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Amagi Recruitment Privacy Notice for Job Applicants/Candidates

1. PURPOSE OF THIS NOTICE: This privacy notice (“Notice”) is provided by Amagi Media Labs Private Limited and its affiliates (collectively “Amagi”, “we”, “us”, or “our”), relating to external job applicants and candidates for positions within Amagi (“you”, “your” or “candidate”), in accordance with our obligations under applicable data protection laws and regulations, such as but not limited to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”) and the General Data Protection Regulation, 2016 (“GDPR”) (collectively “Applicable Data Protection Law”). This Notice explains how we collect, use, process, disclose, and safeguard your personal information. We request you to review this Notice carefully. Your interaction with Amagi’s website is also governed by Amagi’s Website Privacy Policy, provided that in the event of a conflict between Amagi’s Website Privacy Policy and this Notice, this Notice shall prevail. We may provide you additional notices about our data collection practices that are covered by other laws (e.g., if we conduct a background check in California).

2. SCOPE OF THIS NOTICE: This Notice applies to the personal information that we collect from and about candidates, in the context of reviewing, assessing, considering, managing, storing or processing their applications or otherwise considering them for a position with Amagi. We may use the information you provide, in accordance with our legitimate interest, to assess your qualifications for positions within Amagi.

What is personal information? In this Notice, “personal information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household, or as otherwise defined under Applicable Data Protection Law.

What isn’t covered by this notice? This Notice does not apply to the personal information we collect from employees (which is subject to a separate privacy notice), or customers or end users of our products and services, including candidates in the context of their personal use of our products and services (which is subject to our Services Privacy Policy).

Are our practices the same for all candidates? The categories of personal information we collect and our use of personal information may vary depending on the position(s) or location, as well as the associated qualifications and responsibilities. The information in this Notice is intended to provide an overall description of our collection and use of personal information about candidates.

3. CATEGORIES OF PERSONAL INFORMATION COLLECTED:

Generally, we may collect the following categories of personal information about candidates:

Name, Contact Info and other Identifiers. Identifiers such as a real name, alias, postal address, unique personal identifier, online identifiers, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
Education and Professional Information. Education information and professional or employmentrelated history information such as qualifications, experience, information relating to a candidate’s employment history, skills and work experience.
Profiles and Inferences. Inferences drawn from personal information collected by Amagi regarding a candidate, reflecting the candidate’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes and a record of the candidate’s progress through the recruitment process that Amagi may conduct.
Audio, Video and other Electronic Data. Audio, visual and electronic information or similar information such as CCTV footage, photographs, and call recordings and other audio recordings (e.g., recorded interviews, meetings and webinars).
Protected Classifications or Sensitive Personal Data. Characteristics of protected classifications such as a candidate’s social security number, national identification number, driver’s license or passport number, racial or ethnic origin, religious or philosophical beliefs, union membership, disability, citizenship status, military/veteran status, marital status, medical condition and any other information that may fall within a ‘special category of data’.

Please note that Workable may collect usage data, consisting of Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement, as well as physical and network access logs and other network activity information, as related to the candidate’s use of any Workable’s network or other information resource. Where usage data is collected by Workable as a data controller, such processing is carried out in accordance with Workable’s Privacy Policy.

4. PURPOSES OF COLLECTION AND PROCESSING OF PERSONAL INFORMATION:

Generally, we may use the above categories of personal information for the following purposes:

 

Recruiting, Hiring and Managing, and Evaluating Applicants. To assess your job application for the role you apply for and for other roles, or otherwise manage candidates and job applications, including:

  • Verifying your employment, educational history and references.
  • For making recruitment decisions and communicating them with you.
  • To supplement any personal information provided by you with information we receive from third parties or through publicly available information.
  • To permit or vendors, including an online application provided by Workable Software Limited (“Workable”), to assist with our recruitment process.
  • To review, assess, recruit, consider or otherwise manage candidates and job applications, including: scheduling and conducting interviews, working with external recruiters, reviewing, assessing and verifying information provided, to conduct background checks (where relevant and pursuant to applicable law), and to otherwise screen or evaluate candidates' qualifications, suitability and relevant characteristics, to extend offers, negotiate the terms of offers, and assess salary and compensation matters, to satisfying legal and regulatory obligations, to communicate with candidates regarding their applications and about other similar position(s) for which they may be interested, to maintaining candidate personal information for future consideration, and to support our equal opportunity employment policy and practices.

