This Applicant Privacy Statement provides you with information on how GeoComply Solutions Inc., together with its subsidiaries and affiliates (“we,” “us,” “our”), processes your personal data in connection with your job application.  This statement applies solely to the processing of personal data in connection with our application, hiring, and recruitment process. For more information on how GeoComply collects, uses, discloses, and otherwise processes personal data concerning using our products, services, and websites, please review this Privacy Statement.

We may update this statement from time to time, for example, if we implement new systems or processes that involve the use of personal data. We will inform you about such updates, as required by applicable law.

1. What types of data do we process

The types of personal data we collect depend upon the nature of the employment opportunity to which you have applied or are being recruited and the location of the job. We have organized the personal data we collect into categories to make it easier for you to understand:

CATEGORY OF PERSONAL DATA	DESCRIPTION OF INFORMATION
Application Data	Personal data provided by you or the person who referred you. This includes: Contact information and personally-identifying information such as your name, email address, phone number, physical address, date of birth, and any other contact information; Data contained in your resume or CV (e.g., work experience and qualifications, the school you attended and dates of attendance, the highest level of education and degrees) and other documents related to the application or recruitment process (e.g., cover letter, academic qualifications, and transcripts); Information about the type of employment you may be interested in, including targeted compensation, benefits, and other job preferences; Publicly available information from publicly available sources relevant to the hiring process, e.g. your LinkedIn profile; and Other information provided by you in the application, hiring and recruitment process. You may volunteer your previous salary and/or financial and benefits package as part of the recruitment process, but we will not ask for this information.
Account Data	Personal data such as your username and password for our online recruitment system and/or talent management system.
Interview Data	Personal data collected from interviews and outcomes of any recruiting exercises you complete, including assessments and reasoning ability tests.
Travel Data	Personal data we process if GeoComply is arranging travel for on-site interviews or reimbursing you for applicable travel-related expenses.
Background Check Data*	Information received from internal and external references and background checks, including criminal records at the offer stage only (if applicable for the position you have applied for, and as permitted by applicable laws). The results of a background check may include personal data we do not already have about you.
Citizenship and Immigration Data	When necessary, information about your immigration status, visa requirements, and other right-to-work information (e.g., country of birth, passports, and residency permits).
Voluntary Diversity, Inclusion, and Demographic Data*	As part of our Diversity, Equity, and Inclusion program, and as permitted by applicable law in some countries, we may ask you to voluntarily provide us with demographic information such as race, ethnicity, and veteran status. This information is used for equal opportunity monitoring and as required by our legal reporting obligations. Furthermore, on a voluntary basis and as permitted by applicable law, we may also ask you to provide us with other demographic information such as age, national origin, citizenship, sex, gender identity, gender expression, sexual orientation, disability, or accommodation request. When you choose to provide any such information, we will collect it anonymously, and it will not be used in the hiring decision unless permitted by law. This information will be used to help us to evaluate and improve our diversity and inclusion efforts.
Security Data	Data such as your image and video footage captured by closed circuit television (CCTV) when you visit our locations for an interview.
Other Voluntary Personal Data	Data that you choose to voluntarily provide in connection with your application and interview or any other communications with us or data that you make publicly available such as contact information, your education and work experience information (e.g., when you share information via social media, job search and career networking sites).

*There may be instances in which the personal data you provide to us or we collect is considered “special” or “sensitive” personal data under the data protection laws of some jurisdictions.

2. Information you should not provide to us

As part of our recruitment process, your employment application containing your CV and resume generally does not require special categories of data. The following information should not be provided, unless you would like to include them in your application at your own initiative and with explicit consent for processing during our recruitment activities:

a) Race or ethnicity;

b) Political opinions;

c) Religious or philosophical beliefs;

d) Trade union membership;

e) Sexual orientation, gender identity or relationship status;

f) Criminal convictions and offences;

g) Health, including any medical condition.

If you require accommodation to be made in connection with a disability or other special needs, please let us know.

3. Purposes of processing

We are committed to the lawful processing of your personal data in accordance with data protection laws.  In most circumstances, we rely on our legitimate interests (where they are not overridden by your interests or fundamental rights and freedoms), for the performance of a contract with you (or to take steps before entering into an employment contract with you) or to comply with our legal obligations. In certain circumstances, we may rely on your consent, which may be implied (e.g., where you have volunteered information for use by us) or express (in accordance with applicable law). Where we rely on your consent as a legal basis, you may withdraw your consent at any time for any processing activities that we conduct based solely on your consent.

