Our Commitment to Your Privacy

Version: October 2023

Cielo recognizes the importance of transparent and responsible use of your personal information. This Privacy Notice and Cookies Policy (the “Notice”) explains how Cielo collects, uses and safeguards personal information about you when you visit this site and when you contact Cielo, whether by e-mail, post or telephone using the contact options on this site (manage your communications preferences here).

Read Cielo's Statement on the Modern Slavery Act 2015 here.

How we use your information

This privacy notice tells you what to expect when Cielo collects personal information. Click on the links below for further details:

Access to information

What information

What personal data

How we collect personal data

Applying to work for Cielo

What we do with your data

Aggregated data

Data sharing

Disclosures

Direct marketing

California Consumer Privacy Act

Security

Your Rights

Cookies

Contact Us

Complaints

Updates to this Notice

Who can access your information

The information you provide to us directly will be shared within our global group of companies operating under the Cielo brand. All references to “Cielo” in this Privacy Notice and Cookies Policy therefore include Cielo and its related group companies (the “Group”), unless stated to the contrary. The full list of our offices and companies can be found here.

By providing us with your personal information you understand and accept that the personal information provided may be accessed from some of our offices based in countries not offering the same rights and protection to your personal data as your country of residence. Cielo operates a privacy framework, inclusive of organizational and technical security measures, to ensure the personal information you provide is kept secure and that your rights are respected regardless of the country in which it is processed.

What information we collect when you visit our site

  • Information about your Internet Service Provider, your operating system, browser type and/or domain name;
  • The Internet Protocol (IP) address of your computer (or other electronic internet-enabled device); and
  • Your access time(s).

This information helps us to understand which parts of the site are popular or need changing. 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” (as described below).

If you use our site search facility, queries and results are logged anonymously without any user-specific details being collected. Our collection of website use information may also involve the use of cookies and web beacons. Please see the Cookies section below for more information.

If you want to contact us or to use certain facilities we provide on this site, you will need to share with us with some additional personal information so that we can liaise with you and deal with your request, query or application. This information (either on its own or in combination with other information we hold about you) may allow us to identify you as an individual. This type of personal information is called “personal data”. If you do choose to provide us with your personal data, we will collect that information for the purposes described in this Notice.

What type of personal data does Cielo process?

Most of the information we process about you will have been collected directly from you. However, sometimes, where lawful to do so and where you have indicated that we (as a third party) may access this personal data, we also collect personal information from (and combine it with data from) public sources, third party service providers, government, tax or law enforcement agencies, and other third parties. If we have collected your personal data in any of these ways, we will notify you prior to processing it.

Below is a list of the personal data about you which we may process:

  • Your full name;
  • Your work and/or home contact details, e.g., company name, job title, address, postal code, country, fax number, telephone numbers and/or e-mail address;
  • Other company information, e.g., number of employees and industry sector;
  • The reason for your contact such as a query in respect of a job application or information about our services;
  • Information about services that interest you;
  • Information necessary for legal compliance; and/or
  • Where you “like” us or make posts on our pages on social networking websites.

We only process personal data about you that is relevant for the purposes for which it is to be used.

How we collect personal data

Personal Information about you may also come from our contracted clients to whom we provide services.

We may also obtain Personal Data about you from third parties.

When providing our RPO and/or recruitment Search services we may also obtain Personal Data about you from referrals, networking activities, public databases, joint marketing partners, licensed databases, and social media platforms.

The information we collect from these third parties includes information about the identity of potential candidates (e.g., an individual’s name and contact details), information about their background and qualifications (employment and professional history, education, skills, etc.), citizenship, information from former employers and other references.

We may also use Personal Data that you make publicly available on the Internet (e.g., LinkedIn, GitHub and other regional and/or professional social media platforms). As permitted by applicable laws, we obtain background verification information.

Applying to work for Cielo

If you apply for a role with Cielo, we will provide you with a separate notice (the “Recruitment Privacy Notice”) explaining the way we will use your personal information for the purpose of processing your job application.

The Recruitment Privacy Notice is displayed at the time you register or submit your details on our careers site. This applies to all candidates globally.

When applying for a role at Cielo, we will process your name, contact details, career and educational background, salary expectations, skills and attributes relating to the role applied for. It is Cielo’s legitimate interest to process this information as part of recruiting employees into our business.

If we were to offer you role, this may be conditional to some pre-employment checks. These are essential steps to enter an employment contract.

The nature of pre-employment vetting may vary depending on the role’s requirements.

