Introduction
We are committed to complying with applicable data protection laws. This Applicant Privacy Policy (“Policy”) explains how ClearMash Solutions Ltd. (“ClearMash” or “we”, “us”, “our”) collects and uses your personal information when you apply for a role with us, or write to us about working at ClearMash.
ClearMash Solutions Ltd. is the entity that hires for the roles we advertise, and the controller of the personal information described in this Policy.
Contact Us
If you have any questions, comments or concerns regarding this Policy or our processing of your personal information, please email us at legal@clearmash.com. You can also contact our Data Protection Officer at dpo@clearmash.com.
What We Collect and Why
When you apply for a role, or write to us about working at ClearMash, we collect and process:
- Your name, your email address and any other contact details you give us, and the subject and content of your message.
- Your CV, and any other document or information you choose to include.
- The information you give us during the application and interview process.
- If you ask us for a reasonable accommodation, the information you give us about what you need.
We use this information to consider your application, to contact you about it and arrange interviews, and to respond to any request you make for a reasonable accommodation.
Please use discretion when deciding which information to include in your application. You do not have a legal obligation to provide us with this information; however, if you choose not to share it with us, we may not be able to consider your application.
Automated Screening
We may screen applications with automated tools, which may include artificial intelligence (AI). Where your application is screened this way, you have the right to ask for a person to review the outcome, to give us your point of view on it, and to contest it.
Sharing Your Personal Information
We share your personal information with third parties only in the events listed below, or when you provide us your explicit and informed consent:
- With our service providers, who assist us with the internal operations of our business. They are authorized to use your personal information only as necessary to provide these services to us, and not for their own promotional purposes.
- With competent authorities, legal counsels, and advisors, if you violate any applicable law while engaging with us.
- With competent authorities, if a judicial, governmental, or regulatory authority requires us to disclose your information.
- With the target entity of a merger or acquisition, legal counsels, and advisors, if our business is organized within a different framework, or through another legal structure or entity.
International Data Transfers
We may transfer, store, and process your personal information in countries other than your own, and the third parties with whom we share it may be located outside your jurisdiction.
Where a country to which we transfer your personal information provides a level of data protection that does not meet the level provided by your country, we take the appropriate safeguards required by applicable law to ensure that your personal information remains protected, including standard contractual clauses or any other lawful transfer mechanism recognized by applicable data protection legislation.
If you are in the EEA or the UK, any transfer of your personal information to or within countries outside the EU or the UK is made under an adequacy decision, or under the terms of a data transfer agreement which contains standard data protection contractual clauses with adequate safeguards determined by the European Commission and the UK Information Commissioner’s Office.
Data Retention
We retain your personal information for two years from the end of the recruitment process. We may retain it for longer where it is required to comply with our legal obligations, resolve disputes, and establish and defend legal claims.
Data Security
We implement measures to reduce the risks of damage, loss of information, and unauthorized access to or use of your personal information. These measures do not provide absolute information security.
Your Rights
You have the right to review the personal information we hold about you, either yourself or through an authorized representative, and to ask us to correct it if it is incorrect, incomplete, or outdated. You also have the right to have your personal information deleted, under certain circumstances, such as when it is no longer necessary for the purposes for which it was collected.
To exercise any of your rights, email us at legal@clearmash.com. When you contact us with a request, we may ask for reasonable evidence to verify your identity before we provide you with information. If we are not able to provide you with the information you have asked for, we will explain the reason.
Individuals in the EEA and UK
Legal Basis for Processing
We process your personal information as its controller based on the following legal bases:
| Purpose or Scenario | Legal Basis |
|---|---|
| Considering and screening your application, and contacting and interviewing you | Steps taken at your request before entering into a contract with you. |
| Responding to a request you make for a reasonable accommodation | Compliance with our legal obligations as an employer. |
| Complying with a binding request from a competent authority | Compliance with our legal obligations. |
| Keeping a record of your application until the retention period ends | Our legitimate interest in keeping proper records of our recruitment, and in establishing and defending legal claims. |
| Responding to, handling, and mitigating suspected violations of law in connection with our business | Our legitimate interest in defending and enforcing against violations and breaches that are harmful to our business. |
| Enabling a structural change in the operation of our business | Our legitimate interest in our business continuity. |
| Sharing your personal information in an event not listed here | Your consent. |
Your Rights in the EEA and UK
If you are in the EEA or the UK, you also have the following rights:
- Right to Access and receive a copy of your personal information that we process.
- Right to Rectify inaccurate personal information we have concerning you and to have incomplete personal information completed.
- Right to Data Portability, that is, to receive the personal information that you provided to us in a structured, commonly used, and machine-readable format, and to transmit it to another person or entity.
- Right to withdraw your consent, easily and at any time, where the basis for our processing is your consent. Withdrawing your consent will not affect the lawfulness of the processing we carried out based on your consent before its withdrawal.
- Right to Object to our processing of your personal information based on our legitimate interest. We may override the objection if we demonstrate compelling legitimate grounds, or if we need to process the personal information for the establishment, exercise, or defense of legal claims.
- Right to Restrict us from processing your personal information (except for storing it): while we check its accuracy, if you contest it; if the processing is unlawful and you prefer restriction to deletion; if we no longer need it but you require it to establish, exercise or defend legal claims; or while we determine whether our legitimate grounds override yours, if you object to our processing.
- Right to be Forgotten, under certain circumstances, such as when you object to our processing of your personal information based on our legitimate interest and there are no overriding legitimate grounds for the processing. We may still process your personal information where it is necessary to comply with our legal obligations, or for the establishment, exercise, or defense of legal claims.
Lodging a Complaint
Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. If you are in the EU, then according to Article 77 of the GDPR, you can lodge a complaint with the supervisory authority in the Member State of your residence, place of work, or place of an alleged infringement of the GDPR. For a list of supervisory authorities in the EU, see the European Data Protection Board’s list of members. If you are in the UK, you can lodge a complaint with the Information Commissioner’s Office (ICO) through the ICO’s complaint page.
Individuals in the United States
We do not sell your personal information to any third party, or share it for cross-context behavioral advertising.
You may appoint an authorized agent to make a request on your behalf. To do so, you must provide your authorized agent with written approval, and the authorized agent will have to present us with proof that you authorized them to act on your behalf. We will also require verification of your identity.
You have the right not to be discriminated against by us for exercising the rights granted to you under applicable law.
You may appeal our decision to deny your request by submitting a written appeal to us at legal@clearmash.com.
Changes to This Policy
This Policy may be amended from time to time. We will post any change to this Policy on our website a reasonable time in advance of the effective date of the change, and we will also make efforts to proactively notify you of the changes if we have your email address.