Introduction

JWP Connatix (the “Company”, “we”, “us”, “our”), respects the privacy and data protection rights of our job applicants.

This privacy notice (“Notice”) describes the personal information we have about you as a job applicant and your rights concerning that information. It also explains the policies and procedures we use regarding your personal information during our selection and recruitment process. 

This Notice may be amended from time to time. We will post any change to this Notice on our website a reasonable time in advance of the effective date of the change. If the changes affect the personal information about you that we already process, we will also make efforts to proactively notify you by email of the changes to the Notice.

KEY TERMS USED IN THIS NOTICE

• applicant is any job applicant for a position at Company as a temporary, full-time, or part-time employee, intern, contractor, or contingent worker.
• personal information is any information relating to an applicant.
• processor is any organization, such as a service provider, that processes personal information on behalf of the Company.
• processing is anything done with personal information such as collecting, recording, storing, organizing, altering, using, disclosing, transmitting, or deleting it.

PURPOSES OF PROCESSING AND COLLECTING YOUR PERSONAL INFORMATION

We collect and process personal information about job applicants like you for the purpose of conducting a proper recruitment process, assessing how suitable you are for the position, deciding whether to hire you and, where relevant, preparing to enter into an employment agreement with you.

In extraordinary cases, we will also use the information we collect to handle complaints and lawsuits relating to your candidacy. For example, if you or a third-party file a complaint or a lawsuit about our handling of your candidacy, or if we need to file a complaint or a lawsuit relating to your candidacy to protect our legal rights.

We also process your personal information to consider you for future openings at the Company and our corporate group affiliates, other than the specific position to which you initially apply. For example, we may contact you later if a similar position subsequently becomes available, which we believe may be relevant for you.

PERSONAL INFORMATION WE COLLECT

Your personal information as a job applicant includes your name, contact details, address, qualifications, skills, hobbies and leisure activities, employment history, experience and education history, information presented in your CV (Curriculum Vitae) or cover letter, your employment preferences, photos and links to webpages or websites you operate online.

We also collect additional information that you choose to share with us, such as your current and historic salary information and salary expectations. If you voluntarily provide us information about our gender, racial or ethnic origin, and health condition, we also will process that information.

We also collect the names and contact details of you application references, as well as information we receive through reference letters or in our discussions with those references. It is your responsibility to obtain consent from those you provide as references before you give us their contact information.

You are not under any legal obligation to provide us with your personal information. However, we will not be able to consider your application for the position without this information (with the exception of information you can voluntarily choose whether to provide us).

We also obtain information about you from other third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks.

We do not recruit or employ individuals under the age of 18. We do not knowingly collect personal information about individuals under that age.

METHODS AND SOURCES FOR COLLECTING YOUR PERSONAL INFORMATION

The Company collects the information from several sources:

• Directly from you as an applicant, through documents you provide us and interviews we conduct with you.
• Recruiters and recruitment or placement agencies
• References and past employers
• Publicly accessible sources, such as LinkedIn and Facebook, where information is publicly available.
• Employment background check and criminal record checks providers
• The Company also uses applicant screening assessment tests and questionnaires that we will ask you to complete. The information, results and assessments obtained through these tools relate to your skills, characteristics, hobbies, and leisure activities. The Company will use these to evaluate if you are suitable for the position and the Company.

DATA RETENTION AND FUTURE USE

We retain information about your candidacy for the initial period necessary for the recruitment process unless. We then retain the information for an additional period of 36 months for the purpose of considering you for other potential job opening, and in case the information is necessary to handle legal claims related to the application.

Personal information of unsuccessful applicants will be deleted within 36 months of the decision. We will retain the information of candidates we ultimately hire for as long as we employ them and for an additional period of 7 years thereafter.

SHARING YOUR PERSONAL INFORMATION

First and foremost, your information will be shared with our Human Resources and recruitment team, the manager overseeing the position to which you are applying, and at times, also other members of the team to which the position are applying to belongs.

We also will share some of your information with outside parties that we hire to provide services relating to the purposes mentioned above, such as screening and placement agencies, external advisors, and relevant service providers. These parties operate under our instructions, and we require them to implement measures to safeguard your personal information.

Because we operate our business as an affiliated group of companies, we sometimes also share your information with companies in our corporate group for the same purposes listed above.

