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Welcome to Sonru, a Modern Hire Company. We are committed to protecting your privacy. This Privacy Policy (“Policy”) is effective as of the date set forth at the end of the Policy and is intended to memorialize our data collection and disclosure practices for our website and service offerings (collectively, the “Services”). This Policy may be amended and updated from time to time.

By using the Services, you signify that you have read and understood this Policy. To the extent required under applicable law, you also provide your consent to us collecting, using and disclosing your personal information in accordance with this Policy. Personal information may be used interchangeably with “personal data” throughout this Policy.

Who We Are
Collection and Processing of Information
Third Parties
Purpose and Legal Basis of Processing
Disclosure of Information
Retention of Information
Your rights
Data Security
Cookies; Beacons; Tracking Technology
Changes to Policy
International transfers
Contact Information

Who We Are

Sonru is a wholly-owned subsidiary of Modern Hire, Inc. Sonru and its affiliates (set forth at the end of this Policy) (“Sonru,” “we,” “us,” and “our”) offer Services that are fundamentally a means to connect job candidates (“Candidates”) with recruiters (“Recruiters”) acting on behalf of employers (“Employers”). Our core services are delivered through a cloud-based platform whereby Recruiters and Candidates can engage in video interviewing, scheduling, and assessments among other features. Candidates, Recruiters and Employers may be collectively referred to in this Policy as “Users.”

Depending on the context of personal information you provide, we may be the data controller ("Controller") or data processor ("Processor") of your personal information under this policy.

This policy describes how we will make use of your data when you utilize our services, visit our websites and access our social media pages. It also describes your data protection rights. More information about your rights, and how to exercise them, is set out in the “Your rights” section below.

Collection and Processing of Information

Sonru as Processor

For the purposes of the GDPR, Sonru primarily acts as a Processor. This means that we act on behalf of our customers (generally, Employers) and process data on their instructions. Our customers are the Controllers of the personal data that we process. Please refer to their privacy statements for further details about their processing activities. Depending on the jurisdiction in which we operate, the terms “processor” and “controller” may have different designations, but the concepts behind the terminology are consistent. For example, a processor may be referred to under some regulations as a “service provider” or other terminology and a controller may be referred to as a “business” or other terminology. For simplicity, we use the processor/controller terms throughout this policy.

Sonru does not intend to collect or process, and the Services are not intended to store sensitive and or special categories of data such as health data, political opinions, religious beliefs, and financial information (including bank account and credit card information), social security number, date of birth, driver’s license numbers, etc. Sonru may incidentally process information pertaining to a User’s race/gender as captured by video.

Sonru as Controller

When you visit our website or interact with our social media pages we collect the following information:

  • your IP address

  • Cookie ID

  • use and browser information

  • content you interact with

If you request a demo for our product then we will also collect your

  • First Name

  • Last Name

  • Phone Number

  • Email Address

  • Department

  • Company Name

  • Company Industry

  • Number of Worldwide Employees

  • Company Headquarters

We may also collect non-personal and anonymous information to be used in an aggregate fashion. For example, we may collect system-related information to be used for system administration purposes, to help diagnose problems, to monitor traffic patterns, to determine which services are used most frequently and to assess site usage. Where data is anonymized, it is no longer considered personal data as this data does not directly or indirectly reveal your identity.

Third Parties

When you access the Services through any co-branded websites or linked web pages, your personal data will be disclosed to Sonru and/or the relevant co-sponsor where relevant. In that case, the use of such personal data by the co-sponsor company will be subject to the privacy policy of that company, and we are not responsible for nor subject to the co-sponsor’s policy regarding their use of the personal data. Accordingly, we encourage you to review the privacy policies and practices of any relevant co-sponsor before supplying any personal information.

The Services may contain links to third party sites. These links are provided for your convenience only and Sonru is not responsible for the privacy policies, practices, or content of sites owned by others that you may link to or that may be linked from the Services. We encourage you to review the privacy policies and terms and conditions of those sites so that you understand how those sites collect, use, and share your information. This Policy applies solely to the information that we collect from our Services.

Purpose and legal basis of Processing

Where recognized under applicable law, Sonru collects User information to provide the following services:

  • To fulfil a contract, or take steps linked to a contract: this is relevant where you contact us to receive Services. This includes:

    • Setting up accounts.

    • Verifying your identity.

    • Communicating with you.

    • Providing customer services.

  • As required by Sonru to conduct our business and pursue our legitimate interests, in particular:

    • Sending information that we believe Users may find helpful.

    • From time to time, contacting Users for application research purposes.

    • Customizing the Services.

    • Monitoring use of our websites and online services and improving our products.

    • Providing products and services you have requested.

    • Responding to any comments or complaints you may send us.

    • Using data in connection with legal claims, compliance, regulatory and investigative purposes when necessary and as required by law.

  • Where you give us consent:

    • We will send you direct marketing in relation to our relevant products and services, or other products and services provided by us, our affiliates and carefully selected partners.

    • We place cookies and use similar technologies in accordance with our Cookies Policy and the information provided to you when those technologies are used

    • On other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.

For purposes which are required by law:

  • In response to requests by government or law enforcement authorities conducting an investigation.

Sonru may utilize artificial intelligence (AI) during a Candidate interview. The AI analyses responses to interview questions. More information about our use of AI can be obtained upon request.

Relying on our legitimate interests

We have performed balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out later in this notice.

Withdrawing consent or otherwise objecting to direct marketing

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have a right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.

Disclosure of Information

Where authorized by law, we may share your personal data with our affiliated group companies for marketing, communication, and facilitation of our Services.

Sonru will share your personal data:

  • If you are a Candidate – with the Employer and Recruiter;

  • If you are a Recruiter – with the Employer ;

  • If you are an Employer – with the Recruiter in order to provide our Services.

Personal data will also be shared with third party service providers, who will process it on behalf of Sonru for the purposes identified above. In particular, we use third party providers for website hosting, maintenance, audio/visual processing and identity checking.

Where we engage third parties on our behalf, we ensure that we have entered into appropriate agreements to protect your data. Sonru may also disclose personal data and aggregate anonymous information to those businesses, divisions, and units that are affiliated with us (set forth at the end of this Policy). Where we disclose your personal data to an area outside of the EEA, it will be dealt with in accordance with our international data transfer section below.

If one of our business lines or the entire business, or a substantial portion thereof, is acquired or transferred, whether by merger, consolidation or purchase of a substantial portion of assets, we may disclose and transfer your’ personal data to the acquiring third party. We may also disclose your’ personal data to third parties when we believe, in good faith and in our sole discretion, that such disclosure is reasonably necessary to (a) enforce or apply the terms and conditions of the Services; (b) comply with legal or regulatory requirements; (c) protect the rights, property or safety of us, our users or other third parties; or (d) prevent a crime or protect national security. We may also disclose aggregate anonymous information to clients, business partners, merchants, advertisers, investors, potential buyers and other third parties if we deem such disclosure, in our discretion, to have sound business reasons or justification.

Retention of Information

We will not retain data longer than is necessary to fulfill the purposes for which it was collected, by contract or as required by applicable law or regulations. When acting as a processor, data relating to Candidates is established by contract between Sonru and the Employer.

Where we process registration data, we do this for as long as you are an active user of our sites and in conformance with our record retention policies thereafter.

Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data so that we can respect your request in future.

Your Rights

You may have the right to be informed as to the processing of your personal data, to access your data, obtain a copy of the data, port the data, restrict, rectify or object to processing of the data, or request that the data be deleted or to withdraw consent. Users have the right to object to automated decision making and profiling if applicable. Users can also make a complaint to the UK’s Information Commission Office or other supervisory authority in the country where they live, work or believe a breach has happened. Please address your query in accordance with Contact Information section below.

We encourage you to contact us in the first instance to discuss any concerns or issues you may have relating to the processing of your data, so that we may cooperate with you to resolve same.

Data Security

Sonru has put in place appropriate technical and organizational measures to prevent personal data from being accidentally lost, used or accessed in an unauthorized manner.

Cookies; Beacons; Tracking Technology

Sonru uses "cookies," “web beacons” and similar technology for the convenience of Users and to enhance Users experience using the Services. A cookie is a small text file that is recorded either temporarily or persistently on a hard drive by a web page server depending on use they enable us to recognize you without requiring you to repeatedly log in when using the Services. Web beacons are graphics designed to collect web log information such as pages viewed or messages opened. By relying on cookies, web beacons, and similar technology, Sonru is able to deliver a more efficient service that is more personalized for each user. Additionally, these technologies may allow us to monitor traffic patterns, Services usage, and session information to make the Services more useful.

Sonru uses the following Cookies for the following purposes:

cookie retention

We do not knowingly or specifically collect personal information from users under 16 years of age. We do not authorize users under 16 years of age to use the Services.

Policy Changes

Sonru reserves the right to change this Policy at any time. In particular, we may modify this Policy to reflect changes in the way we collect, use, or disclose information, or to reflect changes in privacy laws, regulations, and/or industry standards. We encourage Users to review this Policy when accessing the Services. Where the changes substantially affect the manner in which we handle your data, we will bring them to your attention.

