Applicant Privacy Statement
Effective as of April 2, 2019.
Purpose and Scope
This Applicant Privacy Statement (“Applicant Statement”) describes EazzyLabs, LLC, including its subsidiaries and affiliates (collectively, "EazzyLabs," "we," or "us"), privacy practices that apply to our collection, use, and disclosure of personal information from our applicants (“you” and “your”) for employment, including internship opportunities with EazzyLabs via our application portals, websites, or other recruitment channels (collectively, “Application Sites”).
For the purposes of this Applicant Statement:
- “Job Applicant” means a current or former applicant for employment with us.
- “Applicant Data” means the information we process in connection with your application and as part of the interview process.
How We Obtain Information
As further described below, we collect several types of information from and about you that broadly fall into the following categories:
Information you voluntarily provide to us as Applicant Data
- Contact information (for example, your name, home and email addresses, telephone number)
- Nationality and immigration status
- Job title
- Compensation information (for example, shares of stock and details about any entitlements to shares of stock awarded)
- Background check and drug screening information (where permitted or required by law)
- Employment contracts
- Competency assessments and education history
Information we collect from third parties
We may obtain information about you from other sources, to the extent permitted by applicable law, in connection with your application and as part of the interview process. For example, we obtain information through your contact with us from third parties such as referees, employment research firms, identity verification and background check service providers, and other websites on the Internet (subject to such third party’s privacy policies). For example, you may choose to provide us with access to certain personal information stored by third parties on professional social media sites (for example, LinkedIn).
Information we collect as you navigate through the Application Site
As you navigate through our Application Site, we may also collect certain information from you about your visit to our websites using "cookies" and other similar tracking technologies.
For further information, please consult our Cookies Policy.
How We Use Information
We may use information that we collect about you for recruitment and human resources management purposes at a global level, including:
- Carrying out and supporting human resources functions and activities, including processing and evaluating your application, assessing your eligibility to work, making hiring decisions, and managing and improving our recruiting and hiring processes
- Carrying out obligations under employment and benefits laws
- Managing workplace safety and health
- Administering employee participation in benefits, compensation, human resources, and training plans and programs
- Informing you of future employment opportunities (unless you tell us you do not want to be contacted for such purposes)
- Complying with legal obligations and internal policies
- Managing and conducting business activities, including allocating company assets and human resources; project management, records management, and compilation of audit trails or other reporting tools; managing mergers, acquisitions, sales, re‑organizations, or disposals and integration with purchaser
- Managing the online career portal and conducting background and other pre‑employment checks to the extent permitted by applicable law
If you are hired, Applicant Information may be used in connection with your employment (for example, to establish an employment record; administer employee participation in benefits and training plans and programs; or conduct onboarding activities, including granting access to internal systems).
In general, we do not require Job Applicants to provide sensitive personal information (such as information about your health, race, ethnicity, religion, or sexual orientation), but you may provide such information voluntarily at your discretion. If you agree to provide this information, it will normally be used only for the purposes of diversity monitoring and providing a suitable working environment for you (for example, if you require disability access) and will not be a factor in the hiring or selection process.
For certain roles, however, we may ask for nationality to confirm that we are in compliance with our legal obligations. This information will be viewable in the hiring process as it is required for determining eligibility.
In some countries and for some roles, we may need to conduct criminal background and drug screening checks, but only where this is required or permitted by applicable laws. If this is the case, any information we process in this regard will be treated in strictest confidence and used only for the purpose of assessing your eligibility for employment or specific job duties with us.
How We Share Information Collected
We may disclose personal information contained in Applicant Data to the following categories of recipients:
- Subsidiaries and affiliates (including those located outside of the European Union and Switzerland) in connection with identifying roles for which you may be eligible and otherwise for purposes described in this Applicant Statement.
- Service providers that perform services on our behalf, including for the uses described above. We only authorize our service providers to use or disclose Applicant Data as necessary to perform services on our behalf and only in accordance with our instructions, or to comply with legal requirements. We also require our service providers to appropriately safeguard the privacy and security of Applicant Data.