As part of this process, at the very minimum we will request references from previous employers. Additionally, we may collect additional information, such as the right to work in a specific jurisdiction, your nationality, date of birth and, in some cases, some sensitive information relating to health and criminal record (where a DBS check is required). We will inform you of the specifics for these checks and, if legally required, we will seek your explicit consent to use the information, disclose it to any third party or use it for a purpose other than those for which it was originally collected or subsequently authorized.

For what reasons does Cielo process your personal data?

As part of its core business, Cielo provides a range of outsourced services to its clients.

These services include outsourced recruitment and selection processes, digital marketing, recruitment advertising and candidate satisfaction surveys. As part of these business activities, the two principal scenarios for which your personal data may be processed are:

  • We process Personal Data as instructed by our clients and under their brand (“We Become You”). Under most agreements with our clients, you will not be approached directly by Cielo and this reflects our clients’ outsourcing of their recruitment operations to us. For this purpose, Cielo is a data processor on behalf of its clients.
  • There are occasions in which we may contact you under the Cielo brand. For example, in connection with the search function of our business. Under this scenario, we process Personal Data under the Cielo brand to help you secure a new and exciting role, often confidential, with one of our global clients. For this purpose, you will be approached under the Cielo Search brand.

We will only process personal data where we have a lawful reason for doing so. The lawful basis for processing personal data by Cielo will be one of the following:

  • The processing is necessary for the performance of a contract you are party to or in order to take steps at your request prior to you entering into a contract; for example, an employment contract;
  • The processing is necessary to fulfil an outsourcing contract with one of our clients; in this case we will operate as instructed by the client, who will be the data controller in respect to your personal data;
  • The processing is necessary in order for us to comply with our legal obligations (such as compliance with anti-money laundering and fraud prevention legislation);
  • The processing is necessary for the pursuit of our legitimate business interests (including that of the delivery and the promotion of our services); and/or
  • Processing is necessary for the establishment, exercise or defence of legal claims.

This means that we use information about you:

  • To fulfil our contractual obligations to our clients for service provision. For example: sourcing and recruiting candidates for open or future roles, of pre-employment vetting, logistic management of payroll, implementation of technology solution and employer brand services, including digital marketing;
  • To match you against suitable job opportunities with our clients;
  • To process and respond to your request or inquiry;
  • To improve our services;
  • Administration of the site;
  • For internal record keeping when necessary;
  • To contact you (directly, either by Cielo or by the Group, or indirectly through a relevant partner or agent) by e-mail, post/mail or phone for the above reasons;
  • Where necessary as part of any restructuring of Cielo or sale of a relevant Group company’s business or assets;
  • To perform 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; and
  • Cielo also converts personal data into anonymous data and uses it (normally on an aggregated statistical basis) for research and analysis to improve Cielo/Group performance. For more information, please see the Aggregated Data section below.

Aggregated data

Aggregated personal information does not personally identify you or any other user of the site or our services. It may be used for statistical analysis and administration, including analysis of trends, tailoring of services, risk assessments and analysis of costs and charges in relation to our services; this is not an exclusive list.

Does Cielo share personal data with third parties?

Your personal data will be made available within the Cielo Group of companies for the purposes listed in this Notice (or as otherwise notified to you from time to time), on a “need-to-know” basis and only to responsible management, human resources, accounting, legal, audit, compliance, information technology and other corporate staff who need to know these details for the proper performance of their functions within the Cielo Group of companies.

We may share personal data within the Group as needed for reasonable management, analysis, planning and decision-making, including in relation to making decisions regarding the expansion and promotion of a service offering, and for use by those companies for the other purposes described in this Notice.

Personal Data is shared within the Group via an intra-organizational Data Management Agreement under which standardized security measures are agreed and deployed uniformly in every region. Standardized contractual clauses support these agreements for data transfers between our offices in different regions.

Use of data processors: Data processors are third parties who provide elements of our services for us, including technology vendors that we use to support our recruitment and marketing activities, as well as website hosting and management. We may share personal data with such third-party data processors as needed in connection with the services they provide to us. Cielo’s default policy is for the technology providers not to have access to personal data except, for example, when resolving a reported technical issue.

We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organization apart from us. They will hold it securely and retain it for the period we instruct, or as instructed by our clients, if the client is the data controller.

Website hosting and management: The site is powered by a content management system (CMS) hosted on Microsoft Azure. Here is the link to Microsoft’s privacy policy: https://azure.microsoft.com/en-us/support/legal/.

