Privacy Policy - The Hood

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Privacy Policy

Last updated: November 12, 2024

1. Introduction

Welcome to The Hood. We value your privacy and are committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our platform, including our website and mobile applications.

Data Controllers (The Hood Platform LTD will be the controller of your personal data provided to, collected by, for, or processed in connection with our Services) and Contracting Parties (registered user).

We are a social network and online platform for professionals. People use our Services to find and be found for business opportunities, to connect with others and find information. Our Privacy Policy applies to any Member or Visitor to our Services.

Our registered users (“Members”) share their professional identities, engage with their network, exchange knowledge and professional insights, post and view relevant content, learn and develop skills, and find business and career opportunities. Content and data on some of our Services is viewable to non-Members (“Visitors”).

We use the term “Designated Countries” to refer to countries in the European Union (EU), European Economic Area (EEA), and Switzerland.

Definitions

Affiliate means refers to, with respect to any person, any entity that is directly or indirectly controlled by such person or is under common control with such person.

Recruiter  means professionals assigned by the subscribers to The Hood Career Hub (“Career Hub”) who specialize in identifying, evaluating, and placing qualified maritime and energy industry talent with employers. 

Services are the digital services tailored by the Hood to support seafarers, maritime professionals, and companies within the maritime and energy industries including professional networking and social engagement; career development tools as well as resources such as education, training, news content, and charitable support. 

Talent Pool Creation means the feature that allows the premium recruitment package subscriber (the employer) or Recruiter to search and save professional profiles of applicants for future job postings.

Social Platform refers to the homepage of the Hood platform where users can find all social networking features such as timeline update, communities, resource center including News, Learning and We Care center.

Career Hub refers to the page of the Hood platform that facilitates job search and recruitment services within the maritime and energy sectors. The Career Hub provides users with tools to create job postings, search for roles, and apply for positions relevant to their skills and experience. This feature is accessible to both individual members seeking employment and businesses (subscribers to the Career Hub) looking to connect with qualified candidates.

2. Information We Collect

We collect various types of information from you, including: 

2.1 Personal Information

  • Account Information: When you register for an account, we collect your name, email address, username, and password. 
  • Profile Information: Users may provide additional information such as profile pictures, bio, date of birth, title, location, gender information, and interests.
  • Business Account Information: If you register for a business account, you will need to provide payment and billing information, including bank account and payment card details.
  • Partners: We receive personal data (e.g., your job title and work email address) about you when you use the services of our customers and partners, such as employers or prospective employers, and applicant tracking systems providing us with job application data.

Personal information to recruitment agents; you will have the option to provide personal information to any Recruitment Agent who has also registered with The Hood on the basis that the Recruitment Agent will strictly comply with all applicable data regulations and such information will only be released to the Recruitment Agent after you have given specific authorisation for such release. The Hood will have no responsibility, bear no responsibility, and bear no liability for any data protection breach by recruitment agents or any other members offering services. The Hood shall be fully indemnified by Members offering such services and shall have no responsibility, bear no responsibility, and bear no liability in relation to any of the information supplied by the Member to any recruitment agents.

2.2 Content and Usage Information

  • Posts and Comments: Any content, including text, photos, videos, and comments, that you share on the platform. We also collect personal data when you fill out a form (e.g., with demographic data or salary), respond to a survey, submit a resume, or fill out a job application on our platform.
  • Activity Information: Data about your interactions on the platform, such as posts you like, comments you make, and users you follow. 
  • Professional Information: We also may collect public information about you, such as professional-related news and accomplishments, and make it available as part of our Services, including, as permitted by your settings, in notifications to others of mentions in the news.

2.3 Technical and Device Information

  • Device Information: Information about the device you use to access our platform, including hardware model, operating system, and unique device identifiers.
  • Log Data: Information including but not limited to your IP address, browser type, pages visited, login data, device ID, information on devices, and the date and time of your visit.

2.4 Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect information about your platform activity and remember your preferences. We also allow some others to use cookies to help show relevant advertising to you or for analytics and research purposes. Please refer to our Cookies Policy for further information on our use of cookies.

● Our Services 

Any data that you include on your profile and any content you post or social action (e.g., likes, follows, comments, shares) you take on our Services will be seen by others, consistent with your settings. 

● Profile

Your profile is fully visible to all Members and customers of our Services. Subject to your settings, it can also be visible to others on or off of our Services (e.g., Visitors to our Services or users of third-party search tools). Your settings, degree of connection with the viewing Member, the subscriptions they may have, their usage of our Services, access channels and search types (e.g., by name or by keyword) impact the availability of your profile and whether they can view certain fields in your profile.

● Posts, Likes, Follows, Comments, Messages, Share

Our Services allow viewing and sharing information including through posts, likes, follows and comments.

  • When you share an article or a post (e.g., an update, image, video or article) publicly it can be viewed by everyone and re-shared anywhere (subject to your settings). Members, Visitors and others will be able to find and see your publicly-shared content, including your name (and photo if you have provided one).
  • In a group, posts are visible to others according to group type. For example, posts in private groups are visible to others in the group and posts in public groups are visible publicly. Your membership in groups is public and part of your profile, but you can change visibility in your settings.
  • Any information you share through companies’ or other organizations’ pages on our Services will be viewable by those organizations and others who view those pages’ content.
  • When you follow a person or organization, you are visible to others and that “page owner” as a follower.
  • We let senders know when you act on their message, subject to your settings where applicable.
  • Subject to your settings, we let a Member know when you view their profile. We also give you choices about letting organizations know when you’ve viewed their Page. 
  • When you like or re-share or comment on another’s content (including ads), others will be able to view these “social actions” and associate it with you (e.g., your name, profile and photo if you provided it).
  • Your employer can see how you use Services they provided for your work (e.g. as a recruiter or sales agent) and related information. We will not show them your job searches or personal messages.

● Others’ Services

You may link your account with others’ services so that they can look up your contacts’ profiles, post your shares on such platforms, or enable you to start conversations with your connections on such platforms. Excerpts from your profile will also appear on the services of others.

Subject to your settings, other services may look up your profile. When you opt to link your account with other services, personal data (e.g., your name, title, and company) will become available to them. The sharing and use of that personal data will be described in, or linked to, a consent screen when you opt to link the accounts. For example, you may link your Twitter, LinkedIn, Instagram or WeChat account to share content from our Services into these other services, or your email provider may give you the option to upload your Hood contacts into its own service. Third-party services have their own privacy policies, and you may be giving them permission to use your data in ways we would not. You may revoke the link with such accounts. 

The information you make available to others in our Services (e.g., information from your profile, your posts, your engagement with the posts, or message to Pages) may be available to them on other services. For example, search tools, mail and calendar applications, or talent and lead managers may show a user limited profile data (subject to your settings), and social media management tools or other platforms may display your posts. The information retained on these services may not reflect updates you make on The Hood.

● Related Services

We share your data across our different Services and The Hood affiliated entities.

We will share your personal data with our Affiliates to provide and develop our Services. For example, we may refer a query to Bing in some instances, such as where you’d benefit from a more up to date response in a chat experience. In regions outside the Designated Countries, we may also share your publicly-shared content (such as your public Hood posts) with our Affiliates, including Microsoft, to provide or develop their services. Where allowed, we may combine information internally across the different Services covered by this Privacy Policy to help our Services be more relevant and useful to you and others. For example, we may personalize your feed or job recommendations based on your learning history.  

● Service Providers

We may use others to help us with our Services.

We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, customer support, marketing and development). They will have access to your information (e.g., the contents of a customer support request) as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes. If you purchase a Service from us, we may use a payments service provider who may separately collect information about you (e.g., for fraud prevention or to comply with legal obligations).

