Syndigo Job Applicant Privacy Notice

Effective on: Sep 20, 2023

1. Introduction

Syndigo LLC and its affiliates (collectively, “Syndigo”, “we”, “us”, “our”) take the protection of the individuals applying for an open position at Syndigo (“job applicants”, “you”, “your”) personal data (“Personal Data”) very seriously. Please read this Job Applicant Privacy Notice (this “Notice”) to learn what Personal Data we collect about you in relation to processing your application and evaluating your suitability for working at Syndigo, why and how we collect and use it, how we secure it, and with whom we might share it.

This Notice also informs you of your privacy rights under the:

• European Union General Data Protection Regulation (“GDPR”);
• United Kingdom General Data Protection Regulation (“UK GDPR”) and the Data Protection Act;
• Swiss Federal Act on Data Protection;
• California Consumer Privacy Act of 2018 (“CCPA”) and California Consumer Privacy Act (“CPRA”); 
• Canadian Personal Information Protection and Electronic Documents Act (“PIPEDA”); 
• Mexican Federal Law on Protection of Personal Data Held by Private Parties and the Regulations to the Federal Law on Protection of Personal Data Held by Private Parties; 
• Brazilian Lei Geral de Proteção de Dados Pessoais (“LGPD”); and
• Indian Information Technology Act, Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules (together, “Applicable Data Protection Laws”).

Syndigo has adopted this Notice to comply with Applicable Data Protection Laws. Any terms defined in Applicable Data Protection Laws have the same meaning as when used in this Notice.

2. What Is Covered by this Notice

This Notice is designed to help you understand how we process your Personal Data when you submit an application for an open position at Syndigo. We process your Personal Data for the purposes of recruiting you, which is a process that involves but is not limited to assessing your suitability for an open position at Syndigo (the “Recruitment Process”).

Within the scope of this Notice, Syndigo is the business that makes the decisions about the processing of the Personal Data we collect or that others collect on our behalf (also known as the “data controller” or the “business”).

This Notice does not cover any other data collection or processing, including the data related to our staff (employees or independent contractors), our website, web applications, or mobile applications (for which we act as the “data controller”), or the data we host for our customers via our SaaS applications (and for which we act as a “data processor” or “service provider”). For more information about our collection of Personal Data in other contexts, please see: https://syndigo.com/legal/. If you are engaged by Syndigo as an employee or independent contractor, the processing of your Personal Data will be governed by Syndigo Global Employee Privacy Notice.

3. What Personal Data We Process and How We Obtain It

The table below describes the categories of Personal Data we collect during our Recruitment Process and which we have collected in the preceding 12 months.

Some of this information may qualify as special categories of Personal Data or sensitive personal information under applicable data protection laws.

We will not collect additional categories of Personal Data without informing you.

4. Lawful Bases for Processing

The GDPR and other applicable data protection laws require that we have a valid reason to use your Personal Data. This is called the “lawful basis for processing.” We may process your Personal Data:

• Because you gave your consent.
• Because we need to perform a contract with you.
• Because we have a legitimate interest in processing your Personal Data and it is not overridden by your rights. Some of those interests include:
  • identifying and preventing fraud.
  • enhancing the security of our network and information systems.
  • defend or initiate legal claims, as applicable.
• Because we need to comply with the law.
• On another ground, as required or permitted by law.

When we rely on legitimate interests as a lawful basis of processing, you have the right to ask us more about how we decided to choose this legal basis, and you have the right to object to processing on this basis. To do so, please use the contact details provided here.

Where we process your Personal Data based on your consent, you may withdraw it at any time. However, this will not affect the lawfulness of our processing before you withdrew your consent. It will also not affect the validity of our processing of Personal Data performed on other lawful grounds.

Where we receive your Personal Data as part of the Recruitment Process based on a contract, we require such Personal Data to be able to carry out the contract. Without that necessary Personal Data, we will not be able to carry out the Recruitment Process.

5. Cookies

To learn about Syndigo’s use of cookies and the use of opt-out preference signals such as Global Privacy Control (“GPC“), please read our Cookie Notice.

