EFFECTIVE DATE: September 7, 2022
This Applicant and Candidate Privacy Policy (the “Applicant Policy”) applies to ChurnZero, Inc. and our affiliated companies (collectively, “ChurnZero” or “we” or “us” or “our”).
This policy explains:
- What information we collect during our application and recruitment process and why we collect it;
- How we use that information; and
- How to access and update that information.
This Policy does not apply to you use of our Services, Websites (other than applicant portals), or other ChurnZero products or services. Please visit our general Privacy Policy, available at https://churnzero.com/privacy/global for information regarding our services.
SUMMARY OF COLLECTION AND PROCESSING OF YOUR INFORMATION. Below is a summary of our collection of information and how we process the information you submit to us or which we obtain from other sources:
| Personal Information | Name, contact details, and employment details if you send us a CV, resumé, or other details of your employment history, qualifications, and experience in connection with an advertised job vacancy or a general inquiry regarding employment opportunities with us. |
| How and why we use it | To assess your application and communicate with you about the position. |
| Who we share it with | With our human resources information system provider (Bamboo) based on Art. 28 GDPR in connection with our data processing agreement with the respective provider and, where permitted by applicable law, our background check service providers |
| Lawful Basis | Taking steps necessary (a) prior to entering into potential employment or consultancy agreement with you, (b) to comply with our legal obligations, (c) with your consent, or (d) to meet our legitimate interests in assessing applicants for employment, including to inform you about other job openings that may be of interest to you. In the EU, we will only do the latter with your prior consent. |
| Retention | For applicants in the EU, we retain your data until the application process has been concluded and the position has been filled. For applicants in the EU and with your consent, we keep your information in case of an unsuccessful application for 6 months after the application process has been concluded in case another relevant position arises and will contact you about it. For applicants not located in the EU, this data is retained in accordance with local law. If you prefer us not to retain your information, please let us know at privacy@churnzero.com. Information on successful applicants will be used in our human resources systems and processes. |
TYPES OF INFORMATION WE COLLECT. This Policy covers the information you share with us and/or which may be acquired or produced by us during the application or recruitment process including:
- Your name, address, email address, telephone number and other contact information;
- Your resume or CV, cover letter, previous and/or relevant work experience or other experience, education, transcripts, or other information you provide to us in support of an application and/or the application and recruitment process;
- Information from interviews and phone-screenings you may have, if any;
- Details of the type of employment you are or may be looking for, current and/or desired salary and other terms relating to compensation and benefits packages, willingness to relocate, or other job preferences;
- Details of how you heard about the position you are applying for;
- Any sensitive and/or demographic information obtained during the application or recruitment process such as gender, information about your citizenship and/or nationality, medical or health information and/or your racial or ethnic origin;
- Reference information and/or information received from background checks (where applicable), including information provided by third parties;
- Information relating to any previous applications you may have made to us and/or any previous employment history with ChurnZero;
- Information about your educational and professional background from publicly available sources, including online, that we believe is relevant to your application or a potential future application (e.g., your LinkedIn profile); and/or
- Information related to any assessment you may take as part of the interview screening process.
HOW WE USE INFORMATION WE COLLECT. We use your information for the purposes of conducting our application and recruitment process which includes:
- Assessing your skills, qualifications and interests against our career opportunities;
- Verifying your information and carrying out reference checks and/or conducting background checks (where applicable) if you are offered a job;
- Communications with you about the recruitment process and/or your application(s), including, in appropriate cases, informing you of other potential career opportunities at ChurnZero;
- Creating and/or submitting reports as required under any local laws and/or regulations, where applicable;
- Where requested by you, assisting you with obtaining an immigration visa or work permit where required;
- Making improvements to our application and/or recruitment process including improving diversity in recruitment practices; and/or
- Complying with applicable laws, regulations, legal processes, or enforceable governmental requests; and/or
- Proactively conducting research about your educational and professional background and skills and contacting you if we think you would be suitable for a role with us.
We will also use your information to protect our rights and property and the rights and property of our customers, users, applicants, candidates, employees, or the public as required or permitted by law.
If you are offered and accept employment with us, the information collected during the application and recruitment process will become part of your employment record.
If European Union data protection law (e.g., GDPR) applies to the processing of your information, our legal basis for processing your information may include:
- We collect and process your information where it is necessary to take steps, at your request, prior to our potentially entering into a contract of employment with you.
