Sixley | Privacy policy

Privacy policy

At our core, we value privacy and confidentiality.

So, if you’re the hirer, your network remains your network – Sixley only contacts your network at your bequest and only for your specific job.

And, if you’ve suggested the role to a prospective candidate, Sixley doesn’t share those details (with anyone, even the hirer) unless the person recommended confirms that they’re interested in the job.

You can read our full privacy policy below.

Privacy Policy, effective as of 6 September 2018

Sixley is a peer-to-peer recommendations platform that allows individuals to express interest in or recommend their peers for roles posted by hiring companies.

This Privacy Policy (“Privacy Policy”) describes our privacy policies. Please read this Privacy Policy carefully to learn how we collect, use, share and otherwise process information relating to individuals (“Personal Data”), and your rights and choices regarding our processing of your Personal Data.

This policy is subject to regular review and was last updated on the date that appears at the top of this page.

1. Processing activities covered

This Privacy Policy applies to the following processing activities:

  • Visiting our websites which display or link through to this Privacy Policy
  • Using Sixley for the purpose of hiring for roles
  • Recommending people for jobs
  • Expressing interest or applying for jobs
  • Receiving communications from us including emails, texts or faxes
  • Registering for our events

Our website may contain links to other websites, applications and services maintained by third parties including those of hiring companies. The information practices of other services are governed by the third-party privacy statements, which we encourage you to review to better understand those third-parties’ privacy practices.

2. Responsible Sixley entity

Sixley Ltd is the controller of your Personal data and responsible for the collection, processing and disclosure of your Personal Data as described in this Privacy Policy, unless expressly specified otherwise.

3. What Personal Data do we collect?

3.1 Personal Data we collect directly from you

The Personal Data that we collect directly from you may include the following:

  • If you express an interest in a specific role we generally ask you to provide us with your name, relevant role, email, telephone number, CV, Linkedin profile, and other self-entered information regarding your interest in the role
  • If you recommend someone for a specific role, we generally ask you to provide us with your name, relevant role, email and an optional personal statement on the person you are recommending
  • If you suggest someone else who may be able to help with a role, we generally ask you to provide us with your name, relevant role, and email
  • If you recommend someone who may either be interested in or could help with a role, we ask you to provide their name and email
  • If you express an interest in obtaining additional information about our services, request customer support, use our “Contact Us” or similar features, register to use our websites, sign up for an event or download certain content, we generally ask you to provide us with your contact information such as your name, job title, company name, address, telephone number, email or username and password
  • If you pay for services or receive reward / finder’s fee payments via our websites, we may also require you to provide us with financial information and billing information such as billing name and address, credit card number or bank account information
  • If you use and interact with our websites, we automatically collect log files and other information about your device and your usage of our website through cookies, web beacons or similar technologies, such as IP-addresses or other identifiers, which may qualify as Personal Data
3.2 Personal Data we collect from other sources

We may also collect information about you from other sources, including from our Clients and other people who may have recommended or introduced you to Sixley, and combine this information with Personal Data provided by you. This helps us:

  • For your applications, recommendations or introductions to Sixley’s clients (Clients) for specific roles, understand and provide contextual information on why and by who you were introduced or recommended
  • Verify whether you were either hired by, not hired by or already in separate discussions with our Client for a specific role
  • Verify base salary for a successful role for the purpose of invoicing our Clients
  • Analyse and better understand the relationship between recommendations and job descriptions and roles for the purpose of improving our service
  • Update, expand and analyse our records for the purposes of improving our service
  • Where you have been recommended by a third-party for a role or suggested as someone who may know someone suitable for a role, inform you about new opportunities and roles
  • Where you have opted into Sixley’s Superconnector or Talent Pool programmes, inform you about new opportunities and roles
  • Allow Clients to readily access their employees’ details for the purposes of asking them for recommendations and, where relevant, incorporating their in-house bounty schemes
  • Identify new Clients

In particular, we collect Personal Data from the following sources:

  • From people who may have recommended or introduced you to Sixley
  • From our Clients who i) provide descriptions about the roles they are looking to hire; and ii) provide relevant information on whether candidates were hired, not hired or already in separate discussions for specific roles; or iii) who may wish to upload information about their employees including role, contacts and permissions
  • Business contact information, including mailing address, job title, email address, phone number, ‘intent data’ which is web user behaviour data, IP addresses, social handles, LinkedIn URL and custom profiles from third party data providers for the purposes of targeted advertising, delivering relevant email content, event promotion and profiling.