6. For What Purposes Do We Use Your Personal Data

We may process your Personal Data (including special categories of Personal Data or sensitive personal information) for one or more of the following purposes:

• Recruiting purposes, such as conducting the Recruitment Process, assessing your skills and qualifications, arranging interviews or testing, and making hiring decisions;
• Deciding whether to offer you a job;
• Preparing the offer letter;
• Communicating with you during the Recruitment Process;
• Responding to your requests or questions;
• Carrying out reference or background checks;
• Engaging in necessary precontractual activities or negotiations;
• Making the needed arrangements for your future employment;
• Proactively conducting research about your educational and professional background and skills and contacting you if we think you would be suitable for another role at Syndigo.
• Making improvements to Syndigo’s job application and/or Recruitment Process, including improving interview practices, and improving diversity, equity, and inclusion in our Recruitment Process;
• Talent management;
• Record keeping.

To achieve the above purposes, we need to perform different types of processing activities on your Personal Data, such as storage, access, transmission, consultation, manipulation, and combination.

7. How Long We Keep Your Personal Data

When you accept a job offer at Syndigo, the Personal Data we process will be included as part of your ongoing employment record.

We retain your Personal Data for as long as it is necessary to evaluate your application for employment, unless a longer retention period is required or permitted by law, including for the purposes of satisfying any legal, accounting, or reporting requirements, or any other lawful legitimate purposes, that are not outweighed by your data processing interests or fundamental rights and freedoms.

If you do not receive or accept a job offer from Syndigo, we will keep your Personal Data for eighteen (18) months after the relevant Recruitment Process. We keep your Personal Data so we can contact you for other current and future employment opportunities at Syndigo.

When the purposes of processing are satisfied, we will delete your Personal Data in accordance with our data retention policy and applicable laws and regulations. We will also delete your Personal Data upon receipt of a verified request.

8. Automated Decision-Making

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making. There will always be human intervention into decisions based on automated processing, including automated profiling. If this position changes, or there is a need and lawful basis to do so, we will inform you.

9. Sharing Personal Data with Third Parties

We share your Personal Data with certain third parties who assist us in operating our Recruitment Process. However, these third parties must enter strict data processing agreements with Syndigo to ensure that they keep your Personal Data protected and only use it for the services they provide Syndigo during the Recruitment Process. They therefore must treat your Personal Data with the same level of protection that we do. The categories of third parties to which we may disclose your Personal Data include:

• Recruiting software service providers
• Verification and background checking providers
• Internet service providers
• Cloud service providers
• Email service providers
• Email security services providers
• Project management tool providers
• Office tool providers
• Online work collaboration tools
• Reporting and analytics service providers

We have disclosed Personal Data to third parties for business purposes. The third parties receiving Personal Data and their addresses are listed below. Syndigo may update this list from time to time. We will inform you about the updated list by updating the Effective Date on this Notice.

Note if you are located in the EU: Some of these third parties may be located outside of the European Union or the European Economic Area. In some cases, the European Commission may have determined that in some countries, their data protection laws provide a level of protection equivalent to European Union law. You can see here the list of countries that the European Commission has recognized as providing an adequate level of protection to personal data. We will only transfer your Personal Data to third parties in countries not recognized as providing an adequate level of protection to Personal Data when there are appropriate safeguards in place. These may include the European-Commission-approved standard contractual data protection clauses under Article 46.2 of the GDPR, or BCRs for processors under Article 47 of the GDPR.

Note if you are located in the United Kingdom (“UK”): Some of the entities we send Personal Data are located outside of the UK. In some cases, the UK Secretary of State may have determined that the data protection laws of some countries provide a level of protection equivalent to EU or UK law. You can see here the list of countries that the UK has recognized as providing an adequate level of protection to Personal Data. 

When the GDPR or the UK GDPR apply to the processing of Personal Data, Syndigo will only transfer the data out of the European Economic Area or the United Kingdom (respectively) to countries that have not been recognized as providing an adequate level of protection to Personal Data by using appropriate transfer mechanisms such as the European Commission approved standard contractual data protection clauses under Article 46.2 of the GDPR and the UK GDPR or BCRs for processors under Article 47 of the GDPR and the UK GDPR.

Note if you are located in Brazil: Some of these third parties may be located outside of Brazil. In some cases, the Autoridade Nacional de Proteção de Dados (“ANPD”) may have determined that certain countries’ data protection laws provide an equivalent level of protection to the LGPD. Where this is not the case, we will only transfer your Personal Data to third parties located in other countries when there are appropriate safeguards in place which the ANPD has confirmed as acceptable.