- We may also seek your consent to process your personal information in specific circumstances or process it where necessary to comply with a legal obligation or for purposes connected to legal claims. If we use your information to improve our application or recruitment process, we do so on the basis that it is in our legitimate interests to ensure we recruit the best possible candidates.
WHO MAY HAVE ACCESS TO YOUR INFORMATION.
- Your information may be shared with our affiliates, subsidiaries, or joint ventures in the US, Australia, Netherlands, and in other jurisdictions, in relation to the purposes described above. If you have been referred for a job at ChurnZero by a current ChurnZero employee, with your consent, we may inform that employee about the progress of your application and let the ChurnZero employee know the outcome of the process. In certain circumstances, if it is identified that you have attended the same university/school or shared the same previous employer during the same period as a current ChurnZero employee we may consult with that employee for feedback on you.
- We may also use service providers acting on our behalf to perform certain services, including for the purposes of the verification/background checks. These service providers may be located outside the country in which you live or the country where the position you have applied for is located.
- We may sometimes be required to disclose your information to external third parties such as to local labor authorities, courts and tribunals, regulatory bodies and/or law enforcement agencies for the purpose of complying with applicable laws and regulations, or in response to legal process.
- We will also share your personal information with other third parties if we have your consent (for example if you have given us permission to contact your references), or to detect, prevent or otherwise address fraud, security or technical issues, or to protect against harm to the rights, property or safety of ChurnZero, our customers and their users, applicants, candidates, employees or the public, or as otherwise required by law.
- It is your responsibility to obtain consent from references before providing their personal information to us.
- We operate globally, which means your information may be stored and processed outside of the country or region where it was originally collected, including in the United States of America. These other countries may entitle you with fewer rights in respect of your information than your country of residence. In such cases, we transfer any information pursuant to applicable law using approved transfer mechanisms.
ChurnZero takes appropriate steps to protect information about you that is collected, processed, and stored as part of the application and recruitment process.
OUR RETENTION OF YOUR INFORMATION. If you apply for a job at ChurnZero and your application is unsuccessful, you withdraw from the process, or decline our offer, we will retain your information for a period after your application. We retain this information for several reasons, to include if we face a legal challenge in respect of a recruitment decision, consideration of you for other current or future jobs with us, and helping us better understand, analyze, and improve our recruitment processes.
If you do not want us to retain your information for consideration for other roles, or want us to update it, please contact recruiting@churnzero.com. Please note, however, that we may retain information if required by law or as necessary to protect ourselves from legal claims.
AUTOMATED DECISIONS ABOUT YOU. We may process your personal information using solely automated means to make decisions about your candidacy. This is known as “automated decision-making” and is only permitted when we have a legal basis for this type of decision-making. This may have significant effects for you, namely that you may be rejected for the role you applied for without a recruiter ever reviewing your application. Your application may be automatically rejected if you do not meet minimum job requirements, or if an open role is filled while you are in the first or review stage of the recruitment process, your application may not be considered. Our recruiters can reactivate candidates that have been rejected at a later date, if necessary.
We may make these automated decisions about you:
- Where such decisions are necessary for entering into a contract.
- Where such decisions are required or authorised by l aw.
- Where you give your explicit consent to us conducting automated decision-making.
Subject to local legal requirements and limitations, you can contact us using the details below to request further information about automated decision-making, object to our use of automated decision-making, or request an automated decision to be reviewed by a human being.
YOUR RIGHTS IN RESPECT OF YOUR INFORMATION. In certain countries, you may have certain rights under applicable data protection law, which may include the right to request access or to update your information, request that it be deleted, or object to our use for certain purposes. Please contact privacy@churnzero.com if you wish to exercise any legal right available to you regarding your information. We will respond to any requests in accordance with applicable law, and so there may be circumstances where we are not able to comply with your request (e.g., if we cannot verify your identity).
CONTACT US. If you cannot find the answer to your question in this Policy, you can contact us at privacy@churnzero.com. Also, depending on your country of residence, you may also raise any questions or concerns you have regarding your personal information with your local data protection authority.
CHANGES TO THIS POLICY. We may change this Policy from time to time. We will post any changes to this Policy on the applicant portal available at https://churnzero.com/careers/ and each version of this Policy is identified by the above Effective Date.