DISCLAIMER

This document is an example and template for customers who intend to collect personal data of job candidates. If you are a job candidate and have questions about this document, your data, or any other privacy-related matter, don't hesitate to contact Comeet's customer (the company assessing you as a candidate).

If you are a Comeet customer, this document nor its content applies as legal advice. You (the customer) should contact your attorney to seek legal advice concerning privacy rules, requirements, and obligations, including, without limitation, the specific details and information that you, as the employer, should include in the candidates' privacy notice.

This privacy notice (the "Notice") describes the ways that the company recruiting you as a candidate ("Company," "we," "us," "our"), collects and uses your data as a candidate ("you" or "candidate"). We work with data processors whom we have instructed to collect, store and process personal information on our behalf to provide our services, for example, Comeet, as a recruiting and applicant tracking platform ("Platform") to handle your data as a candidate. It also describes the rights and options concerning your data.

We may have an additional privacy notice(s) explaining our specific privacy practices related to your data ("Company Notice").

Please note that this Notice is provided only for transparency purposes. Contact the company directly if you have any questions about your personal data.

We are only responsible for the candidates' data when provided to the Platform in the context of your candidacy. We determine the means and purposes for the processing of your data.

1. PERSONAL DATA PROCESSED

We receive personal data about you as a candidate for positions at the company, such as: contact information, address, Curriculum Vitae (resumé) information (including information such as skills, work experience, education), notes submitted with the application, URL of your LinkedIn and other online profiles, the position for which you have been or are being considered, the source who submitted your candidacy (e.g., recruiting agency, referral), email correspondences between you, the Company and between the company and other sources (such as recruiting agency and referrals) about your candidacy, information from references, events in the lifecycle of your candidacy, your responses to questionnaires sent to you by us, information about your candidacy and employment options (such as availability to be hired and salary expectations), evaluations of your candidacy, internal discussions within the company about your candidacy, materials you or other parties (such as evaluators or background check providers) submitted in relation to your candidacy. If you offer your candidacy by email or online, you are the primary source of the personal data. Your data can also originate from other sources, such as LinkedIn profiles, recruitment agencies, headhunters, and referrals.

2. HOW YOUR PERSONAL DATA IS USED. LEGAL BASIS.

We will use your data per our Company Notice (if any is available to you), including to evaluate and consider you as a candidate for positions following its processes and policies for assessing employment candidates, to contact you for your candidacy status and interviews, to schedule meetings and discussions, amongst others.

The lawful bases we rely on for processing personal information are (if applicable to us under privacy law):

  1. You gave us your consent to the processing of your data (for one or more specific purposes);

  2. Processing is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into a contract;

  3. Processing is necessary for the legitimate interest; and,

  4. Processing is necessary for compliance with a legal obligation to which the controller is subject.

If you have questions about these uses, please get in touch with us. Please note that the legal basis is for GDPR purposes only.

3. WHO WILL PROCESS YOUR DATA

We may share your data with our service providers and vendors who assist us in collecting, process, and storing your data, including, Comeet (who provide us with the Platform) in the context of your candidacy. These companies are authorized to use your data as necessary to provide these services or as otherwise permitted by us. Comeet's privacy policy is available here.

  1. Personal data may be shared with, or transferred to, our affiliated corporate group entities (entities controlled by, under common control with, or controlling us, directly or indirectly).

  2. We may share your general recruitment status with third parties submitting your candidacy.

  3. If your details are submitted to the company by a third party (such as an employee or a recruiting agency), the company can give the third party access to your name, photo, and general recruitment status.

  4. If you apply to a job opening using a unique referral link that was provided to you by an employee of the company to which you are applying, the company may share some of your general recruitment statuses, without identifying you by name, with the person that provided you the referral link.

  5. The purpose of sharing the above information is to operate the company's incentive programs (i.e., employee referral bonus programs) and to provide feedback to third parties who submit candidates to the company regarding their submission.

  6. We must disclose your information to judicial, governmental, and regulatory authorities to comply with applicable laws, regulations, and rules (including, without limitation, federal, state, or local laws) and requests of law enforcement, regulatory, and other governmental agencies when compelled by court order.

  7. If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares, or assets to a third party, we will disclose your data to such third party (whether actual or potential) in connection with the preceding events.

  8. If we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a similar event, we reserve the right to transfer, disclose or assign your data in connection with the preceding events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company.

If you wish to receive further information, please get in touch with us.

4. SECURITY AND DATA RETENTION

  1. Retention. We will retain your data for as long as we need it to assess you as a candidate or as long as we have a valid legal basis. Per our internal data retention policies and practices, we can decide whether to keep your data, delete it, or pseudonymize/anonymize it.

  2. Security. We implement industry-standard measures to reduce the risks of damage, loss, unauthorized access, or use of your data. However, these measures do not provide absolute information security.

5. INTERNATIONAL DATA TRANSFERS

We host your data in connection with our use of the Platform in the European Economic Area, the U.S., or countries deemed as providing adequate data protection.

Your data will be accessible in the country where we, or our service providers, are located: the U.K., the U.S., and countries deemed with adequate data protection.

See here the Platform's vendors. For more information, please get in touch with us.

6. YOUR RIGHTS

Your rights may vary depending on the applicable law. These rights may not be available in certain jurisdictions and/or may be subject to specific derogations or limitations. You may have the following rights:

  1. To ask us for a copy of your data stored on our servers, including the Platform;

  2. to update, correct, or delete your data;

  3. to request the restriction of processing concerning your data or to object to the processing of your data;

  4. to request to obtain a copy of your data in a structured, commonly used, and machine-readable format;

  5. If we rely on consent, please note that you have the right to withdraw consent at any time; and

  6. to complain to a supervisory authority.

If you wish to exercise any of these rights, don't hesitate to contact us. If you choose to exercise any of your rights, we will handle these requests following applicable law, but please note that exercising some of those rights may have consequences for your application as a candidate.

In the context of the Platform, we do not use any automated decision-making related to your data.

7. MINORS

We do not intend to collect the personal data of children. If you have reason to suspect that children's data is collected, you are kindly requested to report it to us immediately. If you have questions regarding children's data, contact us.

8. CHANGES TO THIS PRIVACY NOTICE

From time to time, we may change or update this Notice. If we do so, we will try to notify you of such changes by any means.

9. CONTACT US

You may send requests, responses, questions, and complaints by contacting us.

(GDPR only) If your question concerns our data protection officer (DPO) or representative in the E.U., we will forward the request accordingly.