Sales or Sharing of Your Personal Data

Syndigo generally does not directly sell your Personal Data in the conventional sense (for money). Like many companies, however, we use services that help deliver interest-based ads to you or analyze our website traffic and may transfer Personal Data to business partners for their use. Making Personal Data (such as online identifiers or browsing activity) available to these companies may be considered a “sale” or “sharing” under the CCPA.
If you would like to opt out of the sales or sharing activities of your Personal Data that take place via cookies, you can learn how here.

Syndigo does not expect that the Personal Data of individuals under 16 is being collected, sold or shared, given that children are not expected to apply for an open position at Syndigo.

Other Disclosures of Your Personal Data

We may disclose your Personal Data to the extent required by law or if we have a good-faith belief that we need to disclose it in order to comply with official investigations or legal proceedings (whether initiated by governmental/law enforcement officials, or private parties). If we have to disclose your Personal Data to governmental/law enforcement officials, we may not be able to ensure that those officials will maintain the privacy and security of your Personal Data.

We may also disclose your Personal Data if we sell or transfer all or some of our company’s business interests, assets, or both, or in connection with a corporate restructuring. Finally, we may disclose your Personal Data to our subsidiaries or affiliates, but only if necessary for Recruitment Purposes, as described in the section above.

10. Risk of Harm

Whenever Personal Data is collected and processed, there is always a slight risk that the Personal Data may be breached, misused, or otherwise result in a harm to you. However, we take several measures to ensure that this risk is mitigated as much as possible. These measures include limiting the Personal Data about you that we collect and process to solely what is necessary, not collecting sensitive Personal Data about you, and implementing appropriate security measures, as described in this Notice.

11. What Privacy Rights Do You Have?

You have specific rights regarding your Personal Data collected and processed by us. In this section, we first describe those rights and then we explain how you can exercise those rights.

Right to Know What Happens to Your Personal Data

This is called the right to be informed. It means that you have the right to obtain from us all information about our Personal Data processing activities that concern you, such as how we collect and use your Personal Data, how long we will keep it, and who it will be shared with, among other things. We are informing you of how we process your Personal Data with this Notice.

Right to Know What Personal Data Syndigo Has About You

This is called the right of access. This right allows you to ask for full details of the Personal Data we hold about you.

You have the right to obtain from us confirmation as to whether or not we process Personal Data concerning you, and, where that is the case, a copy or access to the Personal Data and certain related information. Once we receive and confirm that the request comes from you or your authorized agent, we will disclose to you:

• The categories of Personal Data we collected about you;
• The categories of sources for the Personal Data we collected about you;
• Our purposes for processing that Personal Data;
• Where possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period;
• The categories of third parties to which we disclose that Personal Data, with whom we share it, or “sell” it to;
• The specific pieces of Personal Data we collected about you;
• If we rely on legitimate interests as a lawful basis to process your Personal Data, the legitimate interests pursued; and
• The appropriate safeguards for transferring data from the EEA, or UK to a third country, if applicable.

Please take into account that the GDPR allows us not to satisfy your access request when:

• you already have the information;
• providing such information proves impossible or would involve a disproportionate effort, or in so far providing such information is likely to render impossible or seriously impair the achievement of the objectives of that processing; and
• that Personal Data must remain confidential subject to an obligation of professional secrecy regulated by Union or Member State law, including a statutory obligation of secrecy.

We will not disclose account passwords or security questions and answers. We can inform you that we have this information generally, but we may not provide the specific items to you for security and legal reasons.

Right to Correct Your Personal Data

This is called the right to rectification. It gives you the right to ask us to correct anything that you think is wrong with the Personal Data we have on file about you and to complete any incomplete Personal Data.

Right to Delete Your Personal Data

This is called the right to erasure, right to deletion or the “right to be forgotten”. This right means you can ask for your Personal Data to be deleted.

Sometimes we can delete your information, but other times it may not be possible, such as when the law requires us to keep certain information. If that is the case, we will consider if we can limit how we use it. There may also be circumstances where we deny your request to delete your information under applicable law, such as if we or our third party service providers need to retain the Personal Data to:

• complete the Recruitment Process;
• provide a service you requested that is linked to the Recruitment Process;
• take actions reasonably anticipated within the context of our ongoing relationship with you, or otherwise perform a contract with you that is linked to the Recruitment Process;
• detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
• debug products to identify and repair errors that impair existing intended functionality;
• enable solely internal uses reasonably aligned with your expectations based on your relationship with us during the Recruitment Process;
• comply with a legal obligation, including (but not limited to) obligations from the California Electronic Communications Privacy Act; or
• make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to Ask Us to Change How We Process Your Personal Data

This is called the right to restrict processing. It is the right to ask us to only use or store your Personal Data for certain purposes.

