Job applicants privacy notice

About this Notice		This notice explains our privacy practices and how we handle Personal Information related to you as a job applicant. Our privacy practices related to our employees (including successful job applications) are governed by our employee privacy notice and not this Notice.
What Personal Information Do We Collect and Use?		We record, collect, store and analyze Personal Information, including Personal Information connected to your identity and job application; contact information; other sensitive information; use of or access to equipment; and CCTV footage.
Sensitive Personal Information		We collect and use sensitive Personal Information you provide us for the purpose of supporting our recruitment process.
Whose Personal Information We Process		We process Personal Information related to our current, former, or prospective (nominees) employees, partners, workers, interns, agency workers, consultants, directors or contractors. We may also Process Personal Information in relation to dependents of such parties.
How do We Collect Personal Information?		We collect Personal Information directly from you during your recruitment process, through the application and recruitment process and from third parties.
Why We Collect and Use Personal Information?		We collect and use Personal Information primarily to manage our recruitment process, including management of access and usage, compliance with applicable laws, regulations, and diversity requirements, and for defense against cyber-security attacks.
Lawful Grounds for Processing Personal Information		All Processing of Personal Information related to you that is not based on the lawful grounds indicated in this policy, or if such lawful grounds may not be used for the Processing of Personal Information related to you based on your territory, is based on your consent.
How Long Do We Retain Personal Information?		We retain Personal Information for the period necessary to fulfill the purposes, rights and obligations that this Notice outlines. We retain records relating to our job applicants for a maximum of 4 years following the termination of the job application.
Who Has Access to Personal Information?		We will share Personal Information internally, including with members of our HR, Legal, Security and Finance departments, your direct potential manager, senior management and our IT staff, if access to the Personal Information is necessary to them for the performance of their roles.
Who Do We Share Personal Information With?		We share Personal Information with our affiliates, suppliers and vendors, to fulfil the purposes of Processing outlined in this Notice. We share Personal Information with Institutions and authorities, when we are required to do so by law, or to respond to legal processes; to maintain our security; and, to protect our legal rights and interests.
Selling Personal Information		We do not sell Personal Information. However, we engage third parties to provide us with services such as analytics, marketing automation and user experience and allow them to collect Personal Information on our Websites.
What Are Your Obligations?		It is important that the Personal Information that we hold about you throughout your job application is accurate and current. Please keep us informed if Personal Information related to you changes.
What Are Your Choices and Rights?		You may request to access, correct, delete, or obtain a copy of Personal Information we have about you. Depending on applicable law, you may have additional rights available to you.
How Do We Secure Personal Information?		We have implemented administrative, technical, and organizational security measures as well as policies and procedures to protect Personal Information.
International Transfer		We transfer Personal Information between various sites located in Israel, the U.S., and additional territories. Whenever we transfer Personal Information beyond the country of origin, we will do so in accordance with applicable laws.

About of this Notice

We WiseStamp Technologies Ltd. and our subsidiaries and affiliates (including, without limitation, WiseStamp Inc., collectively: “we”, “us”, and “our”) put great efforts in making sure that we secure Personal Information related to you and use it properly.

This notice (“Notice”) explains our privacy practices and how we handle Personal Information related to you as a job applicant when you apply for a job with us. Specifically, this Notice will provide details about the Personal Information that you submit to us as a job applicant, what we do with Personal Information and how we Process, retain and share it, and the rights that you may have in connection with Personal Information.

Note that if your application for employment is successful, the Processing of Personal Information related to you (including information you provided as part of your job application) will no longer be governed by this Notice and will instead be governed by our then in effect employee privacy notice, which will be provided to you if you become employed with us.

“Personal Information”means information related to you which either identifies or that can identify you and includes any similar terms under applicable laws and regulations governing the protection of privacy and personal data, including without limitation “personal data” and “information”.

“Processing” means any operation performed by us on Personal Information.

Please take the time to read this Notice, and do not hesitate to contact our HR team at: [add email] should you have any questions regarding your privacy rights or this policy.

You may find further information regarding how to contact on [add link], and our privacy team may be reached at: [add email].

What Personal Information Do We Collect and Use?

When you apply for a job with us, we will ask you to provide certain Personal Information that will help us evaluate your qualifications and candidacy and to stay in touch with you during the application and recruitment process. We record, collect, store, and analyze Personal Information that you provide us and that we receive or collect about you, including:

• Personal Information connected to your identity: For example, first name, surname, title, date of birth, place of birth;
• Contact information: For example, address (street, zip code, country), phone number, email address;
• Personal Information related to eligibility: For example, resume/CV, cover letter, salary, benefits, tax and pension-related information, performance-related information, employment history (employers, job titles, length of employment), recruitment history, educational background and training, linguistic capabilities, job skills, personal interest, and background checks;
• Verification and background information and documents: For example, diplomas, certificates, national IDs, driver’s license, passport, social security, birth certificate;
• Reference materials and documents: For example, job references and letters of recommendation, job salary/payment history, military records, titles and licenses, immigration visa status, security clearance, background checks including criminal history (where permitted by law);
• Social media information: For example, your LinkedIn profile;
• Content and Inferences: Any information, content, or communications transmitted to or from, received or printed from, or created, stored or recorded on any of the above, including for personal use, and any inferences drawn from the Personal Information listed above.
• Information Collected On Our ‘Jobs’ Page: When you visit our ‘Jobs’ online webpages available at [add link] or view job positions, or click on the ‘Submit Application’ button for specific positions, we and our third party service providers collect information such as the IP address of your device, which provides your device’s location (up to the city where you are located and not precise geo location), and other non-identifiable information that is used for analytical purposes, such as the type of browser, browser language, type of operating system, domain name of Internet service provider, web pages visited, times and dates of visits and the content you access on and/or through the Websites.

Sensitive Personal Information

Subject to any limitations under applicable laws, we collect and use the following sensitive Personal Information that you provide us and that we receive or collect about you for the purpose of supporting our recruitment process:

• An individual’s government issued ID, such as a national or state identification card, social security number, driver’s license, or passport number.
• An individual’s racial or ethnic origin, religious or philosophical beliefs, or union membership.
• The contents of an individual’s mail, email, and text messages unless we are the business that is the intended recipient of the communication.
• Personal Information collected and analyzed concerning an individual’s health.
• Personal Information collected and analyzed concerning an individual’s sex life or sexual orientation.

We do not use or disclose such sensitive Personal Information for the purpose of inferring characteristics about you or for cross-context behavioral advertising.

Whose Personal Information We Process

We may process Personal Information related to you if you are a current, former, or prospective employee, partner, worker, intern, agency worker, consultant, director or contractor of ours.

We may also Process Personal Information in relation to dependents or other family members of the above people, in the circumstances set out in the section titled “Why We Collect and Use Personal Information?“.

How Do We Collect Personal Information?

We obtain the categories of Personal Information listed above from the following categories of sources:

• Through the application and recruitment process, either directly from you when you apply for a job, or from recruitment service providers or consultants if such were involved. If you use our online application system to apply for a job, our HR platform service provider will collect personal information related to you on our behalf. Hi Bob Ltd. is our third-party service provider that handles our job recruitment process (see further information in the “Who Do We Share Personal Information With?” section below). We may decide to change our job recruitment service provider. Please note that the processing of Personal Information by the job recruitment service provider is also governed by their own separate privacy policy which is available through the career application webpages.
• From third parties including former employers, or other information providers, online sources, publicly available government registries and, subject to applicable laws, through background checks.

Why We Collect and Use Personal Information?

We collect and use Personal Information primarily to manage our recruitment process (the “Purposes”), including:

• To process your application;
• to comply with equal opportunity, diversity, inclusion and other legal requirements and to protect our legal rights;
• to combine Personal Information related to you with background checks’ information that we receive from third party service providers;
• to manage, maintain and document recruitment and other HR-related activities and personnel generally, for example, to conduct data analytics studies to review and understand better personnel retention and attrition rates;
• to manage business operations and governance, for example: auditing, HR development and handling fraud and other violations of the law;
• to comply with legal and other mandatory requirements, including to obey orders and subpoenas, and to comply with supervision and enforcement actions;
• to support any corporate structure change, including mergers, acquisition and other corporate transactions;
• to monitor your use of any information and communication systems that we will make available to you during your recruitment process and for cyber security purposes; and,
• when we believe in good-faith that using Personal Information is necessary to protect the life, health, safety or other vital interest of ours, our personnel, and any other person.

Lawful Grounds for Processing Personal Information

All Processing of Personal Information related to you that is not based on the lawful grounds indicated below, or if such lawful grounds may not be used for the Processing of Personal Information related to you based on your territory, is based on your consent.

• We Process your job application related information to perform the recruitment process contract with you.
• We will also Process Personal Information related to you to comply with our obligations under applicable law and to protect your and others’ vital interests.
• We will further rely on our legitimate interests, which we believe are not overridden by your fundamental rights and freedoms, for example: (1) our HR and corporate management purposes; and (2) cyber security and fraud detection.

How Long Do We Retain Personal Information?

If your application for employment is unsuccessful, we will hold Personal Information related to you on file for up to 4 years after notifying you of our decision or as otherwise required or permitted under applicable laws. Thereafter, personal information related to you will be deleted.

If your application for employment is successful, Personal Information gathered during the recruitment process will be transferred to your personnel file and retained during your employment subject to our then in effect employees’ privacy policy.

However, we will maintain a record with details about your submission of the application with us, such as your name, interview dates and locations, our decision whether to hire you or not and other relevant information to establish exercise and defend legal claims, for internal review, oversight and operation of our HR efforts and if we are required under law to retain Personal Information related to you.

Retention periods can vary based on how long the recruitment process lasts and the period between when you first apply and when a hiring decision is made in connection with your application.

You can let us know that you would like us to save Personal Information related to you for a longer period, to take into account for future job postings.

Who Has Access to Personal Information?

We will share Personal Information internally, including with members of our HR, Legal, Security and Finance departments, your potential direct manager, senior management and our IT staff in appropriate circumstances if access to the Personal Information is necessary for performance of their roles.

Access to Personal Information related to you within our companies is restricted to those who need to obtain access to it for the purposes outlined above, and generally they will only have access to that part of the Personal Information relating to you that is relevant to the particular purpose concerned.

We may disclose certain Personal Information related to you to our auditors and other professional advisors or consultants providing services to us that require such disclosure.

Who Do We Share Personal Information With?

We will share Personal Information in the following instances:

• With our third-party service providers, such as the job recruitment service provider that handle our job recruiting, hiring, and on-boarding process, or with any additional service provides which help us with the recruiting process.
• With third party service providers that provide legitimate business functions for us, which will include processing Personal Information. Such third-party service providers are engaged by us for the provision of, among others, data storage, information security and employee background checks.
• With competent supervisory authorities, if we determine that doing so is in accordance with, or is otherwise required by applicable law, regulation, judicial or legal process.
• With law enforcement or other authorities (including immigration, health, tax, national security) when it is necessary to protect the interests of our company or individuals.
• With another entity when it is required as part of a merger, acquisition or assignment of part or all of our business with that entity, or any other change of corporate structure.

We do not sell, rent, lease or otherwise commercialize Personal Information. See the section titled “Selling Personal Information” for further details.

In the preceding twelve (12) months, we have disclosed identifiers with service providers who assist us with completing certain background checks (including criminal history) and employment eligibility verification processes; and Personal Information related to employment relationship with performance management service providers.

Selling Personal Information

We may share Personal Information related to you with various third parties such as our service providers and our affiliates, as further described under the section titled “Sharing Personal Information with Others” in this policy.

We do not sell or share Personal Information. However, we engage third parties to provide us with services such as analytics, marketing automation and user experience and allow them to collect Personal Information on our websites available at: [add link] and/or [add link] (“Websites”).

We do not knowingly sell or share Personal Information of individuals who are under 16 years of age.

These third-parties do not pay us for collecting such information, but the right granted to them to collect Personal Information may be considered as disclosure for the purpose of sale or sharing for cross-context behavioral advertising under applicable laws governing the protection of privacy. At any time, you can opt-out of the collection of Personal Information by such service providers by contacting us.

What Are Your Obligations?

It is important that Personal Information that we hold about you during the recruitment process is accurate and current. Please keep us informed if Personal Information related to you changes.

You must inform your dependents whose information you provide to us about the content of this Notice and provide them with a copy of this Notice and any relevant policies.

You must also comply with this Notice and our policies, standards, and procedures that are brought to your attention when handling any information to which you have access in the course of your relationship with us, including any Personal Information related to other individuals. In particular, you will not access or use any information for any purpose other than in connection with and to the extent necessary for your work with us. These obligations continue to exist after termination of your job application with us.

What Are Your Choices and Rights?

You have the following rights:

• You may request to confirm that we Process Personal Information related to you.
• You may request to access, correct, delete, or to obtain a copy of Personal Information related to you and, depending on applicable law, you may have additional rights available to you. You may also request that we anonymize, block, or delete Personal Information related to you which you believe to be unnecessary or excessive and is processed in violation of applicable law.

As part of your request, you may also request that we provide you with the following information:

• the purposes of the processing.
  • the categories and specific pieces of Personal Information related to you that we Process .
  • the recipients or categories of recipient to whom the Personal Information has been or will be disclosed, in particular recipients in third countries or international organizations.
  • where possible, the envisaged period for which the Personal Information will be stored, or, if not possible, the criteria used to determine that period.
  • the existence of your right to request rectification or erasure of Personal Information or restriction of Processing of Personal Information related to you or to object to such Processing.
  • the existence of your right to lodge a complaint with a supervisory authority.
  • where the Personal Information in question was not collected directly from you, any available information as to such information’s source.
  • if relevant, the existence of automated decision-making, including profiling, and in such case, information about the logic involved, as well as the significance and the envisaged consequences of such processing for the individual.
  • Confirmation whether or not we sell Personal Information related to you.

We will review your request and use our judgment, pursuant to the provisions of applicable law, to reach a decision about your request.

• AT ANY TIME, CONTACT US IF YOU WANT TO WITHDRAW YOUR CONSENT TO THE PROCESSING OF PERSONAL INFORMATION. NOTE HOWEVER, THAT EXERCISING THIS RIGHT WILL NOT AFFECT THE LAWFULNESS OF PROCESSING BASED ON CONSENT BEFORE ITS WITHDRAWAL. YOU MAY ALSO OBTAIN INFORMATION ABOUT THE POSSIBILITY OF DENYING CONSENT AND THE CONSEQUENCES OF SUCH DENIAL.
• You may request to delete or restrict access to Personal Information related to you. We will review your request and use our judgment, pursuant to the provisions of the applicable law, to reach a decision about your request.

If you exercise one (or more) of the above-mentioned rights, in accordance with the provisions of applicable law, you may request to be informed that third parties that hold Personal Information related to you, in accordance with this policy, will act accordingly.

• You may request information about public and private entities with which we have shared Personal Information related to you.
• You may ask to transfer Personal Information in accordance with your right to data portability.
• We do not Process Personal Information or otherwise use it to make decisions about you that are solely based on automated Processing and we do not create a profile about you.
• You have a right to lodge a complaint with a data protection or privacy supervisory authority of your habitual residence, place of work or of an alleged infringement of applicable laws governing the protection of privacy.

Only you or a person authorized to act on your behalf, may make a request concerning Personal Information that we retain about you. You may also make a verifiable request on behalf of a minor under your charge.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons for such decision and provide you with a cost estimate before processing further your request.

You will not receive discriminatory treatment and you will not be retaliated against for exercising your rights.

To exercise any of the abovementioned rights, please contact our HR team at: [add email]. Upon your request and based on the rights afforded to you under applicable law, we will respond to your request promptly.

We will do our best to respond to your request within 30 days of its receipt (unless otherwise required under applicable laws). If we require more time (up to additional 30 days), we will inform you of the reason and extension period in writing. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. The response we provide will also explain the reasons for our inability to comply with your request, if applicable.

How Do We Secure Personal Information?

We have implemented administrative, technical, and organizational security measures, as well as policies and procedures, to protect Personal Information. These measures and procedures are designed to protect Personal Information against risks, such as temporary or permanent loss, destruction, and unauthorized or unlawful access, alteration, use or disclosure.

We require our suppliers and vendors to apply similar security measures and procedures when they access or use Personal Information that they process on our behalf.

International Transfer

We transfer Personal Information between various sites located in Israel, the U.S., and additional territories to operate our business efficiently, to improve performance, and to create redundancies in order to protect information in the event of an outage or other malfunctions.

Whenever we transfer Personal Information beyond the country of origin, we will do so in accordance with applicable law.

We transfer Personal Information that we process between various territories. Some of these territories regulate such transfer and we take the necessary and appropriate safeguards to ensure a lawful transfer, including to territories that do not provide an adequate level of protection to Personal Information. In particular, before transferring the Personal Information, we will assess risks involved with the transfer, enter into relevant information transfer agreements, adhere to applicable security and confidentiality requirements, or take such other measures to lawfully transfer the Personal Information.

If applicable laws permit us to rely on your consent to transfer Personal Information related to you, then by submitting your application you signify your consent to such transfer.

You can obtain a copy of the suitable safeguards that we use when transferring Personal Information as described above or receive further information about information transfers by contacting us at: [add email[add link]].

How Do We Change this Notice?

From time to time, we will need to update this Notice. If the updates have minor if any consequences, they will take effect 7 days after we post the revised notice subject to this provision. If any change to this Notice materially affects you, we will use reasonable efforts to notify you in advance, such as by sending an email or posting a prominent notice of the changes. We will give you a reasonable period of time to object to any changes and we will seek affirmative consent if and where this is required by applicable data protection and privacy laws.