacy Policy (“Privacy Policy”) describes how Cicero Technologies, Inc. d/b/a Eudia Group and its affiliates including Eudia FDL U.S., Inc. and Johnson Hana International Limited (collectively, “Eudia,” “us,” “we,” or “our”) collects, uses, and discloses your personal information in connection with our website located at www.johnsonhana.com, www.eudia.com and any other websites we own and operate that link to this Privacy Policy (collectively, the “Site”), our social media pages, and our email, text, and other electronic communications, and the choices you have with respect to your personal information.
This Privacy Policy applies solely to individuals who: (a) provide legal consulting services for Eudia as part of Eudia’s delivery services; or (b) are candidates for such engagements; or (c) have applied for such roles (“Candidates”, “Consultants” or “you”) in the context of our management of Candidates and Consultants in relation to the recruitment and HR processes. This Privacy Policy does not apply to other interactions with Eudia. In particular, this Privacy Policy does not apply to any processing of personal information of Consultants where you use Eudia Technology as part of your role to deliver AI-augmented services on behalf of Eudia. Please see our general privacy policy here which applies to processing of Consultants’ personal information where using Eudia Technology as an end user.
We want you to understand how we collect, use, store, and share your personal information. We also want you understand what rights you may invoke to help you to protect your privacy. In this regard, it is important that you read and understand this Privacy Notice. Please note that we reserve the right to update this Privacy Notice as required. We will notify you of changes by posting the new Privacy Policy on this page and changing the “Last Updated” date at the top of this page. In some cases, such as where required by law, we may notify you about any updates by sending you an email, posting a notice on the Site about the update, or using other reasonable means. We encourage you to review this Privacy Policy periodically for any updates.
This Privacy Policy covers the following topics:
COLLECTION OF PERSONAL INFORMATION
SOURCES OF PERSONAL INFORMATION
USE OF PERSONAL INFORMATION
DISCLOSURE OF PERSONAL INFORMATION
TRANSFER OF PERSONAL INFORMATION
SECURITY
RETENTION OF PERSONAL INFORMATION
YOUR CHOICES
CHILDREN
LINKS TO OTHER WEBSITES AND SERVICES
NOTICE TO EU-BASED AND UK-BASED CONSULTANTS
NOTICE TO CALIFORNIA RESIDENTS
CONTACT US
Questions, comments or requests can be submitted to our data protection representatives.
By email to: privacyeurope@eudia.com
By mail to: FAO Legal Department, Dargan House, 21-23 Fenian Street, Dublin 2, Ireland
Categories of Personal Information Collected. We collect personal information about you in different contexts depending on how you use the Platform. The categories we collect and some examples of the personal information within those categories are described in the table below:
Individual Identifiers
Contact information, such as first and last name, email address, phone number, mailing address, and social media handle.
Online identifiers, such as Internet Protocol (IP) address, device ID, and other unique identifiers.
Other identifying information, such as your signature.
Commercial Information
Account information, such as your account details, profile data, or other information that you store in your account, if you create one on the Site.
Order and service history, such as records of the products, services, or subscriptions you have purchased or received from us.
Transaction and billing data, such as payment amounts and payment methods used to complete transactions, subscription details, or other billing details.
Preferences, such as any preferences you set in your account or any marketing or communications preferences.
Communications, such as the information associated with your requests or inquiries, including for support, assistance, or account information, or any feedback you provide when you communicate with us.
Internet or Network Activity
Online activity information, such as the website you visited before browsing to the Platform, pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, or duration of access.
Information Required for Recruitment and Engagement of Consultants
CV/Resume details including skills and qualifications, employment history details, reference details.
Suitability requirements including compensation expectations, notice period, visa requirements, identification documents.
Assessment information including interview notes, reference notes, records of our decision-making process, background check details (where required and so far as legally permitted)
HR Data
Financial information including bank details, pension details, PPS number, social security details, salary and bonus details.
Personnel File including leave details (annual, sick, parental, paternity, maternity, bereavement, sabbatical) performance details/documents, disciplinary documents date of birth, visa details, employment status, emergency contact details, benefit details.
Special Category Data limited information revealing racial or ethnic origin and data concerning health.
Time and Attendance Records
Time sheets, training records.
SOURCES OF PERSONAL INFORMATION
Personal Information You Provide. We collect personal information when you provide it to us, such as when you contact us, register on the Site, complete a contact form, engage in our recruitment and hiring process, join our talent community, or otherwise interact with us.
It is important that the personal information you provide us is up to date and accurate. If personal information we hold on you is inaccurate or incomplete, please contact us and we will update the information.
Personal Information Obtained from Third Parties. We may receive personal information from third parties, such as your nominated referees, our service providers, and data analytics partners, other publicly available sources and social media platforms such as LinkedIn.
References/Referrals. You may provide referee details to us or have the opportunity to refer colleagues or other contacts to us and share their contact information. Please do not provide us with another person’s contact information unless you have their permission to do so.
Automatically Collected Personal Information. When you visit or interact with the Site or engage with us, your personal information may also be collected automatically. We, our service providers, and our advertising partners may automatically log information about you, your computer, or your device, and your activity over time on our Sites.
On-premises Collection. Please note that where working from any of our premises or off-site locations CCTV and Visitor Sign-In may be used for security purposes.
Eudia may use personal information for the purposes set forth below and as otherwise described in this Privacy Policy or at the time of collection.
Business Operations including use of AI. We may use your information for any of the purposes set out in section Purpose and Legal Basis for processing below. As part of this we also use our proprietary AI tools. Eudia is committed to using our augmented intelligence approach of deploying our own trusted AI systems to empower our talent teams to work more efficiently by streamlining administrative steps and surfacing relevant information while always preserving their tenured experience and human judgment in decision making. In practice, our AI tools help us review job applications, CVs, resumes and to generate summaries and Candidate profiles for review by relevant stakeholders. Our team reviews these outputs for accuracy and appropriateness and we do not rely on AI tools for the sole basis for hiring decisions.
For Research and Development. We may use your information to: (i) improve the Site and our business; and (ii) understand and analyze the interaction and engagement trends and preferences of our Candidates.
As part of these activities, we may create aggregated or de-identified data from personal information we collect. We make personal information into de-identified data by removing information that makes the data personally identifiable to you.
Compliance, Fraud Prevention and Safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) audit our internal processes for compliance with legal and contractual requirements and internal policies; (c) prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft. We will use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
With Your Consent. In some cases, we may specifically ask you for your consent to collect, use, or share your personal information, such as when required by law.
DISCLOSURE OF PERSONAL INFORMATION
We may disclose your personal information to the entities and individuals listed below or as otherwise described in this Privacy Policy or at the point of collection.
Related Companies. We may share personal information with our affiliated entities, including parents, subsidiaries, or other related companies. This may include for the purpose of availing of Eudia AI technology as part of our talent search, recruitment and hiring processes as described above under Business Operations including use of AI.
Clients, Customers. We may share personal information with our clients who have roles in which you are interested.
Referees. We may share personal information with companies and/or individuals whose details you provide to us, so they can provide a reference.
Service Providers. We share personal information with third parties and individuals who perform functions on our behalf and help us run our business. For example, we work with service providers that help us perform website hosting, account security and authentication (including screening, background and criminal records checks),such as Checkr, Inc., cloud storage, web analytics, HR and recruitment processes, independent background checkers, payroll services, email services, benefit providers, marketing (including social media providers) and other purposes.
Law Enforcement, Authorities, and Others. Under certain circumstances, Eudia may be required to disclose your personal information to law enforcement, government authorities and departments, and other parties if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). Eudia may also disclose your personal information in the good faith belief that such action is necessary to comply with a legal obligation or for the purposes described above in the section titled “Compliance, Fraud Prevention, and Safety.”
Professional Advisors. We may share your personal information with persons, companies, or professional firms providing Eudia with advice and consulting in accounting, administrative, legal, tax, financial, and other matters.
Business Transaction Participants. We may disclose your personal information to third parties in connection with any business transaction (or potential transaction) involving a merger, acquisition, sale of shares or assets, financing, acquisition, consolidation, reorganization, divestiture, or dissolution of all or a portion of our business (including in connection with a bankruptcy or similar proceedings).
We will not sell your data to any third party and will take all appropriate steps to ensure the security of your data in dealings with third parties.
Eudia is headquartered in the United States, and we work with service providers in the United States and other countries. Your personal information may be collected, used, and stored in these countries or other locations outside of your home country. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country. By providing your personal information, where applicable law permits, you hereby specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein or in any applicable terms of service.
If you are located in Europe please view further information about cross-border transfers in the section below titled “NOTICE FOR EU-BASED AND UK-BASED CONSULTANTS”
The security of your personal information is important to us. We have implemented generally accepted standards of technology and operational security to protect personal information from alteration, unauthorised disclosure or destruction, and from use for unauthorised purposes however, please remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.
We will retain your personal information for as long as necessary to fulfil the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
We have detailed retention periods for which Personal Data shall be retained for particular purposes. We reserve the right to delete Personal Data prior to the conclusion of the retention period or where such retention is not absolutely necessary.
Individual Identifiers
Information provided with your requests or inquiries, in relation to recruitment/hiring process.
Performance of a Contract.
Legal/regulatory requirement
Legitimate interest of Eudia*
Commercial Information
To assist in understanding usage of our Site and performance of recruitment ads.
Performance of a Contract
Legal/regulatory requirement
Legitimate interest of Eudia*
Internet or Network Activity
Processing is based on our legitimate interests in training our AI systems as described in this Privacy Policy.
Consent.
Legitimate interest of Eudia*
Information Required for Recruitment and Engagement of Consultants
Information provided as part of recruitment process to assess suitability to make a hiring decision and to verify the information that you provided as part of your application
Performance of a Contract
Legal/regulatory requirement
Legitimate interest of Eudia*
HR information
Information required to manage employment/engagement of Consultants
Performance of a Contract
Legal/regulatory requirement
Legitimate interest of Eudia*
Time and Attendance Records
Information required to manage employment/engagement of Consultants
Performance of a Contract
Legal/regulatory requirement
Legitimate interest of Eudia*
HR information
With your consent
Processing is based on your consent. Where we rely on your consent you have the right to withdraw it at anytime in the manner indicated when you consented
Use for New Purposes. We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.
Your Rights. European data protection laws may give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
You may submit these requests by emailing privacy@eudia.com. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. In the European Economic Area, you can find your data protection regulator here. In the United Kingdom, you can find your data protection regulator here.
Cross-Border Data Transfer. If we transfer your personal information to a country outside of Europe such that we are required to apply additional safeguards to your personal information under European data protection laws, we will do so. Please contact us at privacy@eudia.com for further information about any such transfers or the specific safeguards applied.
If you have any questions or concerns about our Privacy Policy or any other privacy or security issue, please contact us at privacy@eudia.com.