If you register to receive innovation updates and events from Cielo, your data will be stored in our CRM and communication technologies, which are provided by the following third parties:

  • Customer Relationship Management: Customer Relationship Management: we use Salesforce for managing our sales and marketing activities. Here is a link to Salesforce’s privacy policy https://www.salesforce.com/uk/company/privacy/;
  • We use Marketo for communications, campaigns and events. Here is a link to Marketo’s privacy policy: https://documents.marketo.com/legal/privacy/; and
  • We use a small number of vetted and trusted technology providers to support our recruitment activities. All vendors are periodically screened for their compliance with internationally recognized security standards and privacy frameworks.
  • We use Clockwork Recruiting as a recruitment database for our search function. Access their privacy policy here: https://www.clockworkrecruiting.com/privacy-policy.
  • We work with Phenom People help us delivering great candidate attraction strategies. You can view their privacy policy here: https://www.phenompeople.com/privacy-policy.
  • To deliver some services, we leverage a partnership with SmartRecruiters. Here is a link to their approach to privacy for the various scenarios where personal data is processed using their platform: https://www.smartrecruiters.com/legal/general-privacy-policy/.

International transfers of personal data: Individuals within the European Economic Area (“EEA”), Switzerland and the United Kingdom (“UK”) 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 which may not have adequate data protection laws equivalent to those in the EEA, Switzerland or the UK.

Where there is no Adequacy Decision allocated by the European Commission or the UK’s Information Commissioner’s Office, we leverage other mechanisms, such as Standard Contractual Clauses combined with an applicable transfer risk assessment to ensure adequate protection of your data in accordance with the EU and UK GDPR and other frameworks which may apply to the jurisdictions covered by our services.

If you object to your data being transferred outside the EEA, please visit our Preference Center to advise us or email privacy.office@cielotalent.com.

Our Privacy Office strives to maintain up to date and relevant knowledge on the requirements for handling personal across different jurisdictions.

Disclosure of personal data

If requested, and as governed by applicable law, we may disclose specific information upon lawful request by government, law enforcement and regulatory authorities where required or permitted to do so by law and/or for tax or other purposes.

Personal data may also be released to external parties in connection with legal process, where required to comply with laws, to enforce our contracts, corporate policies and terms of use, and/or to protect the rights, property or safety of Cielo, Cielo employees, agents, customers and others, as well as to parties to whom you have authorized Cielo to release your personal data.

In addition, we may disclose your personal data as necessary in the event that Cielo or any part of the Group restructures, assigns, sells or otherwise disposes of all or any of its business or assets.

Cielo’s default position is to decline access to personal data when a request is generic and/or does not seem lawful (“fishing exercises”).

Direct marketing

Cielo may provide you with information about new services, promotions, industry updates, events and offers from Cielo and the Group, which may be of interest to you, and may invite you to take part in market research or request feedback on Cielo and/or Group services. This communication will occur by email, SMS or telephone. We will obtain your consent where we are required to do so in accordance with applicable law. If you have attended one of our events, requested a white paper or are a member of a client organization benefiting from our services, we may rely on our legitimate interest to contact you. You can update your preferences here.

Cielo will ensure that any direct marketing or market research that you receive or are contacted about by electronic means will provide a simple means for you to refuse further marketing. For example, in emails it may provide you with an ‘unsubscribe’ link, or an email address to which you can send an opt-out request. Cielo will take steps to stop any direct marketing to you to which you object or in respect of which you withdraw your consent within a reasonable period, in order to allow sufficient time for the change to be administered.

In such cases Cielo would not necessarily remove all your personal data from its database(s) but would note and respect your modified direct marketing preferences. If you would like for your data to be removed from Cielo’s database, please convey this request in writing to privacy.office@cielotalent.com.

California Consumer Privacy Act (CCPA)

Cielo does not sell Personal Information to third parties outside the scope of contracted recruitment activities or as part of its business.

If you are a California resident, also please reference the section, Apply For A Role at Cielo.

We collect, and have collected within the preceding 12 months, the following categories of Personal Information, as listed in the CCPA:

  • Category A. Identifiers, such as name, contact information, IP address, and other online identifiers;
  • Category B. Personal information, as defined in the California customer records law, such as name, contact information, medical information, insurance information, education information, employment information, and government-issued ID numbers;
  • Category C. Characteristics of protected classifications under California or federal law, such as age, sex, disability status, primary language, race, citizenship, and marital status, to the extent required or permitted by applicable law;
  • Category D. Commercial information, such as transaction information and purchase history relating to contracted clients;
  • Category E. Internet or network activity information, such as browsing history and interactions with our website;
  • Category F. Audio, electronic, visual, and similar information, such as photographs or audio and video recordings created in connection with our business activities;
  • Category G. Professional or employment-related information, such as work history and prior employer, information relating to references, details of qualifications, skills and experience, human resources data, and data necessary for benefits and related administration services; and
  • Category H. Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and abilities.

