Our Commitment to Your Privacy
Version: February 1, 2020
Cielo recognizes the importance of transparent and responsible use of your personal information. This Privacy and Cookies Policy (the “Policy”) 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:
Who can access your information
The information you provide to us will be shared within our global group of companies operating under the Cielo brand. All references to “Cielo” in this Privacy and Cookies Policy therefore include Cielo and its related group companies (the “Group”), unless stated to the contrary.
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 framework of organizational and technical measures to ensure the personal information you provide is kept secure and that your access rights are respected regardless of the country in which it is processed.
The full list of our offices and companies can be found here.
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 want to contact us or to use certain facilities we provide on this site, you will need to provide 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 Policy.
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 you have not provided personal data directly to us, 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.
Applying to work for Cielo
If you apply for a role with Cielo or with one of Cielo’s clients, 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 your details on our careers site.
If we collect sensitive information from you during the recruitment process, we will inform you and, if legally required, seek your explicit consent to use it, 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. These include 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 persona data is used are:
- We process Personal Data as instructed by our clients and under their brands (“We Become You”). You will not be approached directly from Cielo Talent and this reflects our clients outsourcing some of their operations to us.
- When we contact you as Cielo, we are processing Personal Data under our brand to help you secure a new and exciting role with one of our global clients. For this purpose, you will be approached under the Cielo Search Solutions or Cielo’s Total Talent Solutions’ brands.
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;
- The processing is necessary in order for us to comply with our legal obligations (such as compliance with anti-money laundering 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 fulfill 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 solutions 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 personal information does not personally identify you or any other user of the site. It may be used for statistical analysis and administration, including analysis of trends, tailoring services, risk assessment and analysis of costs and charges in relation to our services.
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 policy (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 properly need to know these details for 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 Policy.
Use of data processors: Data processors are third parties who provide elements of our services for us, including technology providers that we use for our recruitment and marketing activities and 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. 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.
Website hosting and management: The site is hosted on Microsoft Azure and the content management system (CMS) is Umbraco. Here are links to their privacy policies: https://azure.microsoft.com/en-us/support/legal/ and https://umbraco.com/about-us/privacy/.
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:
- We use Lumesse’s Talent Link and iCIMS for our recruitment activities. Here are links to their privacy and security policies: https://www.lumesse.com/privacypolicy and https://www.icims.co.uk/legal/privacy-policy.
International transfers of personal data: 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. If you object to your data being transferred outside the EEA, please visit our Preference Center to revoke your consent or email firstname.lastname@example.org.
Where personal data is transferred to countries outside of the EEA and Switzerland, Cielo will put in place other measures to ensure that those transfers are adequately protected (as required by applicable law).
Individuals in other regions may also have their personal data transferred outside their own country.
Disclosure of 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 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. 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 email@example.com.
California Consumer Privacy Act (CCPA)
Cielo does not sell Personal Information to third parties outside the scope of recruitment activities. According to §1798.45(2)A) of the Cal. Civ. Code, the provisions of the CCPA shall not apply where: "Personal information that is collected by a business about a natural person in the course of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the natural person’s personal information is collected and used by the business solely within the context of the natural person’s role or former role as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or a contractor of that business."
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 organisational measures in accordance with applicable legislation. 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. So, 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 SkyRecruit CRM (Yello) and recruitment platforms use encryption to transmit and store your personal data and the service providers listed above all comply under contract with international information security standards.
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 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. 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 for your personal data to 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: firstname.lastname@example.org or place your request in writing to Gian Zambrini, Privacy Officer, Cielo Talent, Gray’s Inn House, 127 Clerkenwell Road, London EC1R 5DB, 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 finalised 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.
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:
- 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.
- “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.
- “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.
- “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.
This Privacy 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 Gray’s Inn House, 127 Clerkenwell Road, London EC1R 5DB, United Kingdom.
If you have any questions about this Privacy and Cookies Policy, please contact us at email@example.com.
Complaints and Dispute Resolution
Please direct any complaints or requests for dispute resolution under this Policy to:
Gian Zambrini, Privacy Officer, Cielo at firstname.lastname@example.org.
Changes to this Privacy and Cookies Policy
We change this Policy 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 Policy accordingly. If you have opted in to receive information from Cielo, we will contact you to inform you that our Policy 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 Policy (as amended from time to time).