4. Sharing Data with Third-Parties

4.1 Data we share with Clients looking to hire specific roles

If you express an interest in or recommend someone for a specific role, then for the express purpose of recruiting that role, Sixley may share your Personal Data with the Client looking to hire that role. This may include:

  • If you express an interest in a specific role – your name, relevant role, email, telephone number, information contained within your CV, information contained within your Linkedin profile, and other self-entered information regarding your qualifications for and interest in the role
  • If you recommend someone who then expresses an interest in a specific role – your name, relevant role, your connection to the person you recommended, and your optional statement on the person you are recommended
  • If you recommend someone whose subsequent direct or indirect recommendations express an interest in a role – your name, relevant role and your connection to the person you recommended
  • If you register for Sixley’s Superconnector or Talent Pool programmes – 1) we may share your data on an anonymised basis with Clients looking to hire specific roles; and 2) your identifiable personal data will be shared with Clients only if you choose to recommend someone for or express interest in a specific role
  • If you do not express an interest in or recommend someone for a specific role, your Personal Data will not be shared with the Client regarding that role.
4.2 Other parties that we may share data with

We may share your Personal Data with the following recipients:

  • If you were recommended by a third-party for a specific role, we may let them know whether or not you took some form of action based on their recommendation. We will not inform them as to the specific action that you took i.e. we will not inform them as to whether you applied for a job, recommended someone else or could not help
  • If you were hired for a specific role that you were recommended for via Sixley, we will notify the person who recommended you that you were hired for the purpose of sharing with them the hiring reward / finders’ fee
  • Our contracted service providers which provide services such as IT and system administration and hosting, credit card processing, research and analytics, marketing, customer support and data enrichment; such service providers comprise companies located in the countries in which we operate
  • If you register for an event organised by Sixley in conjunction with a third-party, we may share your Personal Data with the third-party to the extent this is required on the basis of the contract with you to process your registration and ensure your participation in the event; in such case, the third-party will process the relevant Personal Data as a separate controller and will provide you with further information on the processing of your Personal Data, where required
  • With third–party social networks, advertising networks and websites, which usually act as separate controllers, so that Sixley can market and advertise on third party platforms and websites
  • In individual cases we may also share Personal Data with professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in countries in which we operate
  • If we are involved in a merger or reorganisation, sell a website or business unit, or if all or a portion of our business, assets or stock are acquired by another company, we may transfer some or all of your Personal Data to such third party. In accordance with applicable laws, we will use reasonable efforts to notify you of any such transfer of Personal Data to an unaffiliated third party as processing of your Personal Data will be required for the purposes set out in “Purposes for which we process Personal Data and on which legal bases” section above.

5. What device and usage data we process

We use common information-gathering tools, such as log files, cookies, web beacons and similar technologies to automatically collect information, which may contain Personal Data, from your computer or mobile device as you navigate our websites or interact with emails we have sent you.

5.1 Log Files

As is true of most websites, we gather certain information automatically via log files. This collected information may include your Internet Protocol (IP) address (or proxy server), device and application identification numbers, your location, your browser type, your Internet service provider and/or mobile carrier, the pages and files you viewed, your searches, your operating system and system configuration information, and date/time stamps associated with your usage. This information is used to analyse overall trends, to help us provide and improve our websites and to guarantee their security and continued proper functioning. We also collect IP addresses from users when they log into the services as part of the Company’s security features.

5.2 Cookies, web beacons and other tracking technologies

We use cookies and similar technologies such as web beacons, tags and Javascript alone or in conjunction with cookies to compile information about usage of our websites and interaction with emails from us.

When you visit our websites, our servers or an authorised third party may place a cookie on your browser, which can collect information, including Personal Data, about your online activities over time and across different sites. Cookies allow us to track overall usage, determine areas that you prefer, make your usage easier by recognizing you and providing you with a customised experience.

We use both session-based and persistent cookies. Session cookies exist only during one session and disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer or device after you close your browser or turn off your computer. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our websites or services. To opt-out from tracking by Google Analytics, please use the specific opt-out mechanism as indicated further below.

We also use web beacons on our websites. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to one of our websites. Such tracking technologies are used to operate and improve our websites and email communications and track the clicking of links or opening of emails.