We have organized how we collect and use your personal data into categories in the table below for easy reference.

PURPOSE FOR PROCESSING YOUR PERSONAL DATA	CATEGORY OF PERSONAL DATA	LEGAL BASIS (WHERE REQUIRED)
For creating, operating, and managing our recruitment and talent management systems.	Application Data Account Data Account Data	Our legitimate interests, such as managing employment applications for opportunities with GeoComply.
For communicating with you during the application, hiring, and recruitment process.	Application Data Account Data Interview Data Other Voluntary Personal Data	Our legitimate interests, such as communicating with applicants and managing applications for employment opportunities with GeoComply.
For processing and assessing your application, including evaluating your qualifications, skills, and suitability for the job applied for and/or other opportunities at GeoComply.	Application Data Interview Data Other Voluntary Personal Data	Our legitimate interests, in considering candidates for current and future employment opportunities with GeoComply and ensuring we attract, recruit and hire qualified candidates. To take steps prior to entering into an employment contract with you.
For verifying your information, including through reference checks and, where applicable, background checks.	Application Data Background Check Data	To take steps prior to entering into an employment contract with you. Consent (for certain background checks in certain jurisdictions). Compliance with legal obligations (for legally required background checks in certain jurisdictions).
For booking travel for on-site interviews or reimburse for travel-related expenses, where applicable.	Travel Data	Our legitimate interests, such as providing accommodations to facilitate the interview process.
For calculating proposed salary and to assess eligibility for certain benefits.	Application Data Interview Data	To take steps before entering into an employment contract with you.
For considering you for and informing you about future job opportunities.	Application Data Account Data Interview Data	Consent (to send career-related updates and employment opportunities that match your interest)
>For preparing your employment agreement if you are offered a career with GeoComply.	Application Data Citizenship and Immigration Information	To take steps prior to entering into an employment contract with you.
For informing the referrer of the status and final outcome of your employment application (if you were referred).	Application Data	Our legitimate interests, such as to facilitate our employment referral program.
For assisting with obtaining the necessary immigration visa or work permit (if requested by you).	Application Data Citizenship and Immigration Information	Our legitimate interests, such as providing immigration support. Compliance with a legal obligation to which we are subject.
For determining your work eligibility.	Citizenship and Immigration Information	Compliance with a legal obligation to which we are subject.
For suggesting suitable opportunities for you at GeoComply (where we have identified you as a potential candidate from information that we’ve collected from public sources).	Other Voluntary Personal Data	Our legitimate interests, such as recruiting candidates for employment opportunities with GeoComply.
For complying with applicable laws, regulations, legal processes or enforceable government requests (e.g., immigration and visa laws and requirements and federal and state laws related to reasonable accommodations).	Application Data Interview Data Background Check Data Citizenship and Immigration Information Voluntary Diversity and Demographic Data	Compliance with a legal obligation to which we are subject.
For fulfilling our obligations to relevant government authorities	Données liées à la candidature Données liées à la vérification des antécédents	Compliance with a legal obligation to which we are subject.
For evaluating and improving our Diversity, Equity, and Inclusion strategy	Voluntary Diversity and Demographic Data	Consent (on a voluntary basis, except where collection is required by law) We will anonymize and aggregate this information, where possible.
For monitoring and improving our application process and our recruitment and talent community systems, including analyzing our candidate base, hiring practices or trends or identifying qualification or skills shortages	Application Data Account Data Interview Data	Our legitimate interests, such as assessing and managing applications for positions with GeoComply and reviewing and updating our application process.
For monitoring our locations using CCTV	Security Data	Our legitimate interests, such as ensuring the safety and security of our offices, employees, members and guests, investigating, detecting and preventing suspicious activity and crime at our locations, protecting our rights and the rights of others.
In responding to your inquiries and requests	Application Data Account Data
For creating and submitting reports as required by applicable law or regulation (e.g., complying with reporting requirements of the federal Equal Employment Opportunity Commission or Office of Contracting Compliance Programs or similar state agencies)	Voluntary Diversity and Demographic Data	Compliance with legal obligations to which we are subject
For establishing, defending, or exercising legal claims in an employment tribunal or any other court of law	Application Data Account Data Travel Data Interview Data Background Check Data Citizenship and Immigration Information Voluntary Diversity and Demographic Data Security Data Other Voluntary Personal Data	Our legitimate interests, such as defending any actual or potential legal claims, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes and handling complaints.

