Privacy Policy

This Privacy Policy describes how we – CastHR Limited aka Vacation Tracker (together with its affiliates companies – “CastHR”, “Vacation Tracker”, “we”, “our” or “us”) collect, store, use and disclose personal data regarding individuals (“you”) who: (i) visit or otherwise interact with our websites (“Visitors”), available at www.casthr.co or any other website, webpage, e-mail, text message or online ad under our control (collectively – “Sites”); (ii) use our cloud-based human resources management platform, via the Sites or mobile applications and any additional extensions whether as an end user (“users”) or as an administrator (“Admin”) on behalf of our business customers (“customers”; and together with the Sites – the “Service”).

Your privacy is important to us, and we are strongly committed to making our practices regarding your personal data transparent and fair.

Please read this Privacy Policy carefully and make sure that you fully understand and agree to it.

You are not legally required to provide us with any Personal Data (defined below), and may do so (or avoid doing so) at your own free will.

If you do not wish to provide us with such Personal Data, or to have it processed by us or any of our Service Providers (defined below), please simply do not enter our Sites or use our Service. You may also choose not to provide us with “optional” Personal Data, but please keep in mind that without it we may not be able to provide you with the full range of our services or with the best user experience when using our Service.

This Privacy Policy pertains to CastHR’s practices as a “data controller”, where we determine the means and purposes for processing personal data. Where we process data on our Customers’ behalf, we act as their “data processor”, pursuant to our agreement with them (as further explained in Section 9 below). If you are a User of the Service on behalf of any of our Customers, we suggest that you contact your Admin with any questions or requests which pertain to your personal data processed by us on behalf of such customer.

This Privacy Policy forms part of our Terms and Conditions and our Customer Subscription Terms (collectively, the “Terms”). Any capitalized but undefined term in this Privacy Policy shall have the meaning given to it in the Terms applicable to your use.

1. Data Collection

We collect various types of personal data regarding our Users as well as data regarding Visitors to our Sites. Such data is typically collected and generated through your interaction with us or our Service, through automatic means, or directly from you, from other Users, from our customers, or from other third parties (including Service Providers, as hereinafter defined).

Specifically, we collect the following categories of data (which, to the extent it relates to an identified or identifiable individual, is deemed as “Personal Data”):

User Data received from you

When you contact us or sign up to the Service and create your individual profile (“User Profile”), you may provide us with Personal Data. This includes your name, workplace, gender and position, contact details (such as e-mail, phone and address), account login details (e-mail address and passwords which are automatically hashed), image, as well as any other data you choose to provide when you use our Service, contact us, or interact with others via our Service. If you choose to sign up or login using your Google or Microsoft account, we will receive these and other details you might have listed there.

Once you are logged in to our Service, you (or your organization’s Admin) may submit various additional details and documentation concerning yourself or your relatives – depending on the requirements and settings by your Admin. This could include your employee ID, government-issued ID or national security number, information and documentation concerning your employment, compensation and benefits details, family status and details on your dependents and emergency contacts, bank account details, investment preferences and plans, and other information you or your organization choose to submit (collectively, “User Data”).

Data automatically collected or generated

When you visit, interact with, or use our Service, we may collect, record or generate certain technical data about you. We do so either independently or with the help of third party Service Providers (as defined in Section 4 below), including through the use of “cookies” and other tracking technologies (as detailed in Section 5 below).

Such data consists of connectivity, technical and aggregated usage data, such as IP addresses and general locations, device and application data (like type, operating system, mobile device id, browser version, locale and language settings used), date and time stamps of usage, the cookies and pixels installed or utilized on such device and the recorded activity (sessions, clicks and other interactions) of Visitors and Users in connection with our Service.

User Data received from our customers and Users

Our customers and Users may provide us with the contact details of their employees, team members and colleagues, in order for us to contact, invite or subscribe them as Users to our Service. Such data typically includes these individuals’ names, phone numbers and work e-mails.

Data received from other third parties

We may receive Personal Data concerning you from other sources. For example, if you participate in an event, webinar or promotion that we sponsor or participate in, we may receive your Personal Data from its organizers. We may also receive your contact and professional details from our business partners or service providers, and through the use of tools and channels commonly used for connecting between companies and individuals.

In any event, such data will only be processed by CastHR on behalf of your organization – our customer, in accordance with our Data Processing Agreement executed by us with a customer (to the extent applicable), any other agreements between us and such organization, and this Privacy Policy.

Data concerning service integrations

If, when using the Service, you or your Admin choose to integrate your organization’s Service account with a third-party service (and such service is supported by our Service as detailed in our Site), we will connect and integrate that third-party service to ours. The third-party provider of this integration may receive certain relevant data about or from your organization’s account (including User Data), or share certain relevant data from your account on their service with our Service. Note that we do not receive or store your passwords for any of these third-party services. If you do not wish your data to be shared with such third-party service(s), please contact your Admin.

Data obtained through Analytics Tools

We use analytics tools (e.g. Google Analytics) to collect data about the use of our Sites and Service. Analytics tools collect data such as how often Users and Visitors visit or use the Sites or Service, which pages they visit and when, and which website, ad or e-mail message brought them there.

2. Data Uses

We use Personal Data as necessary for the performance of our Service; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining and improving our Service.

If you reside or are using the Service in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for processing Personal Data, your acceptance of our Terms and of this Privacy Policy will be deemed as your consent to the processing of your Personal Data for all purposes detailed in this Privacy Policy. If you wish to revoke such consent, please contact us by email at [email protected].