You have this right in certain occasions, such as where you believe the data is inaccurate or the processing activity is unlawful. This right enables you to ask us to suspend the usage of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.

Right to Ask Us to Stop Using Your Personal Data

This is called the right to object. This is your right to tell us to stop using your Personal Data. You have this right where we rely on a legitimate interest of ours (or of a third party).

We will stop processing the relevant Personal Data unless: (i) we have compelling legitimate grounds for the processing that override your interests, rights, or freedoms; or (ii) we need to continue processing your Personal Data to establish, exercise, or defend a legal claim.

Right to Port or Move Your Personal Data

This is called the right to data portability. It is the right to ask for and download Personal Data about you that you have given us or that you have generated by virtue of your participation in the Recruitment Process, so that you can:

• move it;
• copy it;
• keep it for yourself; or
• transfer it to another organization.

We will provide your Personal Data in a structured, commonly used, and machine-readable format. When you make a data portability request electronically, we will provide you a copy in electronic format.

Right to Withdraw Your Consent

Where we rely on your consent as the legal basis for processing your Personal Data, you may withdraw your consent at any time. If you withdraw your consent, our use of your Personal Data before you withdraw is still lawful.

If you have given consent for your details to be shared with a third party, and wish to withdraw this consent, please also contact the relevant third party in order to change your preferences.

Right Not to be Discriminated Against for Exercising your Privacy Rights

We will not discriminate against you for exercising any of your privacy rights, meaning we will not deny you a chance to apply or re-apply for future positions at Syndigo.

Right to Lodge a Complaint with a Supervisory Authority

If the GDPR applies to the processing of your Personal Data with us, the GDPR grants you the right to lodge a complaint with a supervisory authority if you are not satisfied with how we process your Personal Data. In particular, you can lodge a complaint in the Member State of the EEA of your habitual residence, place of work, or of the alleged violation of the GDPR. You can find the details of the authorities of each member State here.

If the UK GDPR applies to our processing of your Personal Data, you have the right to lodge a complaint with the UK Information Commissioner’s Office.

If the LGPD applies to our processing of your Personal Data, the LGPD grants you the right to lodge a complaint with the ANPD if you are not satisfied with how we process your Personal Data.

Right to Opt Out of the Sale or Sharing of Your Personal Data

You have the “right to opt out”, which means you have the right to ask us to not sell or “share” (for cross-context behavioral advertising) your Personal Data at any time.

As our use of some of the cookies that we use for statistical and marketing purposes is the only type of sale or sharing of your Personal Data that Syndigo may be engaging in, the only way to opt out of sales of Personal Data is to change your cookie preferences through our cookie consent management platform. In particular, you need to choose not to allow the following categories of cookies:

• Statistics
• Marketing

Please consider that the preferences you submit through the cookie consent management platform, including your requests to opt out from the sale of personal information, may be stored in cookies or similar technologies that are specific to your browser. If this browser is configured to block cookies or similar technologies, our tool may not be able to store your preferences. In addition, deleting cookies on this browser may result in your preferences being removed. If your preferences are removed after you delete cookies from this browser, you will have to update these preferences again. Also, remember that private browsing technologies (such as incognito mode) automatically delete all local storage and cookies when the browsing session ends, preventing us from recording your choice made during the session; and prevent us from accessing any local storage created outside of the current session, which does not enable us to access the choice you made during a normal or previous private browsing session.

We’ll store your preferences only in this browser. Because some companies may not connect information about this browser with other web browsers or devices you may use (such as a web browser on another computer you may use, or one on a mobile device), you need to update your preferences through the cookie consent management platform to set your preferences separately for other browsers or devices you may use.

Your Right to Opt Into the Sale of Your Personal Data

As our use of some of the cookies that we use for statistical and marketing purposes is the only sale of your Personal Data that Syndigo may be engaging in, the only way to opt into sales of Personal Data is to change your cookie preferences through our cookie consent management platform. In particular, you need to choose to allow the following categories of cookies:

• Statistics
• Marketing

12. How Can You Exercise Your Privacy Rights?

To exercise any of the rights described above, please submit a request by either:

• Calling us at 1-877-847-5467; or
• Contacting us by email at privacy@syndigo.com (Preferred method)

13. Verification of Your Identity

Bear in mind that to evaluate your privacy rights requests, we need to be sure it was you who made the request. Consequently, we may need some information to confirm that you are who you say you are.