Security and Monitoring. In order to monitor and secure our resources, network, premises and assets, including:

  • Monitoring for, preventing and investigating suspected or alleged misconduct or violations of work rules
  • Monitoring for, preventing, investigating and responding to security and privacy incidents
  • Providing and managing access to physical and technical access controls
  • Monitoring activities, access and use to ensure the security and functioning of our systems and assets
  • Securing our offices, premises and physical assets, including through the use of electronic access systems and video monitoring.
Auditing, Accounting and Corporate Governance. Relating to financial, tax and accounting audits, and audits and assessments of our business operations, security controls, financial controls, or compliance with legal obligations, and for other internal business purposes such as administration of our records retention program.
M&A and Other Business Transactions. For purposes of planning, due diligence and implementation of commercial transactions (e.g., mergers, acquisitions, asset sales or transfers, bankruptcy or reorganization or other similar business transactions).
Defending and Protecting Rights. In order to protect and defend our rights and interests and those of third parties, including to manage and respond to legal claims or disputes, and to otherwise establish, defend or protect our rights or interests, or the rights, interests, health or safety of others, including in the context of anticipated or actual litigation with third parties.

5. CATEGORIES OF THIRD PARTIES TO WHOM PERSONAL INFORMATION MAY BE DISCLOSED: We may have to share your data with third parties, including affiliates of Amagi and third-party vendors or service providers or sub-processors.

Which Amagi affiliates may process my personal information? In the case of affiliates of Amagi, regardless of the Amagi affiliate that you are applying to, your personal information may be disclosed to any Amagi affiliate, including but not limited to Amagi Corporation, Amagi Media Private Limited, Amagi Media Labs Pte Limited and Amagi Media Labs Private Limited.

Which third-party vendors or service providers process my personal information? "Third parties" includes third-party service providers (including contractors, professional advisors and designated agents). For instance, the following activities are carried out by third-party service providers: recruitment, candidate tracking, job posting platforms, market research and IT services.

What about other third parties? We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or government agency to comply with the law.

6. SOURCES OF PERSONAL INFORMATION:

We may receive your personal information indirectly from you through other sources such as professional networks where you have set up a publicly available profile, from recruiters or third parties that you have authorized to share your information with us, from third party background verification service providers, and/or from publicly available sources. Information that we receive from other sources may be combined with the personal information that you provide to us.

Workable’s technology allows us to search various databases – some publicly available and others which are not, which may include your personal information (include your curriculum vitae or resumé) to find possible candidates to fill our vacancies, and we may obtain your personal information from these sources in such event. We may receive your personal data from a third party who recommends you as a candidate for a specific job opening or for our business more generally. We may use Workable’s technology to select appropriate candidates for us to consider, based on criteria expressly identified by us, or typical in relation to the role for which you have applied.

7. AUTOMATED DECISION MAKING:

The process of finding suitable candidates through Workable is automatic, however, any decision as to who we will engage to fill the job opening will be made by our staff.

8. USE AND DISCLOSURE OF PERSONAL INFORMATION: We do not sell or share and have not sold or shared your personal information for the purpose of crosscontextual behavioural advertising, in the past 12 months.

We use Workable, as a service provider on our behalf, to process your personal information. Workable is only entitled to process your personal information in accordance with our instructions. In the event that you apply for a vacancy posted by us on Workable, these Notice provisions shall apply to our processing of your personal information.

Where you apply for a job opening via the application function on a third party job site or similar online service provider (“Partner”), you should note that the relevant Partner may retain your personal information and may also collect your information from us in respect of the progress of your application. Any use by the Partner of your information will be in accordance with the Partner’s privacy notice and policy.

If your application has been made through the ‘Indeed Apply’functionality, and you have provided your consent to this disclosure, we will disclose to Indeed certain personal information that we possess, including but not limited to a unique identifier used by Indeed to identify you, and information about your progress through our recruitment process for the applicable vacancy, as well as tangible, intangible, visual, electronic, present, or future information that we hold about you, such as your name, contact details and other information involving analysis of information relating to you as an applicant for employment (collectively “Disposition Data”). Indeed’s privacy notice in respect of Indeed’s use of the Disposition Data is available on Indeed’s website.

