Hiroo Privacy Policy

This privacy policy explains how Hiroo collects, uses, shares, and protects personal data in the course of operating its business. 

Introduction

Hiroo (“Hiroo”, “we”, “us”, “our”) respects your privacy and is committed to protecting it by applicable laws and using generally-accepted industry practices.

This Privacy Policy explains who we are, how we collect, share, and use your personal information, and how you can exercise your privacy rights. If you have any questions or concerns about Hiroo’s collection and use of your Personal Information, please contact us using the contact details provided below. If however, your questions or concerns are related to a Hiroo customer’s collection and use of your Personal Information, please contact that customer directly.

1. Personal data of website visitors

   This paragraph describes the processing of personal data by Hiroo when you visit the Hiroo Website. The personal data of Visitors is collected and used for the following purposes: 

   Hiroo and its partners place cookies for all the purposes listed in this paragraph, additional information about Hiroo’s cookies may be available in the cookie consent banners of the Hiroo Website.

   Hiroo relies on legitimate interests as its legal basis for processing personal data for purposes listed in this paragraph. Such legitimate interests are the same as the purposes that Hiroo processes personal data for. For example, the legitimate interest for processing personal data for the purpose of “the functioning of the Hiroo Website” is also “the functioning of the Hiroo Website”. The personal data listed in this paragraph will be deleted when it is no longer necessary for the purposes it was collected for. 

2. Use of personal data of Users for Hiroo’s business operations

   Hiroo processes the personal data of Users for the following business operations purposes

   Hiroo relies on legitimate interests as its legal basis for processing personal data for purposes listed in this paragraph. Such legitimate interests are the same as the purposes that Hiroo processes personal data for. Hiroo will delete personal data relating to Users after the services associated with the personal data are cancelled and the personal data is no longer necessary for any of the purposes listed in this paragraph. 

3. The providing of Hiroo Application to Users

   Hiroo processes the personal data of Users for the following purposes: 

   Hiroo relies on legitimate interests as its legal basis for processing personal data for purposes listed in this paragraph. Such legitimate interests are the same as the purposes that Hiroo processes personal data for. 

   The Customer and/or User primarily decides the retention period for all personal data that s/he can control the retention of through the Hiroo or that s/he can provide instructions for under the agreements between Customer and Hiroo. 

   Hiroo will delete personal data that is listed in this paragraph after the services associated with the personal data are cancelled and the personal data is no longer necessary for any of the purposes listed in this paragraph. 

   Hiroo's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. Information from Google APIs includes information from any Gmail account or Google Calendar account that a User connects to the Hiroo. Hiroo will not use information from a User’s Gmail account or Google Calendar account for any other purpose than providing the Hiroo.

4. Newsletters, webinars/events and demos

   Hiroo processes the personal data of Users for the following purposes: 

   Hiroo relies on legitimate interests as its legal basis for processing personal data for purposes listed in this paragraph. Such legitimate interests are the same as the purposes that Hiroo processes personal data for. 

   The Customer and/or User primarily decides the retention period for all personal data that s/he can control the retention of through the Hiroo or that s/he can provide instructions for under the agreements between Customer and Hiroo. 

   Hiroo will delete personal data that is listed in this paragraph after the services associated with the personal data are cancelled and the personal data is no longer necessary for any of the purposes listed in this paragraph. 

   Hiroo's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. Information from Google APIs includes information from any Gmail account or Google Calendar account that a User connects to the Hiroo. Hiroo will not use information from a User’s Gmail account or Google Calendar account for any other purpose than providing the Hiroo.

5. Other

   Hiroo may also process personal data to investigate or address claims or disputes relating to use of its services, to satisfy requirements under applicable laws, regulations, or agreements, or pursuant to legal process or governmental request, including from law enforcement. Hiroo relies on compliance with a legal obligations as a legal basis where the processing is necessary for compliance with applicable legal requirements. Otherwise, Hiroo relies on its legitimate interests as a legal basis to perform the above activities on the grounds that they are necessary for purposes of Hiroo’s legitimate interests in investigating and responding to claims and disputes relating to use of Hiroo’s services.

   Further, Hiroo may obtain your personal data in ways that are not described in this privacy policy. In those cases you will be informed about the details of such processing through other means than this privacy policy. Please note that if Hiroo is processing your personal data then you may always reach out to Hiroo to request to exercise your rights, such as asking how we process your personal data.