For requests submitted via password-protected accounts, your identity is already verified.

For requests sent by other means, you will need to provide us with sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data. Generally, we will request only information that we may have about you to confirm your identity, but under some circumstances we may require additional information or documentation to complete your request. We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request.

We will only use the Personal Data you provide us in a request to verify your identity or authority to make the request.

Please note that you may only make a consumer request to know or data portability twice within a 12-month period under the CCPA.

14. Verification of Authority

If you are submitting a request on behalf of somebody else, we will need to verify your authority to act on behalf of that individual. When contacting us, please provide us with proof that the individual gave you signed permission to submit this request, a valid power of attorney on behalf of the individual.

Alternatively, you may ask the individual to directly contact us by using the contact details above to verify their identity with us and confirm with us that they gave you permission to submit this request. We will only use the Personal Data you provide us in a request to verify your authority.

15. Response Timing and Format of Our Responses

We will confirm the receipt of your request within ten (10) days and, in that communication, we will also describe our identity verification process (if needed) and when you should expect a response, unless we have already granted or denied the request.

Please allow us up to thirty (30) days to reply to you from the day we received your request. If we need more time (up to 90 days in total), we will inform you of the reason why, and the extension period, in writing. If we cannot satisfy a request from you, we will also explain why in our response. 

We will not charge a fee for processing or responding to your requests unless we determine that your request is excessive, repetitive, or manifestly unfounded. In those cases, we will tell you why we made that determination and provide you with a cost estimate before completing your request.

16. Privacy of Children

The Recruitment Process is not directed at children under the age of 16. Children under the age of 16 will not participate in the Recruitment Process. If you believe we might have any Personal Data from or about a child under 16, please contact us by using the contact details provided here. If we learn that we have collected or received Personal Data from a child under 16 without parental consent, we will delete that Personal Data.

17. Data Integrity & Security

We are strongly committed to keeping your Personal Data safe. We have implemented and will maintain technical, administrative, and physical measures that are reasonably designed to help protect your Personal Data from unauthorized processing. Unauthorized processing includes unauthorized access, exfiltration, theft, disclosure, alteration, or destruction. In addition, we limit access to Personal Data to those employees, agents, contractors, and other third parties who have a legitimate business need for such access.  In the event your Personal Data is compromised, we will notify you in the most expedient time reasonable under the circumstances and where required by law. 

18. Contact Us

Contact us if you have any questions about this Notice or our processing of your Personal Data or want to submit a verifiable consumer request. Please write to the Syndigo privacy team by email at privacy@syndigo.com, or call at 1-877-847-5467. Please allow up to four weeks for us to reply.

European Union Representative

We have appointed VeraSafe as our representative in the EU for data protection matters. While you may also contact us, VeraSafe can be contacted on matters related to the processing of Personal Data. To contact VeraSafe, please use this contact form: https://verasafe.com/public-resources/contactdata-protection-representative or via telephone at: +420 228 881 031.

Alternatively, VeraSafe can be contacted at:

VeraSafe Ireland Ltd,
Unit 3D North Point House,
North Point Business Park New Mallow Road Cork T23AT2P
Ireland

United Kingdom Representative

We have appointed VeraSafe as our representative in the UK for data protection matters. While you may also contact us, VeraSafe can be contacted on matters related to the processing of Personal Data. To contact VeraSafe, please use this contact form: https://verasafe.com/public-resources/contactdata-protection-representative or via telephone at +44 (20) 4532 2003.

Alternatively, VeraSafe can be contacted at:

VeraSafe United Kingdom Ltd.
37 Albert Embankment
London SE1 7TL
United Kingdom

Data Protection Officer

We have appointed VeraSafe as our Data Protection Officer (“DPO”). While you may contact us directly, VeraSafe can also be contacted on matters related to the processing of Personal Data. VeraSafe’s contact details are:

VeraSafe, LLC
100 M Street S.E., Suite 600
Washington, D.C. 20003
USA

Email: experts@verasafe.com
Web: https://www.verasafe.com/about-verasafe/contact-us/

19. Changes to This Notice

If we make any material change to this Notice, we will post the revised Notice to this webpage. We will also update the “Effective” date. By continuing to participate in the Recruitment Process after we post any of these changes, you accept the modified Notice.