For information on the sources of these categories of Personal Information, please refer to the How we Collect Personal Data section in this Notice.

In certain cases, we may qualify as “selling” (as defined by the CCPA) Category G Personal Information. Selling, under CCPA, broadly includes any disclosure of Personal Information to a third party that is not a service provider or is not directed by the individual. For non-RPO services, such as Search, Cielo may share your Personal Information (specifically your name, title, and employer) with our Clients and in most cases this information is found in public sources.

We have disclosed the following categories of Personal Information, as listed in the CCPA, to third parties for our operational business purposes within the preceding 12 months:

  • Category A. Identifiers, such as name, contact information, IP address, and other online identifiers;
  • Category B. Personal information, as defined in the California customer records law, such as name, contact information, education information, medical information, insurance information, employment information, and government-issued ID numbers;
  • Category C. Characteristics of protected classifications under California or federal law, such as age, sex, disability status, primary language, race, citizenship, and marital status, to the extent required or permitted by applicable law;
  • Category E. Internet or network activity information, such as browsing history and interactions with our website;
  • Category F. Audio, electronic, visual and similar information, such as call and video recordings;
  • Category G. Professional or employment-related information, such as work history and prior employer, information relating to references, details of qualifications, skills and experience, human resources data, and data necessary for benefits and related administration services; and
  • Category H. Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and abilities.

The above information is shared with Cielo’s clients as part of a contracted business activity or hosted on one of our strategic technology partners’ solutions enabling our services.

If you are a California resident, you may request that we:

  • Disclose to you the following information covering the 12 months preceding your request:
    • The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
    • The specific pieces of Personal Information we collected about you;
    • The business or commercial purpose for collecting (if applicable) Personal Information about you; and
    • The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).
  • Delete Personal Information we collected from you.
  • Stop the sale of your personal information. Cielo does not sell your data.
  • Delete Personal Information we collected from you.

Cielo will validate your request by:

  • Verifying that you control the email address associated with your Personal Information; and
  • Confirming that the context of your interactions with Cielo matches our information.

We may require additional information to verify your request, depending on the nature of the information concerned.

If you are submitting a request on someone else’s behalf, you must provide signed proof of authorization and, if necessary, we may ask for additional information. We will respond to your request consistent with applicable law.

You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

We may collect Personal Information when you register to use our Online Systems, submit or build a resume, respond to employment opportunities, complete online assessments or surveys, participate in online courseware, provide Personal Information about yourself to our coaches or contact us via e-mail, electronic forms, telephone or postal mail.

If you submit any Personal Information about other people to us or to our service providers, you represent that you have the authority to do so and to permit us to use the information in accordance with this Notice.

What safeguards are in place to protect your personal data?

Cielo takes steps to seek to protect the confidentiality and security of your personal data and applies technical and organizational measures in accordance with applicable legislation, proportionate to the nature of the information being processed.

As for all website operations, we cannot guarantee the security of any transmission of personal data over the Internet and on a non-encrypted connection. Communications over the internet such as emails are not secure unless they have been encrypted. While we strive to protect such information, we cannot ensure or warrant the security of any information transmitted to us whilst in transit. Please do not submit personal data through the site unless you accept the security implications of doing so.

If you apply for roles at Cielo, the recruitment platforms use encryption to both transmit and store your personal data and all service providers contracted to Cielo conform with recognized international information security standards.

Your rights

We take all required steps to ensure that the personal data we hold about you is accurate, complete and current so that it is reliable for its intended use. In certain circumstances under applicable laws, such as the EU GDPR, you have the following rights:

  • To be notified that your data is processed by Cielo
  • To request access to or a copy of your personal data (“Subject Access Request”). Cielo will work to resolve Subject Access Requests within one calendar month of the request being received If the request is deemed to be complex in nature, we reserve the right to apply for an extension of the prescribed period. One copy of your data will be provided free of charge. For each additional copy requested and provided, a reasonable administrative fee will apply;
  • To request that your personal data be rectified;
  • To request that we cease processing your personal data;
  • To request that we permanently erase your personal data;
  • If you have manually inputted your data in web form, you may also request a copy of your personal data in a portable machine-readable format.

If you would like to exercise any of your rights ,please write to us at: privacy.office@cielotalent.com or place your request in writing to Data Protection Officer, Cielo Talent Management Limited, 30a Great Sutton Street, London EC1V 0DU, United Kingdom.