● Legal Disclosures

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you; (3) investigate and defend ourselves against any third-party claims or allegations; (4) protect the security or integrity of our Services or the products or services of our Affiliates (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of The Hood, our Members, personnel or others. We attempt to notify Members about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

3. How We Use Your Information

Under data protection laws, we can only use your personal data if we have a proper reason, e.g.:

  • you have given consent – where we need your consent, we will ask for it separately of this policy and you can withdraw consent at any time;
  • to comply with our legal and regulatory obligations;
  • to fulfil our contract with you or take steps at your request before entering into a contract; or
  • for our legitimate interests or those of a third party.

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You have the right to object to processing based on legitimate interests. We must then stop the processing unless we can demonstrate compelling legitimate grounds which override your interests, rights and freedoms or the processing is required to establish, exercise or defend legal claims.

We use your information for various purposes, including:

3.1 To Provide and Improve Our Services

  • To operate and maintain the platform. 
  • To personalize your experience and display content based on your preferences and interests.
  • To allow you to seek out, and be found for, career opportunities. Your professional profile (work experience, salary expectation, etc) can be found by those looking to hire (The Hood’s Basic or Premium Recruitment package subscribers), or to be hired by you. We can use your data to recommend jobs to you and you to recruiters.
  • Premium Recruitment services: our Premium Recruitment services allow certain paying users to search for and contact individual users through our platform as part of the Talent Pool Creation. They may choose to offer you suitable job opportunities directly or send promotional/informational content through social media. Premium subscriber- companies can store information they have about you such as your resume or contact information with your approval.

Some, or all, of the above personal and professional data will only be released if you provide specific authority for its viewing and/or release, by following dedicated steps specified on the Recruitment Platform.

We may also use your personal data to improve, develop, and provide products and Services, develop and train artificial intelligence (AI) models, develop, provide, and personalize our Services, and gain insights with the help of AI, automated systems, and inferences, so that our Services can be more relevant and useful to you and others. You can review The Hood’s Responsible AI principles here and learn more about our approach to generative AI here. Learn more about the inferences we may make, including as to your age and gender and how we use them.

Stay Connected 

Our Services allow you to stay in touch and up to date with colleagues, friends, and professional contacts (including recruitment agents). To do so, you can “connect” with the professionals who you choose, and who also wish to “connect” with you. Subject to your and their settings, when you connect with other Members, you will be able to search each others’ connections in order to exchange professional opportunities.

We use data about you (such as your profile, profiles you have viewed or data provided through address book uploads or partner integrations) to help others find your profile, suggest connections for you and others (e.g. Members who share your contacts or job experiences) and enable you to invite others to become a Member and connect with you. You can also opt-in to allow us to use your precise location or proximity to others for certain tasks (e.g. to suggest other nearby Members for you to connect with, calculate the commute to a new job, or notify your connections that you are at a professional event). 

It is your choice whether to invite someone to our Services, or allow another Member to become your connection. When you invite someone to connect with you, your invitation will include your network and basic profile information (e.g., name, profile photo, job title, region). We will send invitation reminders to the person you invited. You can choose whether or not to share your own list of connections with your connections.

Visitors have choices about how we use their data.

Stay Informed

Our Services allow you to stay informed about news, events and ideas regarding professional topics you care about, and from professionals you respect. Our Services also allow you to improve your professional skills, or learn new ones. We use the data we have about you (e.g., data you provide, data we collect from your engagement with our Services and inferences we make from the data we have about you), to personalize our Services for you, such as by recommending or ranking relevant content and conversations on our Services. We also use the data we have about you to suggest skills you could add to your profile and skills that you might need to pursue your next opportunity. We use your content, activity and other data, including your name and photo, to provide notices to your network and others.

Career

Our Services allow you to explore careers, evaluate educational opportunities, and seek out, and be found for, career opportunities. Your profile can be found by those looking to hire (for a job or a specific task) or be hired by you. You can signal that you are interested in changing jobs and share information with recruiters. We will use your data to recommend jobs to you and you to recruiters. We may use automated systems to provide content and recommendations to help make our Services more relevant to our Members, Visitors and customers. Keeping your profile accurate and up-to-date may help you better connect to others and to opportunities through our Services.

Productivity 

Our Services allow you to collaborate with colleagues, friends and search for potential jobs. (Our Services allow you to communicate with other Members and schedule and prepare meetings with them).

3.2 To Communicate With You

  • To send you notifications, updates, and promotional messages.
  • To respond to your inquiries and provide customer support.

● To identify your Device and Location

When you visit or leave our Services (including some plugins and our cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to and the time of your visit. We also get information about your network and device (e.g., IP address, proxy server, operating system, web browser and add-ons, device identifier and features, cookie IDs and/or ISP, or your mobile carrier). If you use our Services from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location.

● For Messages

We collect information about you when you send, receive, or engage with messages in connection with our Services. We also use automatic scanning technology on messages to support and protect our site. For example, we use this technology to suggest possible responses to messages and to manage or block content that violates our User Agreement or community standards from our services.

3.3 For Security and Compliance

  • To protect against and prevent fraud, unauthorized transactions, claims, and other liabilities.
  • To comply with legal obligations and regulatory requirements.

3.4 Advertising and Marketing

  • To serve you tailored ads both on and off our platform. We offer you choices regarding personalized ads, but you cannot opt-out of seeing other ads. 
  • In addition to advertising, we use Members’ data and content for invitations and communications promoting membership and network growth, engagement and our platform, such as by showing your connections that you have used a feature on our platform.

4. Sharing Your Information

We do not sell or rent your personal information. We may share your information with:

4.1 Service Providers

Third-party vendors who we may employ to assist us in operating our Career Hub and Social Platform and providing our services, including, but not limited to marketing and market research. 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

4.2 Legal Requirements

To comply with any applicable law, legal process and obligations, respond to government requests, investigate, detect, prevent or take action regarding illegal activities, exercise our rights to defend against legal claims and protect our rights and the rights of others.

4.3 Change in Control or Sale

We may share your data when our business is sold to others, but it must continue to be used in accordance with this Privacy Policy. 

We can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

5. Your Choices, Rights and Obligations

 We will not keep your personal data for longer than we need it for the purpose for which it was collected or as required by law. We keep most of your personal data for as long as your account is open. 

We generally retain your personal data as long as you keep your account open or as needed to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of our Services. Even if you only use our Services when looking for a new job every few years, we will retain your information and keep your profile open, unless you close your account. In some cases we choose to retain certain information (e.g., insights about Services use) in a depersonalized or aggregated form.

5.1 Access and Update

You can access and update your personal information through your account settings.

You have choices about the information on your profile, such as your education, work experience, skills, photo, city or area and endorsements.

You don’t have to provide additional information on your profile; however, profile information helps you to get more from our platform, including helping recruiters and business opportunities find you.

It’s your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add personal data to your profile that you would not want to be publicly available.

We provide many choices about the collection, use and sharing of your data, from deleting or correcting data you include in your profile and controlling the visibility of your posts to advertising opt-outs and communication controls. We offer you settings to control and manage the personal data we have about you.

For personal data that we have about you, you can: 

Delete Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).

Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.

Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).

Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.

Visitors can learn more about how to make these requests here. You may also contact us using the contact information below, and we will consider your request in accordance with applicable laws. 

Residents in other regions, may have additional rights under their laws.

5.2 Deletion

You may request the deletion of your account and personal information by contacting us.

If you choose to close your Hood account, your personal data will generally stop being visible to others on our Services within 24 hours. We generally delete closed account information within 30 days of account closure, except as noted below. 

We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse (e.g., if we have restricted your account for breach of our community standards), enforce our Terms and Conditions, or fulfil your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed.