6. Social media and distributed content

   Hiroo may use the services of its partners to stay in touch with you or to provide you with content. For example, we may provide you with articles through our Linkedin page. Services of Hiroo’s partners may also be used for Hiroo and its partners to process personal data or place cookies on your device for the following purposes:

   Hiroo may also process public social media posts to stay up-to-date on and respond to social media activity in relation to its business.

   Where appropriate, Hiroo will ask your consent for the processing. In other cases Hiroo relies on legitimate interests for the processing of the personal data for the purposes described above. Such legitimate interests are the same as the purposes that Hiroo processes personal data for. 

7. Advertising

   The following companies process your personal data that was collected for the purposes of marketing and sales to help Hiroo serve you Hiroo’s advertisements on third party websites and applications: Meta, G2, Google, LinkedIn, Microsoft (Bing), X, Quora, Oath (Yahoo), Reddit and Outbrain. Unique identifiers (with the help of cookies), contact information and browsing history are processed for those purposes. Opt-outs for processing of your personal data for this purpose are available on the following pages:

   http://optout.aboutads.info/ (Meta, Google, LinkedIn, Microsoft, X, Oath and Outbrain)

   https://www.g2.com/static/cookie_policy (G2)

   https://www.quora.com/optout (Quora)

   https://www.reddit.com/personalization/ (Reddit)

8. E-mails & other communications

   Hiroo may send you e-mails with information about Hiroo Services, or other information that may interest you. E-mails will only be sent based on your prior consent, unless you register for Hiroo. You can contact us by e-mail to opt-out of our e-mails or use the unsubscribe links provided in the e-mail communications that we send you.

   Communications between you and Hiroo such as chats, e-mails, phone conversations and private messages may be stored to improve our communications and for future reference. More information about retention periods is available on request.

9. Applicants to Hiroo jobs (careers.hiroo.co)

   This section applies to applicants of jobs at Hiroo as shown on our Careers Site (careers.hiroo.co) and any other candidates or potential candidates for any jobs with Hiroo. Our customers have separate privacy policies for their recruitment activities and such recruitment activities are not covered by this privacy policy.

   Hiroo may collect your personal data for recruitment purposes in one of the following three ways:

   1. You apply for a job at Hiroo: If you apply for a job at Hiroo then we process your personal data to facilitate the entire job application procedure on the grounds of our legitimate interests for recruitment. 

   2. We source you through publicly available resources: Hiroo may, based on its legitimate interests for recruitment, search through publicly available resources such as LinkedIn to find candidates that have skills, experience and interests that match with Hiroo’s staffing needs. If Hiroo believes that you may be a match with Hiroo’s staffing needs, then Hiroo will, based on its legitimate interests for recruitment, process your personal data to reach out to you and ask for your consent to match you with job opportunities at Hiroo and to otherwise process your personal data in relation to recruitment for job openings at Hiroo. 

   3. You are referred by someone: Someone who knows you might refer you to us because that person believes you have skills, experience and interests that match with Hiroo’s staffing needs. Upon receiving your contact details and determining that you are a good match we will, based on our legitimate interests for recruitment, reach out to you to ask for your consent to match you with job opportunities at Hiroo and to otherwise process your personal data in relation to recruitment for job openings at Hiroo. 

   The following personal data can be processed for a job application procedure or other recruitment activities:

   • Any personal data that you provide through our job application form or that we collect during the recruitment process including, but not limited to:

   • Contact details such as full name, email address, phone number

   • Photo, cover letter, resume and LinkedIn profile

   • Which job you are in a hiring process for

   • Statuses, notes, evaluations and planning related to a hiring process that relates to you

   • Email and SMS communications

   Under European data protection law we are required to inform you that withholding personal data in your job application can give you a disadvantage in comparison to other candidates who are applying for the same role. Hiroo may share your personal data with individual Hiroo entities once a hiring decision has been made for the purpose of making a hire through that entity.

10. Other recipients of personal data

    We may share personal data:

    1. With relevant third parties as part of a corporate transaction, such as a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with a bankruptcy or similar proceeding);

    2. With one of our business partners, on your request to learn more about the products and/or services of that business partner;

    3. With financial, tax, legal and strategic consultants for the purpose of receiving legal, accounting and compliance advice for Hiroo and for the purpose of receiving advice on the commercial and product strategy of Hiroo, and;

    4. For legal reasons or in the event of a dispute with relevant third parties, e.g. financial, tax, legal and strategic consultants for the purpose of receiving advice and/or law enforcement officials and other government authorities where required.