The following sets out how we use different categories of cookies and similar technologies, as well as information on your options for managing the settings for the data collection by these technologies:

Type of Cookies Description Managing Settings
Required cookies Required cookies enable you to navigate our websites and use their features, such as accessing secure areas of the websites.

If you have chosen to identify yourself to us, we may place on your browser a cookie that allows us to uniquely identify you when you are logged into the websites and to process your online transactions and requests.

Because required cookies are essential to operate the websites there is no option to opt out of these cookies.
Functionality cookies Functional cookies allow us to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features.

Functional cookies may also be used to improve how our websites function and to help us provide you with more relevant messages, including marketing communications. These cookies collect information about how our websites are used, including which pages are viewed most often.

We may use our own technology or third-party technology to track and analyse usage and volume statistical information to provide enhanced interactions and more relevant communications, and to track the performance of our advertisements.

In particular, we use Google Analytics (“Google Analytics”), a web analytics service provided by Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA as our processor. Google Analytics uses cookies to help us analyse how our websites are used, including the number of visitors, the websites visitors have come from, and the pages they visit. This information is used by us to improve our websites.

Sixley may also utilize HTML5 local storage or Flash cookies for these purposes. Flash cookies and HTML local storage are different from browser cookies because of the amount of, type of, and how data is stored.

To manage the use of functional cookies on our websites, consult your individual browser settings for cookies. Note that opting out may impact the functionality you receive when using our websites.

To opt out from data collection by Google Analytics, you can download and install a browser add-on, which is available here.

To learn how to control functional cookies using your browser settings click here.

To learn how to manage privacy and storage settings for Flash cookies click here.

Targeting or Advertising cookies We may sometimes use cookies delivered by us or third parties to show you ads for our products that we think may interest you on any devices you may use and to track the performance of our advertisements. For example, in these cases, cookies may collect and remember information such as which browsers have visited our websites. The information provided to third parties does not include Personal Data, but this information may be re-associated with Personal Data after the Company receives it.

Sixley may also contract with third party advertising networks that collect IP addresses and other information from web beacons (see below) on our websites, from emails, and on third-party websites. Advertising networks follow your online activities over time and across different sites or other online services by collecting device and usage data through automated means, including through the use of cookies. These technologies may recognize you across the different devices you use, such as a desktop or laptop computer, smartphone or tablet. Third parties use this information to provide advertisements about products and services tailored to your interests. You may see their advertisements on other websites or mobile applications on any of your devices. This process also helps us manage and track the effectiveness of our marketing efforts.

See section below, to learn more about these and other advertising networks and your ability to opt out of collection by certain third parties.
5.3 Notices on behavioural advertising and opt-out

As described above, we or third parties may place or recognise a unique cookie on your browser when you visit our websites for the purposes of serving you targeted advertising (also referred to as “online behavioural advertising” or “interest-based advertising”). To learn more about targeted advertising, advertising networks and your ability to opt out of collection by certain third parties, please visit the opt-out pages of the Network Advertising Initiative, here, and the Digital Advertising Alliance, here.

To manage the use of targeting or advertising cookies on this website, consult your individual browser settings for cookies. To learn how to manage privacy and storage settings for Flash cookies click here. Various browsers may offer their own management tools for removing HTML5 local storage.

5.4 Opt-Out from the collection of device and usage data

Where required by law, we will ask you for your consent to our use of cookies when you first visit our Services. You will be presented with a choice of cookies for which we need to ask for your consent and a description of what function these cookies perform. If you agree to cookies, we will place a cookie on your device. You may change your cookie preferences at any time by clicking here. If you wish to opt-out of interest-based advertising click here. Please note, however, that by blocking or deleting cookies and similar technologies used on our websites, you may not be able to take full advantage of the website.

While some internet browsers offer a “do not track” or “DNT” option that lets you tell websites that you do not want to have your online activities tracked, these features are not yet uniform and there is no common standard that has been adopted by industry groups, technology companies or regulators. Therefore, we do not currently commit to responding to browsers’ DNT signals with respect to our websites. Sixley takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.

5.5 Social Media Features

Our websites may use social media features, such as the Facebook “like” button, the “Tweet” button and other sharing widgets (“Social Media Features”). You may be given the option by such Social Media Features to post information about your activities on a website to a profile page of yours that is provided by a third-party social media network in order to share with others within your network. Social Media Features are either hosted by the respective social media network or hosted directly on our website. To the extent the Social Media Features are hosted by the respective social media networks, the latter may receive information that you have visited our website from your IP address. If you are logged into your social media account, it is possible that the respective social media network can link your visit of our websites with your social media profile.

Sixley also allows you to log in to certain of our websites using sign-in services such as Sign In with LinkedIn.  These services will authenticate your identity and provide you the option to share certain Personal Data with us such as your name and email address to pre-populate our sign-up form.   Sixley does not share information back to those sign-in services other than the fact that you have authenticated with Sixley.

Your interactions with Social Media Features are governed by the privacy policies of the companies providing the relevant Social Media Features.

6. Purposes for which we process Personal Data and the legal basis on which we rely

We collect and process your Personal Data for the purposes and on the legal bases identified in the following:

  • Performing our service as a platform for hiring companies to ask for and manage recommendations and applications for roles from their extended network: We will process your Personal Data to the extent this is necessary to fulfil our obligations under the applicable terms of use / service for i) facilitating a job search; or ii) contacting your recommendations; or iii) informing hiring companies about your stated interest in a specific role; or iv) informing you on the progress, outcome or resulting opportunities arising of a search that you interacted with including any resulting rewards and contributions to individuals and charities; or v) contacting people who have opted into Sixley role-finding initiatives including the Talent Pool and Superconnector programmes; or vi) analysis of data for the purpose of improving our service to hiring companies, recommenders and applicants. When you have not been presented with and agreed our terms and conditions, or when we have not entered into a contract with you, we base the processing of your Personal Data on our legitimate interest to present employment-related services or opportunities to you based on recommendations by others who know you
  • Automated decision-making: If you opt into the Superconnector and Talent Pool programmes, we will process your Personal Data to the extent that this is necessary for the purpose of our legitimate interests of identifying relevant and suitable opportunities to you
  • Providing our websites: We will process your Personal Data to the extent this is necessary for the performance of our contract with you for the use of our websites and to fulfil our obligations under the applicable terms of use/service; where we have not entered into a contract with you, we base the processing of your Personal Data on our legitimate interest to operate and administer our websites and to provide you with content you access and request (e.g., download of certain content from our websites);
  • Promoting security of our websites: We will process your Personal Data by tracking use of our websites, creating aggregated, non-personal data, verifying accounts and activity, investigating suspicious activity, as well as violations of and enforcement of our terms and policies, to the extent this is necessary for the purpose of our legitimate interests in promoting the safety and security of the systems and application used for our websites, and protecting our rights and the rights of others;
  • Managing user registrations: We will process your Personal Data by managing your user account for the purpose of performing the contract with you according to any applicable terms of service;
  • Handling contact and user support requests: If you fill out a “Contact Me” web form, request user support, or if you contact us by other means, we will process your Personal Data for the performance of our contract with you and to the extent it is necessary for the purpose of our legitimate interests to fulfil your request and communicate with you;
  • Managing event registrations and attendance: We will process your Personal Data to plan and host the event or webinar, including related communication with you, on basis of the performance of our contract with you;
  • Managing payments: If you have provided financial information, we will process your respective Personal Data to check the financial qualifications and collect payments to the extent this is necessary for completing transaction with you under the contract entered into with you;
  • Developing and improving our websites: We will process your Personal Data to analyse trends, track your usage of our websites and interactions with emails to the extent this is necessary for our legitimate interests to develop and improve our websites and to provide our users with more relevant and interesting content;
  • Managing office visitors: We will process your Personal Data for security reasons, to register who visited our offices and who signed the non-disclosure agreement that visitors may be required to sign.
  • Displaying personalised advertisements and content: We will process your Personal Data to conduct marketing research, advertise to you, provide personalised information about us on and off our websites, and other personalised content based upon your activities and interests to the extent it is necessary for our legitimate interests to advertise our websites or, where necessary, to the extent you have provided your prior separate consent (please also view “Your rights relating to your Personal Data” below to learn how you can control how your Personal Data is processed by Sixley for marketing purposes);
  • Sending marketing communications: We will process your Personal Data to send you marketing information, product recommendations and other non-transactional communications (e.g., marketing newsletters, SMS, or push notifications) about us and our affiliates and partners, including information about our products, promotions or events as necessary for our legitimate interests to conduct direct marketing or to the extent you have provided your prior separate consent (please also view “Your rights relating to your Personal Data” section below to learn how you can control how your Personal Data is processed by Sixley for marketing purposes);
  • Complying with legal obligations: We will process your Personal Data when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Data to protect our rights, and is necessary for our legitimate interests to protect against misuse or abuse of our websites, to protect personal property or safety, to pursue remedies available to us and limit our damages, to comply with a judicial proceedings, court order or legal process, and/or to respond to lawful requests.