Transfers of Data Overseas

Transfers of data from within the EEA to outside the EEA

Personal data originating in the EEA will be stored in servers in the EEA and may be accessed and/or processed outside of the EEA. Sonru adheres to the GDPR where it applies to our Services and use of this site. Where your data is processed outside of the EEA, we have endeavoured to put in place appropriate safeguards. The primary means by which your data may be accessed outside of the EEA is with our affiliated company, Modern Hire in the United States. Until the EU-US Privacy Shield was declared invalid on 16th July 2020, Modern Hire was certified under the EU-US Privacy Shield and maintains the Principles specified in the Privacy Shield.

Where appropriate, we will enter into Standard Contractual Clauses (SCCs) for the transfer of your data, having carried out a risk assessment and taken additional measures over and above the measures contained in the SCCs where possible. A copy of the SCCs is available upon request. However, where we have determined we are unable to provide equivalent protection of your personal data, we will seek to rely on a derogation authorized by the GDPR, including the derogation of consent/contract/request of data subject. If relying on your consent, we will seek your explicit consent in advance.

Transfers of data from a country not within the EEA to outside of that country

When Sonru sends your information from a country (not within the EEA) to outside of that country, we will make sure that your information is protected to at least the same standard as that which is required in the originating country. For example, we will ensure that there is a proper legal agreement that covers the data transfer.

Contact Information
To exercise your rights, ask questions about our privacy practices, or to submit a complaint, please contact us at: Sonru Ltd

Chelsea House
Distillery Road
Wexford, Ireland
Tel: + 353 539272000
Freephone: 00 800 2400 4444 Email: privacy@modernhire.com

Effective Date: October 15, 2020

Australian Addendum

These additional terms apply in Australia. To the extent of any inconsistency these terms take precedence over the terms above in relation to Australia.

In this addendum:

"Australian Privacy Principles" or "APPS", mean the Australian Privacy Principles set out in Schedule 1 to the Privacy Act;

"Privacy Act" means the Australian Privacy Act 1988 (Cth);

"Privacy Policy" means the Privacy Policy to which this addendum is attached.

Terms defined in the Privacy Policy have the meaning given in the Privacy Policy, subject to the modifications set out below:

A reference in the Privacy Policy to:

"data subject" includes "individual" as defined in the Privacy Act;

"personal data" and "personal information" includes "personal information" as defined in the Privacy Act; and

"process" includes "disclose", "hold" and "use" as defined in the Privacy Act.

We will comply with the Privacy Act to the extent it applies to the personal data processed in relation to our Services.

If you do not provide personal information requested, you may not be able to benefit from the full range of Services we offer.

We may incidentally collect Candidates' sensitive information (as defined in the Privacy Act) if the Candidate, Recruiter or Employers provide it to us in the course of using the Services. By providing the sensitive information, Users consent to Sonru’s collection of the information and use and disclosure of the information in accordance with this Privacy Policy for purposes directly related to the reason it was provided. Such information may include racial or ethnic origin, political opinions, religious beliefs or affiliations, membership or trade association or unions, criminal records or health information.

Personal information may be disclosed to recipients described in the Privacy Policy, some of whom may be outside Australia including in the following countries: Countries that are part of the EEA, the United States, Singapore, and others as updated from time to time.

At your request, we will provide you with a copy of any personal information which we hold about you, unless an exception under the Privacy Act 1988 applies. We may charge a fee for retrieving this information, in which case we will inform you of the fee and obtain your agreement to that fee before providing the information.

Please use the contact information in the Privacy Policy if you wish to access or correct any of your personal information that we hold or if you would like to complain about a breach of the Australian Privacy Principles. We will promptly acknowledge and investigate any complaint about the way we manage personal information.

Affiliates and Contact Information

MODERN HIRE (United States)
Modern Hire, Inc.
3201 Enterprise Parkway, Ste 460
Cleveland, Ohio 44122
Tel: (877) 451-1659

Sonru Ltd Chelsea House
Distillery Road
Wexford, Ireland
Tel: + 353 539272000
Freephone: 00 800 2400 4444

Sonru UK Ltd
1st Floor Holborn Gate
330 High Holborn
Tel: 00 800 2400 4444

Sonru Asia Pacific Pte Ltd
1 - Scotts Road, #24-10
Shaw Centre, Singapore 228208
Tel: +65 8118 9493

Sonru Australia Pty Ltd
PO Box 965
NSW 2830
Tel: +61 405 410 100

Sonru France SAS
9 Rue Lasson
75012 Paris