If the operation of our business is organized within a different framework, or through another legal structure or entity (such as due to a merger or acquisition), we will share your information with the target entity of the merger, acquisition, or reorganization, and with legal counsels, and advisors. We do so for the purpose of facilitating the structural change in the operation of our business.

In the extraordinary case of complaints and lawsuits relating to your candidacy, we will also share your information with our general counsel and outside legal counsels.

If a law or binding order required us to, we will disclose your personal information to the parties required under the law or the order.

In any case, we do not sell your personal information to third parties.

INFORMATION SECURITY

We implement measures designed to secure your personal information and protect it from unauthorized disclosure, use or copying. We also require all those who have access to your personal information to implement such measures. However, although efforts are made to secure the applicant personal information, we cannot guarantee its absolute protection.

CHANGES TO THIS POLICY

The Company may change this policy. Such changes become effective when the updated policy is posted on our website. If the changes materially affect your privacy, the Company will notify you and seek your consent.

QUESTIONS

If you have any questions about this policy, the information we have about you or our processing of your personal information, please contact us by e-mail at privacy@jwpconnatix.com.

ADDITIONAL INFORMATION FOR INDIVIDUALS RESIDING IN CALIFORNIA

If you are an individual residing in California, we provide you with the following information pursuant to the California Privacy Rights Act (CPRA). This is also the information we have collected in the past 12 months.

We do not sell your personal information and have not done so in the past 12 months.

We also do not share your personal information for online behaviorally targeted ads and have not done so in the past 12 months.        

DISCLOSING YOUR INFORMATION TO THIRD PARTIES

The chart below explains about the personal information we disclosed for a business purpose to third parties in the preceding 12 months.

YOUR RIGHTS UNDER THE CPRA IF YOU ARE A RESIDENT OF CALIFORNIA

Knowing the personal information, we collect about you
You have the right to know:

• The categories of personal information we have collected about you.
• The categories of sources from which the personal information is collected.
• Our business or commercial purpose for collecting personal information.
• The categories of third parties with whom we share personal information, if any.
• The specific pieces of personal information we have collected about you.

Right to deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

• Delete your personal information from our records; and
• Direct any service providers to delete your personal information from their records.

Please note that we may not delete your personal information if it is necessary to:

• Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us.
• Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes.
• Debug to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act.
• Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the ability to complete such research, provided we have obtained your informed consent.
• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which you provided the information.

or

• Comply with an existing legal obligation.

We also will deny your request to delete if it proves impossible or involves disproportionate effort, or if another exception to the CPRA applies. We will provide you a detailed explanation that includes enough facts to give you a meaningful understanding as to why we cannot comply with the request to delete your information.

Right to correct inaccurate personal information

If we receive a verifiable request from you to correct your information and we determined the accuracy of the corrected information you provide, we will correct inaccurate personal information that we maintain about you.

In determining the accuracy of the personal information that is the subject of your request to correct, we will consider the totality of the circumstances relating to the contested personal information.

We also may require that you provide documentation if we believe it is necessary to rebut our own documentation that the personal information is accurate.

We may deny your request to correct in the following cases:

• We have a good-faith, reasonable, and documented belief that your request to correct is fraudulent or abusive.
• We determine that the contested personal information is more likely than not accurate based on the totality of the circumstances.
• Conflict with federal or state law.
• Other exception to the CPRA.
• Inadequacy in the required documentation
• Compliance proves impossible or involves disproportionate effort.

We will provide you a detailed explanation that includes enough facts to give you a meaningful understanding as to why we cannot comply with the request to correct your information

Protection against discrimination

You have the right to not be discriminated against by us because you exercised any of your rights under the CPRA.

Exercising your CPRA rights by yourself or through an authorized agent

If you would like to exercise any of your CPRA rights as described in this Notice, please contact us by e-mail at privacy@jwpconnatix.com.

We will ask you for additional information to confirm your identity and for security purposes, before disclosing the personal data requested to you, by using a two or three points of data verification process, depending on the type of information you require and the nature of your request.

You may also designate an authorized agent to make a request under the CPRA on your behalf. To do so, you need to provide the authorized agent written permission to do so and the agent will need to submit to us proof that they have been authorized by you. We will also require that you verify your own identity, as explained above.