Where we need to collect and process Personal Data by law, or under a contract we have entered into with you and you fail to provide that required Personal Data when requested, we may not be able to perform the contract.

7. International transfer of information collected

Your Personal Data may be collected, transferred to and stored by us in other countries where we operate.

Therefore, your Personal Data may be processed outside the EEA, and in countries which are not subject to an adequacy decision by the European Commission and which may not provide for the same level of data protection in the EEA. In this event, we will ensure that such recipient offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of data as approved by the European Commission (Art. 46 GDPR), or we will ask you for your prior consent to such international data transfers.

8. Children’s Privacy

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

9. How long do we keep your Personal Data?

We may retain your Personal Data for a period of time consistent with the original purpose of collection (see “Purposes for which we process Personal Data and on what legal basis” section above). We determine the appropriate retention period for Personal Data on the basis of the amount, nature, and sensitivity of your Personal Data, the potential risk of harm from unauthorised use or disclosure, and whether we can achieve the purposes of the processing through other means, as well as the applicable legal requirements (such as applicable statutes of limitation).

After expiry of the retention periods, your Personal Data will be deleted. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of the data.

10. Your rights relating to your Personal Data

10.1 Your rights

You have certain rights regarding your Personal Data, subject to local data protection laws. These may include the following rights:

  • to access your Personal Data held by us (right to access)
  • to rectify inaccurate Personal Data and ensure it is complete (right to rectification)
  • to erase / delete your Personal Data to the extent permitted by other legal obligations (right to erasure; right to be forgotten)
  • to restrict our processing of your Personal Data (right to restriction of processing)
  • to transfer your Personal Data to another controller to the extent possible (right to data portability)
  • to object to any processing of your Personal Data carried out on the basis of our legitimate interests (right to object). Where we process your Personal Data for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection
  • not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects (“Automated Decision-Making”)
  • to the extent we base the collection, processing and sharing of your Personal Data on your consent, to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal
10.2 How to exercise your rights

To exercise your rights, please contact us in accordance with the “Contacting Us” section below. We try to respond to all legitimate requests within one month and will contact you if we need additional information from you in order to honour your request. If you are an employee of a Sixley customer, we recommend you contact your company’s system administrator for assistance in correcting or updating your information.

In addition, if you have registered for an account with us, you may generally update your user settings, profile, organization’s settings or event registration by logging into the applicable website with your username and password and editing your settings or profile. To update your billing information, discontinue your account, and/or request return or deletion of your Personal Data and other information associated with your account, please contact us.

10.3 Your preferences for marketing communications

If we process your Personal Data for the purpose of sending you marketing communications, you may manage your receipt of marketing and non-transactional communications from us by clicking on the “unsubscribe” link located on the bottom of our marketing emails, by replying or texting ‘STOP’ if you receive SMS communications, or by turning off push notifications on our apps on your device. Additionally, you may unsubscribe by contacting us using the information in the “Contacting Us” section below. Please note that opting-out of marketing communications does not opt you out of receiving important business communications related to your current relationship with us, such as information about your subscriptions or event registrations, service announcements or security information.

11. Security

We take precautions including organisational, technical, and physical measures, to help safeguard against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, the Personal Data we process or use.

While we follow generally accepted standards to protect Personal Data, no method of storage or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices, and signing out of websites after your sessions. If you have any questions about the security of our websites, please contact us via the “Contacting Us” section below.

12. Changes to this Privacy Policy

We will update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements and other factors. If we do, we will update the “effective date” at the top of this Privacy Policy. If we make an update, we may provide you with notice prior to the update taking effect, such as by posting a conspicuous notice on our website or by contacting you using the email address you provided.

We encourage you to periodically review this Privacy Policy to stay informed about our collection, processing and sharing of your Personal Data.

13. Contacting us

To exercise your rights regarding your Personal Data, or if you have questions regarding this Privacy Policy or our privacy practices please contact us at:

Data Protection Officer
Sixley Ltd
WeWork, 3 Waterhouse Square
138 Holborn
London EC1N 2SW
Email: privacy@sixley.com

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, and you are located in the EEA, you have the right to lodge a complaint with the competent supervisory authority.

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