If your application has been made through another service provider, we may disclose information similar to the Disposition Data defined above to such service provider. The service provider’s privacy notice shall govern such service provider’s use of such data.

9. CROSS-BORDER TRANSFER OF DATA: You acknowledge that your personal information may be transferred outside of the jurisdiction in which you reside or to a jurisdiction other than the one in which the personal information was collected or stored. Amagi shall ensure that such transfers will adhere to transfer mechanisms prescribed under Applicable Data Protection Law, shall implement reasonable technical and organisational measures during transfer of the personal information, shall enter into appropriate data processing addendums with the recipients of such data to ensure that the terms of processing and the measures employed by the recipient are at least comparable to the terms set forth in this Notice and shall ensure that such transfer is necessary for the processing of information under this Notice.

10. STORAGE: We take appropriate and reasonable safety and security measures to ensure that all personal information is kept secure, including the use of security measures designed to prevent personal information from being accidentally lost or used or accessed in an unauthorized manner. We limit access to your personal information to those who have a genuine business need to know it. Those processing your personal information are obligated to do so only in an authorized manner and are subject to a duty of confidentiality.

We have instituted procedures to address any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. The transmission of information via the internet is not completely secure. Although we will use appropriate, reasonable security measures to protect your personal information, we cannot guarantee the security of your personal information transmitted through any online means, therefore any transmission remains at your own risk.

Your personal information is stored within and outside the United States and/or the European Economic Area.

When you submit personal information using Workable, your personal information may be accessible to (i) Workable’s staff anywhere in the USA, and/or (ii) may be stored by Workable’s hosting service provider on servers in the USA as well as in the European Union. A data processing addendum has been signed between Workable Software Limited and its overseas group companies, and between Workable Software Limited and each of its data processors. These data processor agreements are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information.

11. RETENTION PERIOD:

We retain your personal information in accordance with applicable law and as required for legal, regulatory, reporting and accounting purposes or for a period not exceeding 24 months.

12. INFORMATION ABOUT MINORS:

We do not intentionally collect any personal information of persons under the age of 16.

13. YOUR RIGHTS AS A CALIFORNIA RESIDENT:

a) Right to Access Personal Information: You have the right to request for a copy of the personal information that we hold about you in a structured, commonly used and machine-readable format.

b) Right to Deletion of Personal Information: You have the right to request for the deletion of your personal information in our possession.

c) Right to Correct Inaccurate Personal Information: You have the right to request us to rectify any inaccurate personal information that we have collected from you.

d) Right to Know What Personal Information is Being Collected: You may request the following information:

(i) categories of personal information collected about you;

(ii) categories of sources from which personal information has been collected;

(iii) business purpose for collecting, disclosing, selling or sharing personal information;

(iv) categories of third parties to whom your personal information is disclosed;

(v) specific details of personal information about you that we have collected.

e) Right to Opt-Out of Sale or Sharing of Your Personal Information: Although you have the right to opt-out of the sale or sharing of your personal information and sensitive personal information, we do “sell” or “share” your personal information or your sensitive personal information in a manner contemplated or defined under the CCPA, and we have not nor attempted to do so in the preceding 12 month period.

f) Right to Object or Restrict Processing: You have the right to object at any time to our continued processing of your personal information. You have the right to restrict our processing of your personal information in certain circumstances.

The aforementioned rights are subject to certain exemptions and are not absolute in nature. We may decline certain requests based on the application of Applicable Data Protection Law.

14. CONTACT INFORMATION AND EXERCISE OF RIGHTS:

We hope that we can resolve any query or concern you raise about our use of your personal information. For questions or concerns about this Notice, or to exercise your rights, please contact us at privacy@amagi.com. We may need to verify your identity and confirm your current residence to process any of your requests. You may appoint an authorized agent to exercise your rights and send requests on your behalf, subject that we may verify such agent’s identity and obtain a copy of a valid power of attorney executed between you and your authorized agent or a copy of a written permission enabling the authorized agent to represent you.

The GDPR also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of Applicable Data Protection Law occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at http://ico.org.uk/concerns/ or telephone: +44303-123-1113.