Privacy policy

This Privacy Policy sets out the approach taken by Headhunter Systems Limited (“Headhunter Systems”, “we”, or “us”) to the personal information of subscribers and visitors to its website and any other website powered by “Graduway” (“the Sites”). By browsing Alumni UIB and the services within them (collectively the "Services”), you (“You”) agree that Your personal information and data (collectively, "Personal Information") will be dealt with in accordance with this privacy policy.

Privacy and confidentiality are at the heart of the Services. We treat Personal Information acquired from You seriously and make every effort to comply with our obligations under applicable privacy statutes including the Freedom of Information and Protection of Privacy Act and the UK Data Protection Act 2018 and / or the General Data Protection Regulation (GDPR) (EU) 2016/679. Additionally, we understand the importance of maintaining the confidentiality of any information stored about You while using the Services. We respect Your privacy – Graduway’s entire service depends on treating Personal Information properly, in the strictest confidence and with sensitivity.

The Information you provide by using the Services is owned by You, and You may ask us to remove any information that Graduway stores about You, at any time, unless you have shared information or content with others and they have not deleted it, or it was copied or stored by other users, by sending us an e-mail stating in the subject heading, “Remove Details”. Further information related to this section is available in our General Terms of Use and in Sub-Clause 3.7 below.

Other than as provided for in clause 1.2 below, the definitions and interpretations contained in our General Terms and Conditions shall apply to these Terms also.

Information Collection and Use

  1. We collect Personal Information when you register for an account, when you use certain Services and when you visit certain Site pages.
  2. When you register with us, as further described under clause 3 to our General Terms and Conditions, we will ask You for Personal Information, directly (for example, to enter your name, email address, birth date, gender, post code, occupation, industry, personal interests etc.) or indirectly (through the "Connect with" LinkedIn or Facebook option, located at our Website's homepage).
  3. By registering with us, You acknowledge and agree that we may access and store your Personal Information anywhere in the world. If you registered with us through the "Connect with" LinkedIn or Facebook option, You also acknowledge and agree that we may access and store information from your LinkedIn or Facebook profile, respectively. Further information related to this section is available under Clause 3 of our General Terms of Use.
  4. Once you register with us and sign in to our Services, you are not anonymous to us.
  5. The Personal Information You provide us will be displayed to other users of the platform, including your email address unless you choose to hide Your Personal Information from other users.
  6. Personal Information and other details about You that You supply as part of the registration process are stored securely by us and are used to provide You with the Services and information as set out in Alumni UIB. You have chosen to provide us with this information and we will not use that information for any purpose other than as set out as part of the Services.
  7. We will use information provided by you to help you advance your career through inside connections, leverage your professional network, get introduced to people, socially interact with other users and share photos with them, create and/or share and/or find business opportunities and stay in touch with UIB ("Membership organization"). You consent to the use of your profile and Personal Information being used for this purpose.
  8. We also automatically receive and record information on our server logs from your browser including your IP address, cookie information, software and hardware attributes, and the page you requested.
  9. We use information for the following general purposes to fulfil your requests for services, improve our services, contact you, conduct research, and provide reporting for internal and external clients. You agree that we may transfer your Personal Information for the general purposes set out above within Graduway to any group company and to the Membership organization.
  10. We do not rent, sell, or share Personal Information about you with other people or non-affiliated companies except to provide products or services you've requested, when we have your permission, or under the following circumstances:
    • responding to court orders, legal process, or to any legitimate request by authorities with which we must comply; and
    • to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our terms of use, or as otherwise required by law.
  11. In reference to general Site activity, you retain copyright and any other rights you already hold in all information and contents which you submit, post or display on or through the Alumni UIB Alumni Site. By using the Services you grant us a nonexclusive, transferable, sub-licensable, royalty-free, worldwide licence to use such information and contents that you post on the Site for the purposes set out in Paragraph 7 above, and for the purpose of enabling us to provide the Services through the Site. Such a licence does not include permission for us to commercialise (for our own purposes) the information and contents you have posted. This licence will end in relation to certain information and contents that you delete from the Alumni UIB Alumni Site when such certain information and contents are deleted, and will end in relation to all such information and contents on the Site when you delete your account from the Site, unless the relevant information or contents have been shared with others and they have not deleted such information or content.
  12. You also agree that we may transfer your information to the Membership organization to use for development and advancement purposes.


  1. Cookies are small pieces of information that are stored by Your browser on Your computers hard drive. Graduways cookies do not contain any personally identifying information, but enable us to identify Your computer when You access the Services and to provide You with a convenient means of access. The Services may from time to time contain links to and from the websites of Graduways partner networks, advertisers and affiliates. If You follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before You submit any Personal Information to these websites.

Edit and Delete Your Information and Preferences

  1. You can edit your Personal Information on Your account at any time.
  2. You can re-sync your account with your Linkedin Account at any time.
  3. We may restrict any change being made to any report produced about You, if we are of the opinion that such report is not a fair and true representation of You.
  4. You authorise for us to display and make available for download to authorised third parties all media recordings of You which You submit to us or post on Alumni UIB or through the Services.
  5. We will endeavor to correct any material error in your Personal Information that You make us aware of.
  6. We reserve the right to send you certain communications, such as service announcements and administrative messages and other communications relating to our Service, without offering you the opportunity to opt out of receiving them.
  7. You may delete your account by emailing us at, verifying your password once more and confirming your choice to terminate the account.

Confidentiality and Security

  1. We have physical, electronic, and procedural safeguards that comply with our legal obligations to protect Personal Information about you.

Posting on Publicly Accessible Areas

  1. A publicly accessible area is any area of Alumni UIB and/or Services that is accessible by the general public and may be indexed by search engines.
  2. We may offer you the opportunity to post, submit and exchange content and information on publicly accessible areas and You should exercise caution if you choose to disclose Personal Information in a publicly accessible area. Remember that this information may remain indefinitely in the publicly accessible area of Alumni UIB and Services.
  3. You are solely responsible for any Personal Information that you disclose and disseminate on Alumni UIB and through the Services.
  4. We shall not be held liable for any loss of information. Any information you submit to us is at your own risk of loss.

User-to-User Communication and Sharing

  1. You are solely responsible for your interactions with other users.
  2. We reserve the right, but have no obligation, to monitor disputes between you and other users and to restrict, suspend, or close your account if we determine, to our sole discretion, that doing so is necessary to enforce these Terms.
  3. We cannot guarantee that other users will not use the ideas and information that you share to and/or through our Services. Therefore, if you have an idea or information that you would like to keep confidential or don’t want others to use, or that is subject to third party rights that may be infringed by your sharing it, do not post it to and/or through our Services. We are not responsible for another’s misuse or misappropriation of any content or information you post.

Changes to this Privacy Policy

  1. We may amend this policy from time to time. If we make any substantial changes in the way we use your Personal Information we will notify you by sending a notice to the primary email address specified in your account or by posting a prominent notice on our pages however You should review this policy on a regular basis to check for any changes made to it.


Questions, comments and requests regarding this privacy policy are welcome and should be addressed to:

November 2015
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