Specifically, we use Personal Data for the following purposes:

To facilitate, operate, and provide our Service
To verify and carry out financial transactions in relation to payments customers make in connection with the Service
To authenticate the identity of our Users, and to allow them access to our Service
To provide our Visitors, Users and customers with assistance and support
To gain a better understanding on how Visitors and Users evaluate, use and interact with our Service
To facilitate and optimize our marketing campaigns, ad management and sales operations
To contact our Visitors, Users and customers with general or personalized service-related messages, as well as promotional messages
To facilitate, sponsor and offer certain events, contests and promotions
To publish your feedback, user story and submissions in our public forums and blogs
To support and enhance our data security measures
To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data
To comply with applicable laws and regulations

We do not sell your personal information for the intents and purposes of the California Consumer Privacy Act (CCPA).

3. Data Location and Retention

Data Location

Your Personal Data is maintained, processed and stored by us and our authorized Service Providers (defined below) in US, Europe, UK. We may also retain your Personal Data in other locations as reasonably necessary for the proper performance and delivery of our Service, or as may be required by law.

While privacy laws may vary between jurisdictions, CastHR and its affiliates and Service Providers are each committed to protect Personal Data in accordance with this Privacy Policy and customary industry standards. For data transfers from the EU to countries which are not considered to be offering an adequate level of data protection, we and the relevant data exporters and importers have entered into Standard Contractual Clauses as approved by the European Commission.

Data Retention

We will retain your Personal Data for as long as it is reasonably necessary in order to maintain and expand our relationship and provide you with our Service and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes.

Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete, anonymize or restrict access to it for any reason and at any time, with or without notice to you.

If you have any questions about our data retention policy, please contact us by e-mail at [email protected].

Legal Compliance

In exceptional circumstances, we may disclose or allow government and law enforcement officials access to your Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations.

Service Providers

We may engage selected third-party companies and individuals to perform services complementary to our own (collectively, “Service Providers”). These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and enhancing our Service, and may only use it for such limited purposes as determined in our agreements with them.

Our Service Providers shall be deemed as ‘Data Processors’ in circumstances where CastHR assumes the role of ‘Data Controller’. A list of our current Subprocessors may be found here.

We may share your Personal Data with the customer owning the account to which you are subscribed as a User. Any Personal Data you submit to areas in the Service marked as “private” may still be accessed, copied and processed by your organization’s Admin(s).

If you submit a public review or feedback, note that we may (at our discretion) store and present your review to other users of our Sites and Service. If you wish to remove your public review, please contact us at [email protected].

Protecting Rights and Safety

We may share your Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of CastHR, any of our Users or customers, or any members of the general public.

CastHR Subsidiaries and Affiliated Companies

We may share Personal Data internally within our group, for the purposes described in this Privacy Policy. In addition, should CastHR or any of its subsidiaries or affiliates undergo any change in control or ownership, your Personal Data may be shared with the parties involved in such an event.

5. Cookies and Tracking Technologies

Our Sites and Service (including some of our Service Providers) utilize “cookies”, anonymous identifiers, pixels, container tags and other technologies in order for us to provide our Service and ensure that it performs properly, to analyze our performance and marketing activities, and to personalize your experience.

6. Communications

Service Communications

We may contact you with important information regarding our Service. You can control your communications and notifications settings from your User Profile settings. However, please note that you will not be able to opt-out of receiving certain service communications which are integral to your use.

Promotional Communications

We may also notify you about new features, additional offerings, events and special opportunities or any other information we think our Users will find valuable.

If you do not wish to receive such promotional communications, you may notify CastHR at any time by sending an e-mail to [email protected], changing your communications preferences in your User Profile settings, or by following the “unsubscribe” instructions contained in the promotional communications you receive.

7. Data Security

In order to protect your Personal Data held with us, we are using industry-standard physical, procedural and technical security measures, including encryption as appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties. To learn more, please visit https://casthr.co/legal/security/.

8. Data Subject Rights

If you wish to exercise your rights under any applicable law, including the EU General Data Protection Regulation (GDPR) such as the right to request access to, and rectification or erasure of your Personal Data held with CastHR, or to restrict or object to such Personal Data’s processing, or to port such Personal Data – please contact us by e-mail at [email protected].

If you would like to make any requests or queries regarding Personal Data we process on your organization’s (our customer’s) behalf, please contact your organization’s Admin directly.

9. Data Controller/Processor

CastHR is the “Data Controller” of Personal Data relating to its Visitors’, Admins’ and other business contacts at our customers, as well as of User Data consisting of profile and contact details, and usage, preferences, engagement and analytics data.

If any of our Users upload or submit to the Service Personal Data which relates to other individuals, such data will only be processed by CastHR on behalf of our customer. In such instances, our customer shall be deemed the “Data Controller” of such data, and CastHR will process such data on the customer’s behalf, as its “Data Processor”.

If you would like to make any requests or queries regarding personal data we process as a Data Processor on our Customer’s behalf, please contact your Admin directly.

10. Additional Notices

Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Service. The amended version will be effective as of the date it is published. Your continued use of the Service after the changes have been implemented will constitute your acceptance of the changes.

External Links: While our Service may contain links to other websites or services, we are not responsible for their privacy practices. This Privacy Policy applies only to our Service.

Our Service is not designed to attract children under the age of 16: We do not knowingly collect Personal Data from children and do not wish to do so. If you believe that we might have any such data, please contact us by e-mail at [email protected].