Job Applicant Privacy Policy and
Notice at Collection

Effective Date: October 30, 2023

Last Reviewed: October 30, 2023

This Job Applicant Privacy Policy and Notice at Collection (“Policy”) describes how OwnCompany Inc. (“Company”, “we”, “us” and “our”) collects, uses, and discloses information about individuals who apply for open positions at our Company (“Job Applicants”).

This Policy does not apply to our handling of data gathered about you in your role as a user of our services. If you interact with us as in that role, the Own Privacy Notice applies.  

Please read this Policy and any other privacy notices carefully.  Please note that this Policy does not form part of any employment contract or contract to provide services.

Types of Personal Information We Handle

We collect, store, and use various types of information that identifies, relates to, or could reasonably be linked to you (“personal information”) in connection with your application for employment with us. We collect such information either directly from you or (where applicable) from another person or entity, such as professional networking websites, job posting websites, employment agencies, recruitment companies, or your professional references. We may collect additional personal information throughout the course of your application process.

The information we collect from and about Job Applicants includes, where applicable:

Education information such as institutions attended, degrees, academic record, certifications, licenses, transcript information, and professional memberships.

Business travel and expense information such as travel itinerary information, how long it took to get to the interview, and expenses incurred for travel during the interview process.

Audio or visual information such as CCTV footage, as well as other information relating to the security of our premises collected during in-person interviews or other parts of the recruitment process.

Internet and electronic network, and device activity and device information and related identifiers, such as information about your use of our network while you are on Company premises, including IP address and device identifiers and attributes, and browser-type.

Geolocation data: such as approximate location inferred from your IP address, city, or county.

Potentially protected classification information to the extent required or as permitted by law and voluntarily provided such as race/ethnicity, color, sex/gender, military and veteran status, disability, accommodation information, nationality, citizenship, and other information (insofar as such information is “sensitive personal information,” we use it for the purposes set forth below specific to sensitive personal information).

Inferences drawn from other personal information provided for example, preferences, abilities, aptitudes, and characteristics.

Other information that you may voluntarily choose to include on your resume, in connection with your application, during your interview, or otherwise.

How We Use Personal Information

We may collect, use, disclose, and store personal information for our business purposes, which include, where applicable:

• Engaging in the recruitment process, including communicating with you; contacting you about jobs you may be interested in; interviewing, selecting and hiring new personnel; responding to your inquiries or requests; verifying eligibility for employment; conducting applicant reference checks to assist in hiring decisions; conducting background and related checks; employee onboarding; maintaining and administering payroll and employee benefit plans maintaining personnel records; and complying with record retention requirements.

• HR management and administration, including determining compensation, scheduling, IT and informational security purposes, fraud prevention, conducting internal analyses and audits,  promoting the Company’s diversity and inclusion, and perform workforce analytics, data analytics, and benchmarking; providing you with HR and employment-related services and support; engaging in human capital analytics (including to identify correlations about individuals and job success, analyze data to improve retention and productivity, and analyze employee preferences) to inform human resources policies and procedures; and communicating with you, your emergency contacts, or your beneficiaries.
• Security operations, including detecting security incidents, debugging and repairing errors, and preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution; monitoring and controlling access to company premises and locations (including through use of CCTV); facilitating the efficient and secure use of Company information systems; ensuring compliance with Company information systems policies and procedures; and safeguarding the Company and its locations, services, and employees.
• Safeguarding Company and the services, including the protection of the Company, our workforce, users, partners, and others.

• Legal compliance and exercising our legal rights, such as complying with applicable laws; responding to and cooperating with legal or regulatory requests and investigations; conducting internal audits; investigating grievances, complaints, and suspected violations of the law or Company policies; exercising or defending the legal rights of the Company and its employees; seeking legal advice from our external lawyers or in connection with litigation with a third party; and responding to requests as required by applicable law or court order.

• At your request, in order to fulfil your instructions.

We may also use personal information for any other legally permitted purpose (subject to your consent, where legally required).

Some personal information we collect in the recruitment process, such as ethnicity and veteran status, may be considered “sensitive” under applicable law. We use such information only for the following purposes: government reporting purposes, such as to help us monitor compliance with equal opportunity legislation; designing, implementing, and promoting our diversity and inclusion programs; analyzing and understanding our workforce; conducting internal audits; investigating grievances and suspected violations of Company policy; and exercising or defending the legal rights of Company or our employees. Some “sensitive” information may be required for certain job applications

In countries where we are required to state the “legal basis” on which we process personal information, we process Job Applicants’ personal information where:

• The processing is necessary to enter into or perform a contract to which you are party, such as to evaluate whether we want to enter into an employment contract with you.

