Privacy Policy

1. The Company

Etwosteps Limited (the Company) is a company registered in England, UK number 7173026. Etwosteps operates the website known as twosteps.com and all other websites associated with twosteps and its brand. This policy applies to all our websites regardless of where you have accessed this information from.

The Company operates in many countries around the globe and strives to fulfil our obligations in respect of the management of your information in each of those countries.

The Policy applies to the provision of personal information which allows us to identify you. This policy does not affect our obligation of confidentiality. The obligation to respect your privacy is in addition to obligations of confidentiality.


2. Personal Information

The Company is an online jobs board offering job vacancies for those individuals working in professional services around the world. Those vacancies are posted by companies advertising their own vacancies. Where links are provided to other websites and you choose to access those websites etwosteps limited has no responsibility for the use of those sites and how they collect and store your personal information.

The Company may collect and hold the following personal information provided by you when registering and accessing the secure private site:

  • Your name
  • Diversity information in relation to your gender, age group, religion, ethnicity and any disability.
  • Address and contact details (electronic and physical).
  • Occupation
  • Career history
  • CV drawn up by you.
  • References
  • Professional qualifications
  • Results of aptitude and other tests
  • Your job preferences.
  • E-mail correspondence between employers and jobseekers where you have chosen to correspond using the internal contact management systems.
  • Your IP address.
  • Billing and Account Information.
  • Demographic information.

You can log in and change your account details at any time and alter the preferences in your profile.


3. Use and disclosure

Personal information is collected for the purpose of:

  • Allowing you to apply for suitable jobs that you have selected.
  • Allowing employers to contact you in relation to their own vacancies where you have opted to allow them to do so.
  • Allowing the company to monitor fraud and abuse.
  • Allowing the company to ensure job ads are directed to the right candidates.
  • Allowing the company to monitor and track our own external advertising.
  • Processing payment, financial statements and administering the internal accounting systems.

We may also collect the information in order to provide adequate information about a candidate’s position in the market place.

The Company will disclose this information to:

  • Prospective employers when you apply for an advertised position or when you have consented to release your details to potential employers in their search for suitable candidates and your search for a suitable position.
  • Our service providers (eg the organisations that provide testing services to us or our information service providers);
  • Our insurer.
  • When we are required to do so by law.


4. How we collect personal information

The Company only collects information provided by you when you have voluntarily registered your details on our website or over the telephone.

When you visit our website or download information from it, our Internet Service Provider (ISP) makes a record of your visit and records the following information:

  • your Internet address;
  • your domain name, if applicable; and
  • the date and time of your visit to the website.

Our ISP also collects information such as the pages our users access, the documents they download, links from other sites they follow to reach our site, and the type of browser they use. However, this information is anonymous and is only used for statistical and website development purposes.
 

5. Use of Cookies

Our website uses cookies. A cookie is a small message given to your web browser by our web server. The browser stores the message in a text file, and the message is then sent back to the server each time the browser requests a page from the server.

We use cookies to measure how you use the site and how much traffic is attributed to each section of the site. We may also use cookies to improve the functionality of our website and to direct users to the most relevant parts of the site.

When cookies are used by this site, they are used to store information relating to your visit such as a unique identifier, or a value to indicate whether you have seen a web page.

Most Internet browsers are set up to accept cookies. If you do not wish to receive cookies, you may be able to change the settings of your browser to refuse all cookies or to notify you each time a cookie is sent to your computer, giving you the choice whether to accept it or not.
 

6. What happens if you choose not to provide the information

You are not obliged to give us your personal information. However, if you choose not to provide the Company with some or all of the personal information requested we may:

(a) not be able to provide you with any services through the website;

(b) be more restricted in providing you the full range of services; and

(c) decline to allow you to register on the website.


7. Use and Disclosure

We will use personal information for the purposes for which it was collected.

Having read and understood our terms of use, including this policy, you will have provided your authority and consent for us to collect, use and disclose your personal information. The Company through its website allows you to monitor the level of information that you disclose at different times and it is always your choice to do so.


