PONTON MEDIA LIMITED places great importance on the protection and respect of personal data.
This privacy policy (the “Privacy Policy”) has been designed to help you understand how PONTON MEDIA LIMITED, as the publisher of the BestOnlineResume website, collects and processes your personal data, and what your rights are.
This Privacy Policy applies to:
Visitors to our website BestOnlineResume (the "Site"), and
Users of our online CV creation, cover letter and application preparation services (the “Services”).
In this Privacy Policy, the term “Personal Data” refers to any information that allows or can legitimately be used to identify a natural person.
PONTON MEDIA LIMITED, a company incorporated under English law, whose registered office is located at 9 Greyfriars Road, RG1 1NU, Reading, Berkshire, United Kingdom. Registered office address: Cambridge House, 16 High Street, Saffron Walden, Essex, CB10 1AX, United Kingdom. and registered with the Registrar of Companies for England and Wales under number 13437039 (hereinafter the “Company” or “we”), is responsible for the processing of your Personal Data collected via the Site and Services.
We process your Personal Data in compliance with applicable data protection regulations, including the UK General Data Protection Regulation ("UK GDPR"), the Data Protection Act 2018 ("DPA 2018"), and, where our processing activities fall within its territorial scope, Regulation (EU) 2016/679 of 27 April 2016 on the protection of personal data ("GDPR").
The data processing carried out by the Company pursues specific, explicit, and legitimate purposes. For each of these processing operations, the Company undertakes to process only Personal Data that is adequate, relevant, and limited to what is necessary for the purposes for which it is processed.
We only process your personal data when we have a legal basis for doing so:
| Purpose | Personal data | Legal basis | Source |
|---|---|---|---|
| 1. Provision of the site and services | |||
| Managing our contractual relationship with you (providing you with our Services, processing your payments, allowing you to personalize your Account, your personalized documents, your profile and your customer area) | • Identity, contact details • Photograph • Information contained in your CV and cover letters • Login credentials for your personal account on the Site • Payment information | Execution of our contract with you | Data provided by the data subject or collected automatically during their use of the services |
| Managing our site, including maintaining its security and resolving problems, and for the purposes of access, data analysis, evaluation, research, surveys and analysis | • Identity, contact details • Information contained in your CV and cover letters • Login credentials for your personal account on the website • Data about your equipment (type, operating system, settings) | The Company's legitimate interest in managing its Site | Data provided by the data subject or collected automatically during their use of the site and/or services |
| Improve our site so that content is presented in the most effective way possible | •Identity, contact details •Photograph •Information contained in your CV and cover letters •Login credentials for your personal account on the Site •Data about your equipment (type, operating system, settings) | The Company's legitimate interest in managing its Site | Data provided by the data subject or collected automatically during their use of the site and/or services |
| 2. Communication and prospecting | |||
| Handling contact requests (contact form on the Website, telephone and email) | Identity and contact details Purpose of your request Any information or document you share with us. | Consent | Data provided by the person concerned |
| Sending marketing communications to our clients | Identity and contact details User journey data | The Company's legitimate interest in developing its business | Data provided by the data subject or collected automatically during their use of the services |
| 3. Respect for the rights of the persons concerned and for regulations | |||
| Defending our interests in case of litigation | •Identity and contact details •Any information necessary for processing the dispute | The company has a legitimate interest in defending its interests in the event of a dispute. | Data provided by the data subject, data collected automatically during their use of the Site and/or services, and data collected from third parties |
| Management of requests to exercise rights | Identity and contact details Any information necessary to process your request to exercise your rights | Legal obligation | Data provided by the data subject or collected automatically during their use of the site and/or services |
| Comply with the legal or regulatory requirements that apply to us (accounting, taxation, data protection) | All information necessary to comply with legal or regulatory requirements | Legal obligation | Data provided by the data subject or collected automatically during their use of the site and/or services |
The data required to respond to your requests is marked with an asterisk or equivalent on the data collection forms or specified verbally at the time of collection. If these fields are not completed, we will be unable to respond to your requests or provide certain services.
You must provide us with accurate information that does not infringe upon the rights of third parties. If you provide us with Personal Data relating to another person, you agree to share the link to this Privacy Policy with that person. This way, the person concerned will be informed about the processing of their Personal Data by the Company.
We share the different categories of personal data mentioned above with:
our authorized staff, who need access to it as part of their duties;
our subcontractors and service providers who perform various services on our behalf (for example in the areas of payment processing, hosting, audience measurement, customer service management or data analysis), within the limits of what is necessary for the execution of their missions;
where applicable, some of our technical or commercial partners involved in the provision, improvement or promotion of the Services, when such sharing is necessary and contractually governed;
our external advisors (lawyers, auditors, etc.) and debt collection agencies, when necessary for the purposes of our legitimate interests;
public or judicial authorities, when required by law or when we believe in good faith that transparency is legitimate to respond to a claim against us, to comply with a legal proceeding, as part of an investigation or to protect the property or personal safety of the Company, its partners or its users.
We may also share your Personal Data with third parties in connection with a potential or actual sale or restructuring of our company or some of our assets, in which case your data may be among the transferred assets.