- A potential buyer (and its agents and advisors) in connection with any proposed merger, acquisition, or any form of sale or transfer of some or all of our assets (including in the event of a reorganization, dissolution or liquidation), in which case Applicant Data held by us will be among the assets transferred to the buyer or acquirer. Should a sale, merger or acquisition occur, we will use reasonable efforts to direct the transferee to use the Applicant Data in a manner consistent with this Applicant Statement.
- Any other person with your consent to the disclosure.
Legal Basis for Processing
If you are from the European Economic Area, we will normally collect personal information from you only where we have your consent to do so or where the processing is in our legitimate interests (for example, assessing your application to work at EazzyLabs) and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you. Where we collect sensitive personal information from you, we will do so normally only with your explicit consent or where we have an obligation under employment law to process such information.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided below.
We and our service providers may transfer your Applicant Data to jurisdictions other than the one in which you provided it. This Applicant Statement applies wherever your data is processed.
If you are a visitor from the European Economic Area ("EEA"), we will protect your personal information when it is transferred outside of the EEA by:
- processing it in a territory which the European Commission has determined provides an adequate level of protection for personal information;
- when your personal information is transferred to EazzyLabs, LLC in the Republic of Kenya, processing it in accordance with our Privacy Shield commitments, described above; or
- otherwise implementing appropriate safeguards to protect your personal information, including through the use of Standard Contractual Clauses adopted by the European Commission.
If you require further information about our international transfers of personal information, please contact us using the contact details provided further below.
Security and Confidentiality
We maintain appropriate technical and organizational measures to protect Applicant Data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, and access. Our employees with access to Applicant Data are required to keep that information confidential and secure.
Unless a longer retention period is required by law, we retain Applicant Data where we have an ongoing legitimate business need to do so or as long as the such data is needed to fulfill the purposes outlined in this Applicant Statement. Additionally, we may also retain Applicant Data to consider you for other job opportunities where such retention is permitted by law, unless you do not permit us to retain your Applicant Data for such purposes.
We may delete Applicant Data at any time as permitted or required by law. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it. If this is not reasonably feasible, then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Your Privacy Rights
We provide you with certain rights regarding your Applicant Data:
- If you wish to access, correct, update, or request deletion of your personal information and are not able to do so within the application tool we use, you can send an email to email@example.com. You may also contact your recruiter or human resources representative.
- Certain jurisdictions (for example, the European Economic Area), provide their residents specific privacy rights under applicable law. We will process your requests to exercise such rights, including if you object to the processing of your personal information, ask us to restrict or cease processing or request portability of your personal information, in accordance with applicable data protection laws. Subject to applicable law, you have the right to request access to and receive information about your Applicant Data, update and correct inaccuracies in the Applicant Data, and have us restrict or cease processing of such data; or to have the data erased, deleted or ported (as appropriate or as permitted by applicable law). You may send us an e‑mail at firstname.lastname@example.org or using the contact details under the “Contact Us” heading below.
- In addition, if we process your Applicant Data with your consent, you can contact us to withdraw your consent at any time.
- You have the right to complain to a data protection authority if you are unhappy about our collection and use of your personal information. For more information, please contact your local data protection authority.
We will respond to such requests in accordance with the requirements of applicable data protection laws. Please note that in order to fulfil your request, we may need you to provide certain information to verify your identity.
Changes to Our Applicant Statement
We reserve the right to update or change this Applicant Statement from time to time. If we make material changes to this Applicant Statement, we will notify Job Applicants through an appropriate online notice or other means (which may include, if we have your contact details, notification by e‑mail) and obtain your consent, if and where required by applicable law.
To ask questions or comment about this Applicant Statement and our privacy practices or if you need to update, change, or remove your information or exercise any other rights, then Job Applicants who are located outside of the European Economic Area can contact us at: email@example.com.
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