4. Transfer of your personal data

To achieve the purposes set out above, we may transfer your personal data to the following categories of recipients:

a) Within the GeoComply Group. The entity to which you are applying is part of a wider group (the “Group“), which shares management, human resources, legal, compliance, finance and audit resources. As a result, we may transfer your personal data to, or otherwise allow access to such data by other entities within the Group, which may use, transfer, and process the data for the following purposes: to maintain and improve recruitment processes; to maintain IT systems; to monitor and ensure compliance with applicable laws, policies, and procedures; to establish and defend our legal rights; and to respond to requests and legal demands from regulators and other authorities. Our Group comprises companies in several EEA and non-EEA countries, including Canada, USA, and Vietnam. To obtain a full list of our corporate entities, please contact us using the details provided below in section 9.

b) Service providers assist us in the development, performance, and management of our recruitment processes. Service providers act as our processors and process your personal data under our instructions. The data processors are subject to contractual obligations to implement appropriate technical and organizational security measures to safeguard personal data and to process the personal data only as instructed.

c) Regulators, authorities, and other third parties. As necessary for the processing purposes described above, personal data may be transferred to regulators, courts, and other authorities, independent external advisors, directors within the Group, internal compliance and investigative teams, external advisers appointed to conduct internal investigations, other service providers used by us or other members of our Group (for example, providers of online collaboration and productivity solutions, business software, cloud computing providers, legal and corporate administration services).

5. International Transfer of Personal Data

Because of the global nature of our business, we share personal data internationally with GeoComply group companies, service providers, and partners when carrying out the activities described in this Applicant Privacy Statement. Some of the recipients referred to in section (4) are located or process personal data in countries other than the country in which you are located. The level of data protection in such other countries may not be equivalent to that in your local jurisdiction. However, we only transfer your personal data if and when appropriate safeguards exist.

6. Retention periods

If your application is successful and you become an employee of GeoComply, where permitted by local law, we will transfer the personal data we collected during the application, hiring, and recruitment process to your personnel file, which you will have access to at the start of your employment.

If your application is unsuccessful (or you withdraw from the process or decline our offer), we will retain your information for a period after your application. We retain this information for various reasons, including in case we face a legal challenge regarding a recruitment decision, to consider you for other current or future jobs at GeoComply and to help us better understand, analyze and improve our application, hiring and recruitment process.

Where you have given us your consent to process certain Voluntary Diversity, Equity, Inclusion, and Demographic Data (including Equal Opportunities information), we may anonymize and aggregate this information, and store it in a form that does not personally identify you, for the purpose of monitoring and improving our application, hiring and recruitment process.

If you do not want us to retain your information for consideration for other roles, or want us to update it, please please contact us using the details provided in Section 9 below. Please note, however, that we may retain some information if required by law or as necessary to protect ourselves from legal claims.

7. Your rights in connection with your personal data

Depending on where you live, you may be able to exercise certain rights in relation to your personal data. These rights may include the right to:

a) Obtain confirmation as to whether or not your personal data is being processed by us, and where that is the case, access to such personal data (and related details);

b) Correct inaccurate personal data and have incomplete personal data completed;

c) Request erasure or deletion of your personal data;

d) Obtain restriction of our processing of your personal data or object to the processing of your personal data;

e) Receive information and the existence of Automated Decision-Making and not be subject to Automated Decision-Making;

f) Withdraw your consent at any time, to the extent we rely on your consent as the legal basis for processing your personal data (without affecting the lawfulness of the processing based on such consent before your withdrawal or processing based on reliance on a legal basis other than consent);

g) Lodge a complaint with the applicable supervisory authority in your country (or, if different, in the country where the infringement took place); and

h) Obtain additional information about the suitable safeguards and means we rely upon with regard to the international transfer of personal data, as described in Section 5 above.

You will not be discriminated against for exercising any of your rights described in this Applicant Privacy Statement. Please note that these rights may be subject to further conditions, limitations, and/or exemptions under applicable data protection and employment laws. If any of the above rights are not provided under law for your jurisdiction, we have absolute discretion in providing you with these rights.

8. Right to withdraw consent

If we seek your explicit consent to process your data for any purpose, you have the right to withdraw your consent for processing for that purpose at any time. However, please remember that withdrawing your consent will not affect the lawfulness of processing based on any consent provided before the withdrawal. To withdraw your consent, please contact us using the details in section 9.

9. Contacting us

Please address your requests or questions concerning the processing of your personal data to: privacy@geocomply.com.

10. California residents only

As required by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), please see our supplemental California privacy statement that provides certain disclosures about our handling of California residents’ personal data.

 

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