We may transfer your Personal Data to our third-party service providers located outside the United Kingdom and, where applicable, the European Economic Area, including in countries that do not benefit from an adequacy decision by the European Commission (Article 45 of the GDPR) or from adequacy regulations adopted in the United Kingdom. In this case, we ensure that these transfers are carried out in accordance with applicable regulations and are secured by appropriate mechanisms, such as:
the European Commission's standard contractual clauses (Articles 46 et seq. of the GDPR) and/or
The International Data Transfer Agreement ("IDTA") and/or the UK addendum to the standard contractual clauses approved by the Information Commissioner’s Office ("ICO"), as applicable.
You can request a copy of these mechanisms (excluding confidential clauses) by contacting us using the contact details provided in the "How to contact us?" section below.
We retain your Personal Data only for as long as necessary for the purposes described and in accordance with the law.
Here are the applicable shelf lives:
Data associated with your personal account (your “Account”): When you create an online account, your Personal Data is retained as long as you use our services through your account. Your data and your account will be deleted:
If you close your account,
If your account is inactive, that is, you have not used any of our services for a period of two consecutive years and you have ceased to interact with us during this second year (in particular, you have not opened our emails, you have not logged into your account, etc.).
Data relating to your subscription to our services: when you subscribe to our services, your Personal Data (billing address, type of subscription, payment methods etc.) is kept for 5 years from the end of the contractual relationship.
Data for prospecting: we send marketing communications until you unsubscribe or 3 years after your last interaction with our emails.
Furthermore, we may retain your Personal Data for a longer period, limited to what is strictly necessary for the purposes for which it is processed, to assert our rights, or to comply with a legal obligation. When your data is no longer needed, we will ensure that it is deleted or anonymized.
We take appropriate technical and organizational measures to prevent the unauthorized or unlawful processing of your Personal Data and to avoid any accidental loss, destruction, or damage to your Personal Data. These include internal security procedures relating to the storage and destruction of your Personal Data, as well as the management of access to this data.
You have several rights regarding your Personal Data. The table below presents the different rights you have over your Personal Data, the conditions for their implementation, and the exceptions to the exercise of each of these rights.
| Right | Conditions and exceptions |
|---|---|
| You can withdraw your consent at any time | This right can only be exercised when the processing is based on your consent. Withdrawal of consent has no retroactive effect on prior processing. |
| You can ask if we process your Personal Data, access it, and obtain a copy of it. | Access may be refused or limited if the request is manifestly unfounded or excessive, or if it infringes on the rights of a third party (e.g., trade secrets, third-party confidentiality, copyright). We may require proof of identity if we have reasonable doubt about the identity of the requester. |
| You can request the correction of inaccurate or incomplete data. | This right can be exercised regardless of the legal basis for the processing. |
| You can request the erasure of your data or the restriction of its processing | Cases where erasure can be exercised: • The data is no longer necessary for the purposes for which it was collected or processed. • You withdraw your consent when the processing was based solely on this legal basis. • You object to the processing based on our legitimate interest and there are no overriding grounds justifying the continued processing. • Your data has been unlawfully processed. • Your data must be erased to comply with a legal obligation to which we are subject. The right to erasure does not apply, in particular, when processing is necessary: • for compliance with a legal obligation (e.g., accounting records, tax obligations, anti-money laundering); • for the establishment, exercise, or defense of legal claims; • freedom of expression and information |
| You can request the portability of your data in a structured, commonly used and machine-readable format or its transfer to another data controller. | This right applies only to data processed automatically and based on your consent or the performance of a contract concluded with you. It concerns only the data you have provided to us directly (excluding derived or inferred data). Direct transfer to another data controller will only be possible if technically feasible. |
| You can object to any processing based on our "legitimate interest" | This right does not apply if we can demonstrate compelling legitimate grounds justifying the continued processing (e.g., necessity of processing for security purposes, fraud prevention). If the processing is based on a legal or contractual obligation, objection is not possible. For direct marketing, the right to object applies without justification and must be taken into account immediately. |
| You can set guidelines regarding the fate of your data after your death. | You can designate a person to carry out these instructions or request the deletion of your data after your death. In the absence of specific instructions, heirs may exercise certain rights (access, rectification, erasure) to the extent necessary for the organization of the estate. |
To exercise your rights, contact us using the information provided in the "How to contact us" section. You can also lodge a complaint with your local data protection authority. In the UK, this is the Information Commissioner's Office ("ICO"). If you live in another country, you can also contact your national data protection authority.
For more information, you can contact us using the contact details provided in the "How to contact us?" section.
A "cookie" is a small file stored by your browser when you visit a website.
Cookies are placed on our Site. To learn more about the conditions under which these cookies are placed and used, please consult our Cookie Policy.
We invite you to submit all your requests, questions or comments relating to this Privacy Policy or the processing of your Personal Data:
– via the "Contact Us" section available on the website, and/or
– using the Company's contact details indicated in the Site's Terms of Use and Terms and Conditions of Sale.
We reserve the right to modify or update this Privacy Policy at any time in accordance with changes in legal requirements or our data processing practices. We will notify you in the event of any substantial changes.