Last updated: 1 March 2015

1. About this privacy notice

1.1            This privacy notice sets out the personal data processing practices which Cielo, Inc. and Cielo Talent Management Limited with its registered office at 200 South Executive Drive, Suite 400 Brookfield, WI 53005 and Gray’s Inn House, 127 Clerkenwell Road, EC1R 5DB (registered number 3723978) (“Cielo”, “we”, “us”, “our”) along with its group companies (“Group”) carry out for the purposes of their online recruitment activities relating to external candidates, for example where you submit an application for employment through

1.2            This privacy notice only applies to Cielo's online recruitment activities. Other non-recruitment related Cielo websites are governed by various other privacy notices, for example our Privacy and Cookies Policy. In addition, this notice will not apply to personal data you supply to Cielo offline (for example, in person or over the telephone). 

2. Your personal information

2.1            “Personal data” is information about you which identifies you or from which you are identifiable, either on its own or in combination with other information in or likely to come into Cielo’s possession.

2.2            Cielo may collect the following types of personal data from you, including your:

2.2.1           name;

2.2.2           address;

2.2.3           email;

2.2.4           phone number;

2.2.5           date of birth; and

2.2.6           resumé/curriculum vitae contents including education information.

2.3            In very limited circumstances, Cielo may collect and process “sensitive personal data” but only where permitted by applicable laws and pursuant to (required) consents (e.g. where necessary for the recruitment purpose and/or where you voluntarily provide us with such information).

2.4            Cielo may, in addition, collect your shortened IP address to facilitate your browsing of Cielo websites.  We do not retain this information in a manner that is attributable to you as an individual and this means it is not your personal data.

3. Collecting your personal data

3.1            Cielo collects your personal data where you:

3.1.1           submit an online query or request for further information;

3.1.2           complete a form or otherwise submit an application for employment online (on or through; and

3.1.3           voluntarily provide other information about yourself.

3.2            By submitting information subject to this privacy notice you agree that Cielo may, depending on how far your application proceeds, collect additional information about you during the recruitment process, from you and/or other sources such as referees, recruitment agencies, publicly available information and any third parties we work with in our recruitment processes. Cielo would prior to doing this, take steps to ensure that you are told why it requires additional information about you and obtain from you any consents that may be necessary in order for Cielo to process such additional information lawfully.

4. Using your personal data

4.1            When Cielo collects, stores, uses, discloses, erases or otherwise performs operations on your personal data, this is called “processing”. 

4.2            Cielo processes your personal data for the following recruitment-related purposes:

4.2.1           dealing with your queries and requests for further information;

4.2.2           dealing with your application for employment at Cielo;

4.2.3           making decisions in respect of your employment at Cielo;

4.2.4           in the event your application is successful, making further decisions regarding your employment with Cielo;

4.2.5           in the event your application is unsuccessful, maintaining appropriate records of the same for a short period in case of queries from you, and (subject to section 9 of the policy and your consent) provide you with information in respect of future job vacancies at Cielo; and

4.2.6           analysis of our recruiting processes and reporting purposes.

4.3            Subject to applicable law, we may also process your personal data for other legitimate business purposes including management analysis, audit, forecasts, business planning and transactions, ensuring our compliance with applicable laws, regulatory requirements and Cielo policies, and dealing with legal claims and related administrative activities and related records retention.  We may also process it to establish or exercise our legal rights and to comply with law enforcement or other government agency requests or court orders.

4.4            Cielo or Group may also convert personal data into anonymous data and use it (normally on an aggregated statistical basis) for research and analysis to improve Cielo/Group performance.  For more information, please see the Aggregated Information section below.

5. Aggregated Information

Aggregated personal information does not personally identify you.  It may be used for statistical analysis and administration, including analysis of trends, carrying out actuarial work, tailoring products and services, risk assessment and analysis of costs and charges in relation to our products and services.

6. Sending your personal data abroad

6.1            Individuals within the European Economic Area (“EEA”) should be aware that recipients of their personal data, whether within the Group or external third parties (as mentioned in this notice), may be located in countries or territories outside the EEA which may not have adequate data protection laws equivalent to those in the EEA.

6.2            Cielo is Safe Harbor certified with the U.S. Department of Commerce, which means that transfers of personal data from the EEA and Switzerland to Cielo in the United States (U.S.) are deemed adequately protected. For more information about Cielo’s commitments under the Safe Harbor program, please read our Privacy and Cookies policy.

6.3            Where personal data is transferred to countries outside of the EEA and Switzerland (other than the U.S.) Cielo will put in place other measures to ensure that those transfers are adequately protected (as required by applicable law).

6.4            Individuals in other regions may also have their personal data transferred outside their own country. 

7. Sharing your personal data

7.1            Your personal data will be processed by the HR/recruitment team(s) within the Cielo company to which your application relates and by other individuals from different companies within the Cielo Group where required in order to ensure that your application is dealt with properly. 

7.2            In the event that your application is unsuccessful, Cielo may (subject to 9 and your consent) share your personal data between Cielo companies in order to provide you with details of any alternative vacancies that might be of interest to you.

7.3            Cielo may share your personal data with external third parties in order to receive recruitment-related services such as the administration of certain HR systems and management of interview and assessment centre services.

7.4            Your personal data may also be disclosed to third parties, where permitted by applicable laws, in connection with a corporate restructuring, sale, transfer or assignment of assets or business, merger, divestiture, or other changes to Cielo’s control or financial status (or any of the Cielo Group).

8. Securing you personal data

8.1             Cielo takes steps to seek to protect the security of your personal data in accordance with applicable laws. 

9.  Retaining your personal data

9.1            Cielo will retain your personal data for as long as necessary in respect of the recruitment purpose for which it was collected.

9.2            If your application is unsuccessful, we may retain for your personal data for a short period in case of queries from you, and where you have provided your consent for us to do so, for the purposes of providing you with information on future job opportunities and considering your application for the same.

9.3            Where your application is successful your personal data will be retained and processed in accordance with the Cielo employee privacy notice and consent (which will be provided to you following recruitment).

10. Your rights in relation to your personal data and how to contact Cielo

You may have the right (subject to the applicable law in your country) to request copies of or access your personal data and/or request the deletion of your personal data held by Cielo and to have certain inaccurate information about you corrected.  If you would like to do this or if you have any questions about this notice, please contact us at:

11. Changes to this privacy notice

Cielo may make changes to this privacy notice from time to time.  Please check this page regularly in order to see our most up to date notice.