• We, or a third party, have a legitimate interest in using your personal information for business purposes such as evaluating your candidacy for employment, determining compensation, and security.
• The processing is necessary for compliance with a legal obligation.
• You have consented to such processing.

How We Disclose Personal Information

We may disclose certain personal information to the following types of entities or in the following circumstances (where applicable):

• Internally: to employees within the Company that participate in the recruitment process, such as HR managers and employee interviewers, and among our corporate affiliates.

• Vendors: such as background check companies, security providers, information technology providers, travel management companies, and employment businesses (e.g., recruiting contractors or agency workers) that provide us with services relevant to recruiting and hiring.
• Recruiters: to the extent you are working with a recruiter in connection with your application for employment and your recruiter is authorized by you to obtain feedback from us regarding your application and interview process.
• Legal compliance and exercising legal rights: (i) when required to do so by law, regulation, or court order, (ii) in response to a request for assistance by the police or other law enforcement agency; (iii) to seek legal advice from our external lawyers or in connection with litigation with you or a third party or (iv) as otherwise necessary to exercising our legal rights or to protect the Company or its employees.
• Business transaction purposes: in connection with the sale, purchase, or merger of all or a portion of our Company.
• Consent: with your consent and as permitted by law, we may disclose personal information to any other parties in any other circumstances.

Data Retention

The personal information we collect from Job Applicants will be retained until we determine it is no longer necessary to satisfy the purposes for which it was collected and our legal obligations. As described above, these purposes include our business operations and complying with reporting, legal and accounting obligations. In determining how long to retain information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which we process the personal information and whether we can achieve those purposes in other ways, the applicable legal requirements, and our legitimate interests.  

Additional Privacy Information for Residents of Certain Jurisdictions

Residents of California, the European Economic Area (“EEA”), the United Kingdom (“UK”), and Switzerland have certain rights regarding their personal information. This section is solely applicable to such residents to the extent that such rights apply.

California: Subject to certain exceptions, if you are a California resident, you may request:

• access to certain of your personal information, including the right to know the categories of personal information we have or will collect about you and the reason we will or have collected such information;

• correction of certain of the personal information that we have about you that is inaccurate; or
• deletion or removal of certain of your personal information.

You also have the right not to be discriminated against (as provided for in California law) for exercising your rights.

EEA, UK, and Switzerland: Subject to certain exceptions, if you are in the EEA, UK, or Switzerland, you may request:

• access to your personal information;

• correction of certain of the personal information that we have about you that is inaccurate;
• deletion or removal of certain of your personal information;
• to receive personal information you provided to us to transmit it to another entity;
• to object to or restrict certain processing of your personal information; or
• to withdraw consent to our future processing of your personal information where the basis of such processing is your consent.

You also have the right to lodge a complaint with the Supervisory Authority in your jurisdiction regarding our processing of your personal information, but we encourage you to contact us first so we can do our best to resolve any complaints.

Exceptions to Your Rights: There are certain exceptions to these above rights. For instance, we may retain your personal information if it is reasonably necessary for us or our service providers to provide a service that you have requested or to comply with law or to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity or prosecute those responsible for that activity.

Exercising Your Rights: To exercise one of the rights above, you may contact us as provided below. We will take reasonable steps to verify your identity before responding to a request. In doing so, we may ask you for verification information so that we can match at least two verification points with information we maintain in our files about you. If we are unable to verify you through this method, we shall have the right, but not the obligation, to request additional information from you.

Other Information for California Residents: California law places certain obligations on businesses that “sell” personal information to third parties or “share” personal information with third parties for “cross-context behavioral advertising” as those terms are defined under the California Consumer Privacy Act (“CCPA”). We do not “sell” or “share” the personal information covered by this Policy and have not done so in the twelve months prior to the effective date of this Policy.

California law also requires that we provide you with the “categories” of personal information we collect and the categories of entities to which we disclose such personal information. In the 12 months leading up to the effective date of this Policy, we have disclosed the categories of personal information described in Section 1 of this Policy to the categories of entities described in Section 3 of this Policy, as follows:

Under California law, we collect the following “sensitive personal information”: race and ethnicity. We disclose this information to the following categories of entities as necessary for equal opportunity and diversity and inclusion purposes and for compliance with applicable law (including immigration and employment law) or to exercise rights thereunder: internally and to vendors, for purposes of legal compliance and exercising legal rights, and with your consent.

How to Contact Us About This Policy

If you have questions about our collection, use, or disclosure of personal information, please contact us by email at privacy@owndata.com or in writing at: