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This Candidates Privacy Notice (“Notice”) describes how Frontegg Ltd., and its affiliates companies and subsidiaries (collectively “Frontegg”, “we” or “us”) collects and processes your Personal Data (as defined below) when you apply for a position at Frontegg (whether for an employee, worker or contractor position, and collectively “Candidates”, “you” or “your”) upon submission of your application, throughout the recruitment process, and thereafter.
This Notice applies to Candidates in the territory in which we offer job opportunities and is subject to applicable data protection laws that applies to Frontegg when processing your Personal Data.
This Notice provides you with information about the Personal Data we collect, how your Personal Data will be used, how long we will retain it, with whom we share it, our cross-border data transfer practices, and your rights regarding your Personal Data we process. This Notice further includes or incorporates specific information required under applicable data protection laws for residents of certain jurisdictions, among others, if you are a located in the EEA or UK – this Notice further details our lawful basis for processing Personal Data, as well as additional information we are required to disclose to you under the EU and the UK General Data Protection Regulations (“GDPR”). If you are a California resident – please see Section 10 of this Notice – “Additional Information for California Residents” for information required to be disclosed under the California Privacy Rights Act 2018 as amended by the California Privacy Rights Act (“CCPA”) including your rights under the CCPA.
Please note that, the information provided in this Notice is an integral part of Frontegg Privacy Policy governing the use of Frontegg’s website (in the event your application is submitted from the website), and supplements the information provided therein. In addition, if following the recruitment process you are engaged with Frontegg, your Personal Data collected through the course of the recruitment process will be subject to our internal privacy policies, as provided to our employees and staff members.
YOU ACKNOWLEDGE THAT YOU ARE NOT UNDER ANY STATUTORY OBLIGATION TO PROVIDE FRONTEGG WITH PERSONAL DATA AND ANY PERSONAL DATA YOU PROVIDE WHEN YOU SUBMIT THE APPLICATION AND THROUGHOUT THE RECRUITMENT PROCESS IS PROVIDED AT YOUR FREE WILL AND CONSENT (WHERE YOUR CONSENT IS REQUIRED UNDER APPLICABLE DATA PROTECTION LAWS). Without derogating from the above, you should be advised that we must collect or receive some Personal Data to examine your application (initially or in later stages), and if you will not provide us with the required Personal Data, we will not be able to fulfill certain purposes, for example, we will not be able to examine your application if we are not provided with the information needed to decide whether you qualify for a certain position, decide if you are legally entitled to work in certain territories, etc., all as described under Section 3 of this Notice – “Categories Of Personal Data We Collect, Purpose For Collection And Use & Lawful Basis” which details the purposes for which we need and use each type of Personal Data collected.
It is important that you read this Notice, together with any other notices that might be provided on specific occasions when we are collecting Personal Data about you, so that you are aware of how and why we are collecting and using such Personal Data.
For any questions or concerns you might have regarding our collection or use of your Personal Data please contact us as set forth in the Data Controller Information & Contact Information paragraph below.
In accordance with applicable data protection laws, Frontegg acts as the “data controller” (or the “business” under the CCPA) with respect to the Personal Data collected from Candidates. This means that Frontegg, together with the relevant entity within its company group, determines the purposes and means of processing your Personal Data (as described in this Notice) and is responsible for facilitating the exercise of your data protection rights.
For any question, inquiry or concern you might have regarding this Notice or our processing of your Personal Data, you may contact us as follows:
By Email: privacy@frontegg.comBy Mail: Frontegg Ltd., Jabotinsky St. 7, Ramat Gan, Israel
For the purpose of this Notice, the term “Personal Data” refers to information that can identify an individual, either directly or through reasonable effort (which can be further defined under data protection laws as “personal information”, “personally identifying information”, etc.). Personal Data may further include types of information defined under applicable data protection laws as “Sensitive Data” which may include, depending on the applicable law, information such as governmental identification number or certificate, professional qualifications, financial information, personality assessments, and health related information, etc. (and can be further defined under applicable data protection law as “highly sensitive information”, “special categories of personal data”, “sensitive personal information”, etc.).
Frontegg collects, stores, and processes various types and categories of Personal Data about Candidates, which may include Sensitive Data. The table below provides an overview of the categories of Personal Data collected and processed by Frontegg, the purposes for which each category is used, and, where applicable, the lawful basis for processing (such as under the GDPR).
Please note that the specific categories or types of Personal Data collected may vary depending on the position you apply for and the requirements of applicable data protection laws
Frontegg will not process your Personal Data to perform automated decision-making.
Personal Data about Candidates is collected, as follows:
Frontegg discloses your Personal Data internally with personnel involved in the recruiting and hiring processes (i.e., human resources, managers, and our company group) or externally with our third-party contractors, consultants and service providers that help us with our recruitment process operation, administration and performance, and where needed to comply with our legal obligations or to exercise and defend our rights. We implement measures to ensure your Personal Data will be accessed on a “need to know” basis and in accordance with our instructions.
The table below outlines the categories of such third-parties we share Personal Data with and purpose of sharing.
This will include information shared with third party involve in a corporate event such as a merger, acquisition or purchase of all or part of our assets.
The categories of Personal Data that will be shared can include any of the types of Personal Data detailed under this Notice, as needed to fulfill such purposes.
The categories of Personal Data that will be shared will be as requested by you.
The categories of Personal Data that will be shared can include any of the types of Personal Data detailed under this Notice, as needed to fulfill such purposes however solely to the extent necessary to comply with such purpose.
We take great care in implementing and maintaining the security of your Personal Data. We employ industry standard procedures and policies to ensure the confidentiality of Personal Data and prevent unauthorized disclosure or use of any such. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have the “need to know”. They will only process your Personal Data on our instructions. We have implemented technical, physical and administrative security measures to protect the Personal Data we collect and store, including procedures to detect and manage suspected or actual security breach.
Although we take reasonable steps to safeguard information, to the maximum extent permitted under applicable laws, we cannot be responsible for the acts of those who gain unauthorized access or abuse our systems and network, and will not always be able to prevent such access.
Please contact us at: privacy@frontegg.com if you feel that your privacy was not dealt with properly, or if you become aware of a third party’s attempt to gain unauthorized access to any of your Personal Data. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.
We retain Personal Data we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws.
The criteria according to which we determine the retention periods are as follows:
In addition to the above, we may retain limited Personal Data as a reference for any future applications submitted. If you are hired, we will store your Personal Data collected through the recruitment process in accordance with our practices and policies related to our employees and staff members’ Personal Data.
Please note that except as required by applicable law, we will not be obligated to retain your Personal Data for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice if our intention to do so.
Due to our global operation, your Personal Data may need to be processed or accessed in countries other than your jurisdiction, including, for example, when shared or accessed by our service providers or other affiliates. This may include transfer of Personal Data to or from the State of Israel, the US, UK and the EEA.
Panaya only transfers Personal Data to another country, including within its company group, in accordance with applicable data protection laws. We take appropriate measures to ensure that your Personal Data receives an adequate level of protection, including by using contractual obligations or other data transfer mechanisms that were per-approved by applicable data protection authorities to ensure your Personal Data is protected. Where your consent is required under applicable data protection laws for the transfer of your Personal Data, by submitting your application you are deemed to have consented to the transfer of your Personal Data, as described herein
We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what Personal Data we collect so that you can make meaningful choices about how it is used. We allow you to exercise certain choices, rights, and controls in connection with your information. Depending on your jurisdiction and the applicable data protection laws that apply to you, these rights may include one or more of the following principal rights:
If you wish to exercise your rights, directly or through an agent, please contact us at: privacy@frontegg.com.
We sometimes need to request specific information from you to help us confirm your identity and ensure the requested rights apply to you. This is another appropriate security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. Information provided in connection with such request will be processed only for the purpose of processing and responding to your request, and it may be shared with our legal and administrative teams.
The below provides further information and disclosures required under the CCPA with regards to our data collection and privacy practices of Candidates’ “personal information”, in Frontegg’s capacity as the “business”. This section is an integral part of this Notice and supplements the information provided under the Notice
This Notice provides comprehensive information regarding the Personal Data we collect and process.
In the table below we further provide details regarding the categories of “personal information” collected as defined and listed under the CCPA (and that we have collected in the previous 12 months).
Please note that under the CCPA, personal information does not include: publicly available information that is lawfully made available from government records, that a consumer has otherwise made available to the public; de-identified or aggregated consumer information; information excluded from the CCPA’s scope, such as: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 and the California Confidentiality of Medical Information Act or clinical trial data; personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act or California Financial Information Privacy Act and the Driver’s Privacy Protection Act of 1994.
The source from which we obtain personal information is mainly from you (i.e., you directly provide it to us), or third parties (for example a previous employer you have provided as reference) – and as further described under Section 4 of this Notice – “How Do We Collect Personal Data?”. The purpose for which we collect personal information is mainly to manage the recruitment process and asses your application for decisions making, as well as, to comply with applicable laws and defend our rights – as described under Section 3 of this Notice – “Categories Of Personal Data We Collect, Purpose For Collection And Use & Lawful Basis”. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing notice and where required, obtain your consent.
We may disclose your personal information for a business purpose, and mainly with relevant third parties who support our recruiting processes or to comply with legal obligations and exercise and defend our rights. The categories of such third-party recipients with whom we share personal information are as described under Section 5 of this Notice – “Who May Have Access To Your Personal Data” and includes: Frontegg company group, to allow us to manage our recruitment process as a business at the organizational level; Service providers and contractors, to perform certain services and functions requested on our behalf, for example, service providers and vendors related to recruitment, talent acquisition and administration, technology services, background checks, where allowed by applicable law, etc.
The categories of personal information we disclose, include any of the categories detailed under the table above (A, B, C, H, I and L) – as needed to fulfill the purposes. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to keep that personal information confidential and not use it for any purpose except performing the contract.
We do not “sell” your personal information to any third party nor “share” it, as defined under the CCPA, meaning, we do not disclose or share your personal information in exchange for monetary or some other form of consideration.
The retention periods are determined according to the criteria explained under Section 7 of this Notice – “Retention of Personal Data”, and mainly for as long as it necessary in order to achieve the purpose for which it was initially collected; to comply with our regulatory obligations and to resolve a claim or a dispute with you.
Please see Section 9 of this Notice – “Your Rights Regarding Your Personal Data & How Can You Exercise Them” which details your principal rights as for your personal information, including under the CCPA and how you may exercise them. In addition to those rights, under the CCPA you further have the right to: limit the use or disclosure of your “sensitive personal information” and not to be discriminated against for exercising your rights.
You can designate an authorized agent to submit requests to exercise rights on your behalf. However, we will require written proof of the agent’s permission to do so or to verify your identity directly.
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 e ective. We recommend you review this Notice periodically to ensure that you understand ourff privacy practices and to check for any amendments.