Keeping you informed through the process: We will initially acknowledge your request and will then contact you to discuss it further and to address any specific queries you may have regarding the process. We will maintain a record of your personal data until we have finalized dealing with your request. We may also retain a record of some or all of your personal data afterwards, if this is required by applicable law.

Cookies

We use “cookies” for certain areas of our site. Cookies are small data files stored on your hard drive by a website. Cookies help us monitor and improve the functionality and usage of our site and your experience. We use cookies to see which areas and features are popular and to count visits to our websites, to recognize you as a returning visitor and to tailor your experience of the site according to your preferences. We also use cookies for targeting or advertising purposes.

We also use “web beacons” on our site or in our emails. Web beacons are electronic images that may be used to deliver cookies, count visits, understand usage of the site and to tell if an email has been opened and acted upon.

To delete or block cookies by browser settings at any time and for more general information about cookies including the difference between session and persistent cookies, visit www.allaboutcookies.org.

The cookies used on our site are categorized as follows:

  1. Cookies which are “strictly necessary” for functionality of the site’s platforms. These cookies are essential in order to enable users to move around the site and use its features.
  2. Functionality” cookies which allow the site to remember choices you make and your preferences, for example, where you register/sign-up for events and/or services.
  3. Performance/Analytical” cookies which collect information about how users navigate the site, for example, which pages users access most frequently. They identify how users interact with our site, any errors that occur, which pages are not used often, which pages take a long time to load, which pages users tend to visit and in what order. These cookies do not collect any information which could identify you and are only used to help us improve how our site works and understand what interests our site’s users.
  4. Targeting or advertising” cookies are used to deliver advertisements relevant to an identified machine or other device (not a named or otherwise identifiable person) and are tailored to interests associated with the website activity tied to that machine or device. For example, if a cookie on a third-party website recognizes that a particular product was purchased from a particular device, that cookie may “talk to” marketing cookies on the site to ensure advertisements about similar products displayed on the site are accessed from that device. These cookies are also used to limit the number of times a user sees an advertisement as well as to help measure the effectiveness of an advertising campaign. They may also remember that the site has been visited from a device and share that information with marketing organizations. The marketing cookies on our site are operated by third parties with our permission. Marketing cookies are used to monitor from which advertising source a user was directed towards our site so that we know whether it is worth us investing in that particular advertising source. If your browser sends a “do not track” signal or similar mechanism to indicate you do not wish to be tracked or receive interest-based ads, we will alert our partners to suspend use. As described more fully herein, we allow our advertising partners to collect personal information about your online activities when you leave our site.

Google Analytics: The Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses its own cookies to help us analyze how you and other users use the site. The information generated by the cookies about your use of the site (which may include your IP address, the internet browser and language you use, preferences, the date and hour of your access to the web page and the websites you access after visiting the site) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the site, compiling reports on website activity for website operators and providing other services relating to website activity and Internet usage.

Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of the site. By using the site, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

Your consent to our use of Cookies: The below explain the cookies used on the site and if you visit the site, they will be placed on your machine.

 

 

Contact us

This Privacy Notice and Cookies Policy applies to the website www.cielotalent.com (referred to as the “site” throughout the document) which is owned by Cielo, Inc. (“Cielo”, “we”, “us”, “our”) headquartered at 200 South Executive Drive, Suite 400, Brookfield, WI 53005, United States of America for itself and for other Cielo companies.

Cielo’s European head office is located at 30a, Great Sutton Street, London EC1V 0DU, United Kingdom.

If you have any questions about this Privacy Notice and Cookies Policy, please contact us at privacy.office@cielotalent.com.

Complaints and dispute resolution

We hope that you will never need to, but if you want to complain how we use your personal data, In the first instance, please direct any complaints or requests for dispute resolution under this Notice to: Data Protection Officer, privacy.office@cielotalent.com.

If you are still dissatisfied with our response, you also have the right to lodge a complaint with the relevant data protection authority. We are registered with the United Kingdom’s Information Commissioner’s Office (“ICO”).

For additional information on your rights and how to complain to the ICO, please visit https://ico.org.uk.

Changes to this Privacy Notice and Cookies Policy

We change this Notice from time to time by updating this page in order to reflect changes in the law and our privacy practices. We will update the date at the top of the Notice accordingly. If you have opted in to receive information from Cielo, we will contact you to inform you that our Notice has been updated.

By using the site, submitting your personal data to us and/or registering an account, you consent to the use of your personal data as described in this Notice (as amended from time to time).