8. Storage and Security

We will take all reasonable steps to protect the security of the personal information we hold. This includes appropriate measures to protect electronic materials and materials stored and generated in hard copy.

The Company has Data Storage facilities in different geographic locations internationally complying with local laws wherever practicable.

It is possible that your personal information could be unlawfully and/or maliciously observed by a third party while in transit over the Internet or while stored on our Website, our secure storage servers or secure third party servers. Etwosteps disclaims all and any liability to you to the maximum possible pursuant to the law should this occur.


9. Sending Information to Other Locations

The Company conducts itself on a global basis. Accordingly, information may be sent to employers overseas.

If you are within the European Economic Area (the EEA) please note that information may be transferred to locations outside the EEA. Any data sent or uploaded by you may be accessible in jurisdictions outside the country or your location including outside the EEA.

Your personal data may be controlled and processed by any of etwosteps limited offices and affiliates in the operation and management of twosteps.com or its derivative websites, some of which are outside the EEA.

By continuing to use this website and by providing any personal data (including sensitive personal data) to us via this website or e-mail addresses provided on this website, you are consenting to such transfers, provided that they are in accordance with the purposes set out above. Please do not send us any personal data if you do not consent to the transfer of this information to locations outside the your location including, if applicable, outside the EEA).

When we do send information overseas, and the laws of the receiving countries do not have comparable privacy protection laws, we will take all reasonable steps to make contractual arrangements that provide for privacy protection of the personal information that we send overseas.


10. Access and Complaints

(a) Overriding principles

At all times, the conduct under this Policy will be governed by the following principles:

  • all requests for access or any complaints will be treated seriously;
  • all requests or complaints will be dealt with promptly;
  • all requests or complaints will be dealt with in a confidential manner; and
  • your request to access your personal information, or any complaints that you make, will not affect your existing obligations or affect the commercial arrangements between you and the Company.

(b) Form of Access

The Company will provide access by allowing you to inspect, take notes of or receive copies or print outs of the personal information that the Company holds about you.

You can make your request in writing to the Privacy Manager at privacy@twosteps.com.

In making your request, you will have to provide proof of your identity (for example, driver’s license or other appropriate identification). This is necessary to ensure that personal information is provided only to the correct individuals and that the privacy of others is not undermined.

(c) When will Access be denied?

Access will be denied if:

  • the request does not relate to the personal information of the person making the request;
  • providing access would pose a serious and imminent threat to life or health of a person;
  • providing access would create an unreasonable impact on the privacy of others;
  • the request is frivolous and vexatious;
  • the request relates to existing or anticipated legal proceeding;
  • providing access would prejudice negotiations with the individual making the request;
  • access would be unlawful;
  • denial of access is authorised or required by law;
  • access would prejudice law enforcement activities;
  • access discloses a ‘commercially sensitive’ decision making process or information; or

Where possible, the Company will favour providing access. It may do so by providing access to the appropriate parts of the record or by using an appropriate ‘intermediary’.

(d) Time

We will take all reasonable steps to provide access within 30 days of your request. In cases where the request is not complicated or does not require access to a large volume of information, we will take all reasonable steps to provide that information within 14 days.

(e) Costs and charges

The Company has a right to charge you a reasonable fee for providing access. For example:

  • photocopying charges;
  • delivery cost of information stored off-site; and
  • access to electronic databases.

The charge may include the cost of our professional time.

(f) Complaints

If you have provided us with personal information, you have a right to make a complaint, have it investigated and dealt with. The Company tries to resolve complaints at the local level if possible. If you wish to make a complaint, please contact the Privacy Manager at privacy@twosteps.com.

The Company will keep a record of your complaint and the outcome.

The Company is unable to deal with anonymous complaints. This is because it is unable to investigate and follow up such complaints. However, in the event that an anonymous complaint is received, we will note the issues raised and try to resolve them appropriately.


11. Right to Review

The Company reserves the right to review, and if necessary, revise or amend the terms of this policy.

 

  

Etwosteps Limited
25 June 2010