11. Cookie permissions

    Upon visiting our website for the first time you are presented with our cookie consent tools. The cookie consent tools offer visitors a choice to either accept or reject cookies that require your consent under data protection law. Hiroo will always respect your choices. It’s also possible to either disable or delete our cookies in your internet browser.

12. Hiroo’s responsibility versus the responsibility of Customers

    In many cases Hiroo processes personal data as a service for Customers of the SaaS Products. In those cases the Customer carries the responsibility for the personal data that is being processed. In the words of the European Union’s GDPR and Turkey’s KVKK Customer is the controller and the Hiroo is the processor. This privacy policy (only) describes the processing of personal data insofar as Hiroo is the controller. The details of the processing of personal data by our Customers can be found in the privacy policies of our Customers. We encourage you to review the privacy policies of our Customers before submitting any personal data to them.

    The other paragraphs of this privacy policy provide detailed information about the processing that Hiroo is responsible for, but for a more simplified overview of who the controller is please refer to the following matrix: 

13. Transfers outside of the European Union

    A processing of personal data under the responsibility of Hiroo may involve a transfer of personal data outside of the European Union (such as to the United States of America and the United Kingdom). In such cases Hiroo always remains the responsible party for the processing (controller). In the absence of adequacy decisions (such as the Data Privacy Framework and the UK adequacy decision), Hiroo uses standard contractual clauses for use between controller and controller (module one) and between controller and processor (module two) as grounds for legitimizing such a transfer. Please note that Hiroo will never transfer personal data that it processes on behalf of its Customers, as a processor, outside of the European Union, unless the Customer instructs Hiroo to do so. Please contact us for more information about data transfers to countries outside of the European Union. 

14. Your rights, requests or questions

    Feel free to contact us if you have any questions regarding your personal data. You can also contact us with requests to exercise your rights under European data protection law. Such rights include the rights to access, rectification, erasure, restriction of processing, data portability and objection to processing.

    Wherever we rely on your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

    There are instances where we have a legitimate interest to use your data. Our legitimate interest will vary depending on what we are using your data for, and we explain above what the interest is and how it relates to the processing operations that we are carrying out. Where we process personal data on the basis of a legitimate interest, then – as required by data protection law – we have carried out a balancing test to document our interests, to consider what the impact of the processing will be on individuals and to determine whether individuals interests outweigh our interests in the processing taking place. You can obtain more information about this balancing test by contacting [email protected]. 

    If you would like to exercise your rights or otherwise have any requests or questions with regard to your personal data you can contact us at: [email protected]. 

15. Updates to this policy

    From time to time, Hiroo will revise this policy. Hiroo recommends that you regularly check whether this policy has been revised. However, where possible, Hiroo will notify Users via notifications in the in-app live chat or by e-mail about any substantive or material changes. 

16. Hiroo’s identity and address

    The contact details of Hiroo are as follows.
    Postal mail: Acıbadem Mah. Cecen Sk. Akasya A Kule 25A/150 Üsküdar, Istanbul Turkey
    E-mail: [email protected]

17. Definitions

    The following definitions have the following meanings in this privacy policy:‘Browser and Internet Metadata’: The metadata of requests and responses sent to Hiroo by your device and by Hiroo to your device: time, headers, approximate location, device, browser, unique identifiers such IP-address and referrer;‘Candidates’: Any candidate, potential candidate, applicant or potential applicant for a job position of our Customers or visitor of a Careers Site of a Customer of Hiroo;‘Careers Site’: A website that is used by an organization for talent acquisition purposes such as publishing vacant job positions and publishing job application forms;‘Customers’: Hiroo’s paying and non-paying customers for its SaaS Products;‘Referrers’: Anyone who visits a referral site of a Hiroo Customer or makes a referral for a Candidate through the SaaS Products;‘SaaS’: Software as a Service;‘Hiroo Services’: Any services provided by Hiroo;‘Hiroo Websites’:, hiroo.co, careers.hiroo.co‘Usage Patterns’: Logs and statistics of which pages, functionalities, buttons, links and forms you have used at which time;‘Users’: Everyone with personalized access rights for Hiroo, except Referrers and Candidates;‘Visitors’: Anyone that visits the Hiroo Websites