Job candidate privacy notice
Last updated: September 15, 2022
This Job Candidate Privacy Notice (“Notice”) describes what personal data we - Themis Tech Inc. d/b/a Flare and our affiliates (“Flare”, “we”, “our” or “us”) - collect and process on our job candidates and applicants (“Candidates”, “you” or “your”) with respect to our application and recruitment process, why we collect it and how we use it. It also describes how candidates may exercise their rights to such data held with us.
We strongly urge you to read this Notice and make sure that you fully understand and agree to it. If you do not agree to this Notice, please do not provide us with your personal data.
You are not legally required to provide us with any personal data, but without it we may not be able to process your application.
1. What data do we collect, how do we collect it, and how do we use it?
Throughout the application and recruitment process, you may provide us (or we may otherwise have access to) personal data about you. We may collect this data directly from you, as you provide it voluntarily through your application and candidacy review process, or from other sources such as recruitment agencies, background check services (as applicable and subject to applicable law), or your references.
Specifically, we may collect the following personal data and use it for the following purposes (and in reliance on the legal bases for processing noted next to them, as appropriate):
Name, postal address, phone number, email address, username, password, IP address, Social Security number, driver’s license number,, or other similar identifiers
Additional personal information categories
Name, signature, Social Security number, address, telephone number, driver’s license or state identification card number, education, employment, or medical information.
Protected classification characteristics
Age, ethnicity, citizenship, religion or creed, marital status, medical condition (including physical or mental disability, pregnancy), gender, sexual orientation
Internet or other similar network activity
Access history and information on your interaction with our website recorded by log files, cookies, pixels, device fingerprinting, information for authentication
Audio, electronic, visual or similar information
Professional or employment-related information
Current or past job history, employer information
Non-public education information
Education level, grades, transcripts, student financial information or student disciplinary records
Credit reports, credit scores, bank and credit card details and other financial information
Information from references and feedback from previous employers
Notes (and recordings) from interview sessions
In addition, if we wish to conduct any additional activities that may require the use of your data, we will request your specific consent in advance.
2. Where do we store our Candidates’ data?
Your personal data will be maintained, processed and stored by Flare and our Service Providers (as defined in Section 5 below) in Flare’s different offices worldwide including in Israel and the US, in the applied position’s location(s), and other jurisdictions, as necessary for the proper handling of your candidacy.
While privacy laws may vary between jurisdictions, Flare, its affiliates and Service Providers processing personal data on our behalf are each committed to protect personal data in accordance with this Notice, customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred.
3. How long will we keep your data?
We may retain Candidates’ data even after the applied position has been filled or closed. This is done (i) so we can reconsider Candidates for other positions and opportunities at Flare; (ii) so we can use your personal data as reference for future applications submitted by you; (iii) if you are hired, for additional employment and business purposes related to your work; and (iv) as reasonably necessary to comply with our legal obligations, to resolve disputes, prevent fraud and abuse, enforce our agreements or otherwise protect our legitimate interests.
4. How will we secure your data?
Flare has implemented security measures designed to protect the personal data of our candidates, including physical, procedural and electronic measures. We also regularly seek new ways and tools for further enhancing the security of our system and the integrity of the personal data that we hold. Please be aware that regardless of the measures we take and the efforts we make, we cannot and do not guarantee the absolute protection and security of any personal data stored with us.
5. Who will have access to your data?
Flare will share your personal data with several selected Service Providers, whose services and solutions complement, facilitate and enhance our own. These include any recruitment firms that have referred you to us (or vice versa), candidate evaluation centers, recruitment software providers, background check providers, web analytics, and our business, legal, compliance and financial advisors (collectively, "Service Providers"). Such Service Providers may receive or otherwise have limited access to our Candidates’ personal data, depending on each of their particular roles and purposes in facilitating and enhancing our recruitment process, and may only use it for such purposes.
Additionally, we may disclose or otherwise allow access to any Candidates’ personal data pursuant to a legal request, such as a subpoena, search warrant or court order, or in compliance with applicable laws, with or without notice to you, if we have a good faith belief that we are legally required to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud or other wrongdoing. We may also share your personal data with others, with or without notice to you, if we believe in good faith that this will help protect our rights, property or personal safety, any of our customers or employees, or any member of the general public.
Finally, we may share personal data internally within our group of companies, for the purposes described above. In addition, should Flare undergo any change in control, including by way of merger, acquisition or purchase of all or part of its assets, your personal data may be shared with the parties involved in such event.
6. Which cookies and tracking technologies do we use?
Flare uses certain monitoring and tracking technologies, such as “cookies” and other downloaded data files, including ones offered by our Service Providers. These technologies are used to maintain, provide and improve our processes and operations on an ongoing basis, and in order to provide a better experience to our website visitors and Candidates.
For example, these technologies enable us to better secure our website and services and detect abnormal behaviors, to identify technical issues, and to monitor and improve the overall performance of our services and processes.
7. How can you access your data or request to delete it?
If you wish to exercise your privacy rights under any applicable law, such as the California Consumer Privacy Act (CCPA) or other state or federal laws, such as the right to know/request access to (specific pieces of personal information collected; categories of personal information collected; categories of sources from whom the personal information was collected; purpose of collecting personal information; categories of third parties with whom we have shared personal information), to request rectification or erasure of your personal information held with Flare, or to restrict or object to such personal information’s processing (including the right to direct us not to sell your personal information to third parties now or in the future), or to obtain a copy or port such personal information, or the right to equal Services and prices (i.e. non-discrimination) – please contact us by email at email@example.com.
Please note that we may require additional information, including certain personal data, in order to authenticate and process your request. Such additional information may be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with Section 3 above. We may redact from the data which we will make available to you, any personal data related to others.
Please also note that such rights are not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal data that we hold about you. In the event that we cannot accommodate your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
8. Will this Notice be updated?
We may update this notice to reflect changes in our privacy practices. If we make any changes that we deem as "material", we will update this page prior to the change becoming effective.
What if you have any questions?
California Requirements: This policy describes the categories of personal information we may collect and the sources of such information (in Section 1 above), and our retention (Section 3) and deletion (Section 7) practices. We also included information about how we may process your information, which includes processing for “business purposes” under the California Consumer Privacy Act (CCPA). We do not sell your personal information for the intents and purposes of CCPA. We may disclose personal data with third parties or allow them to collect personal data from our Services as described above, if those third parties are authorized Service Providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such personal data, or if you integrate the services of third parties with our Services, or direct us to disclose your personal data to third parties.