Website Privacy Policy

Last updated: 06/02/2024

Statement

VariaCode Software, S.p.A. (“VARIACODE”) and its subsidiary VariaCode INC. (USA) respects your privacy and is committed to protecting it in accordance with applicable laws and using generally-accepted industry practices. This Privacy Policy explains who we are, how we collect, share, and use personal information about you, and how you can exercise your privacy rights. For purposes of this Privacy Policy, “Personal Information” means any information that is available to VARIACODE and that is protected explicitly by the European Union General Data Protection Regulation of 2016 (the “EU GDPR”); the EU GDPR as saved into United Kingdom law by virtue of section 3 of the United Kingdom's European Union (Withdrawal) Act 2018 (the “UK GDPR”); and the California Consumer Protection Act (“CCPA”), to the extent applicable.

If you have any questions or concerns about VARIACODE's collection and use of your Personal Information, please contact us using the contact details provided. If, however, your questions or concerns are related to a VARIACODE customer's collection and use of your Personal Information, please contact that customer directly.

Consent

You agree to the terms and conditions contained in this Privacy Policy, and you expressly consent to the processing of your data in accordance with this Privacy Policy. If you do not agree to any of these terms and conditions, or approve of VARIACODE's data practices as explained herein, then you should immediately cease all use of our Services. To the fullest extent permitted by applicable law, you agree that any dispute over privacy or the terms contained in this Privacy Policy and Terms of Use, or any other agreement we have with you, will be governed by the laws of Chile.

(This does not apply if you are based in the European Economic Area (“EEA”).)

Scope of this Policy

Our websites, products, and services are designed for businesses and their representatives. We do not offer products or services for use by individuals for their personal, family, or household purposes. Accordingly, we treat all Personal Information we collect as pertaining to individuals in their capacities as business representatives and not as individual consumers.

Our customers are the controllers of the Personal Information they collect through VARIACODE's Services to manage their own recruiting and onboarding processes (e.g., names, contact information, and other data collected as part of job applications), and each customer manages that Personal Information in accordance with its own privacy policies.

VARIACODE's privacy commitments to our customers are governed by a separate customer agreement that authorizes us to collect, process, and store Personal Information on their behalf as a processor under the EU GDPR and the UK GDPR and a service provider under the CCPA.

VARIACODE processes Personal Information relating to our customers' employees and job applicants within our Services only according to our customers' instructions (as defined in our customer agreements), and we have no direct relationship with the individuals whose Personal Information we process in connection with our customers' use of our Services. For example, if you apply to a job posted on a career page of a VARIACODE customer, your Personal Information will be automatically processed by VARIACODE on behalf of that customer.

However, the company you applied to is the data controller (or business, as that term is defined in the CCPA) with respect to your Personal Information, and you should contact that entity directly with any questions you may have regarding its privacy policies or data processing practices, or if you wish to modify or access your Personal Information, restrict its processing, or delete it from our Services.

VARIACODE is the controller of Personal Information that we collect directly from visitors to our marketing website, www.variacode.com (the “Website”); from our own job applicants; and from our customers and vendors to help us manage our business relationships with them. This Privacy Policy describes the type of Personal Information that VARIACODE collects; VARIACODE's policies around the use, disclosure, and retention of that Personal Information; and the choices available to you regarding your rights in relation to your Personal Information generally.

What Data We Collect

VARIACODE may collect the following information, including Personal Information from and about you:

How We Use the Data

VARIACODE may use the information that we collect about you and from you, including Personal Information, for the following purposes:

Information Sharing and Disclosure

To the extent permitted by applicable law, VARIACODE may disclose your Personal Information in the following circumstances:

We may also disclose your Personal Information with your prior informed consent. Service providers acting on our behalf are obliged to adhere to confidentiality requirements no less protective than those set forth herein and will only receive access to your Personal Information as necessary to perform their functions.

We may transfer Personal Information (including personal data about residents of the EEA) to our vendors, consultants, and other service providers who need access to such Personal Information to carry out work on our behalf.

VARIACODE will be liable for the processing of such Personal Information by a third-party service provider unless we can prove that we are not responsible for the event giving rise to the damages. We may also be required to disclose such Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Your Choices

How We Protect Your Data

We are committed to protecting the security of information received via the Online Services, including Personal Information. We provide reasonable and appropriate administrative, technical, and physical security controls to protect your Personal Information from unauthorized access, use, or disclosure. For example, we use secure socket layer technology (SSL) in connection with our Online Services. Despite our efforts, no security controls are 100% risk-free, and VARIACODE does not warrant or guarantee that your Personal Information will be secure in all circumstances.

You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Privacy Policy.

Contact

VARIACODE welcomes your comments, questions, and concerns regarding our Privacy Policy.

Please contact us at security@variacode.com or our mailing address below:

VariaCode Software, S.p.A.
Huerfanos 1160, Of 1102.
Santiago, Chile