Information you have shared with others (e.g., through InMail, updates or group posts) will remain visible after you close your account or delete the information from your own profile or mailbox, and we do not control data that other Members have copied out of our Services. Groups content and ratings or review content associated with closed accounts will show an unknown user as the source. Your profile may continue to be displayed in the services of others (e.g., search tools) until they refresh their cache. 

5.3 Marketing Communications

You can opt-out of receiving promotional emails by following the unsubscribe instructions in the emails.

We contact you and enable communications between Members. We offer settings to control what messages you receive and how often you receive some types of messages.

We will contact you through email, mobile phone, notices posted on our websites or apps, messages to your Hood inbox, and other ways through our Services, including text messages and push notifications. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use our Services, network updates, reminders, job suggestions and promotional messages from us and our partners. You may change your communication preferences at any time. Please be aware that you cannot opt out of receiving service messages from us, including security and legal notices.

We also enable communications between you and others through our Services, including for example invitations,  groups and messages between connections. 

5.4 Data Subject Rights

Depending on your location, you may have additional rights under applicable data protection laws, such as the right to object to processing, request data portability, or lodge a complaint with a supervisory authority.

6. Your rights in relation to your data

6.1 Data protection legislation gives you, the data subject, various rights in relation to your personal data that we hold and process. These rights are exercisable without charge, and we are subject to specific time limits in terms of how quickly we must respond to you. Those rights are, in the main, set out in Articles 12–23 of the EU GDPR. They are as follows:

6.1.1 Right of access – the right to obtain from us confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, access to that personal data and various other information, including the purpose for the processing, with whom the data is shared, how long the data will be retained, and the existence of various other rights (see below).

6.1.2 Right to rectification – the right to obtain from us, without undue delay, the putting right of inaccurate personal data concerning you. 

6.1.3 Right to erasure – sometimes referred to as the ‘right to be forgotten’, this is the right for you to request that, in certain circumstances, we delete data relating to you.

6.1.4 Right to restrict processing – the right to request that, in certain circumstances, we restrict the processing of your data.

6.1.5 Right to data portability – the right, in certain circumstances, to receive that personal data which you have provided to us in a structured, commonly used and machine-readable format, and the right to have that personal data transmitted to another controller. 

6.1.6 Right to object – the right, in certain circumstances, to object to personal data being processed by us where it is in relation to direct marketing, or in relation to processing supported by the argument of legitimate interest.

6.1.7 Right not to be subject to automated decision making – the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

6.2 Full details of these rights can be found in the EU GDPR or by reference to guidance produced by the Information Commissioner’s Office.

6.3 In the event that you wish to exercise any of these rights you may do so by:

6.3.1 contacting us using any medium you wish, including in writing, by telephone, by text, electronically, or using such social media as we employ for communication purposes;

6.3.2 by completing a form which we can supply to you for this purpose; or

6.3.3 through a third-party whom you have authorised for this purpose.

7. Data Security

We monitor for and try to prevent security breaches. Please use the security features available through our Services.

We implement reasonable security safeguards designed to protect your data. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

8. Cross-Border Data Transfers

We process data both inside and outside of the EEA and rely on legally-provided mechanisms to lawfully transfer data across borders.

9. Changes to This Privacy Notice

We may update this Privacy Notice from time to time. We will notify you of any changes by posting the new Privacy Notice on our platform. You are advised to review this Privacy Notice periodically for any changes.

10. Contact Us

If you have any questions or concerns about this Privacy Notice, please contact us at support@the-hood.com.

You can also contact our Data Protection Officer by email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint at dpo@the-hood.com.

If you have received a response to your complaint by the Company which you deem to be unsatisfactory, you may also complaint to the Office of the Commissioner for Personal Data Protection in Cyprus, (http://www.dataprotection.gov.cy).

MINORS

Individuals below the age of 16 are not entitled to receive the Company’s Services.