Candidate Privacy Notice
This Privacy Notice (“Notice”) is intended to provide candidates to any job posting (“Candidate”) published on the website https://careers.launchmetrics.com/ (“Website”) with information about how Fashion GPS Inc. (“Launchmetrics”, “we”, “us” or “Data Controller”) will process Candidate Personal Data and related information on the Website.
For the avoidance of doubt, this Privacy Notice does not form part of your contract of employment (where applicable).
Any terms in capital letter shall have the meaning attributed to it within the EU General Data Protection Regulation 2016/679 (“GDPR”), or in the California Consumer Protection Act (“CCPA”) or otherwise provided herein.
Launchmetrics will process Candidate (sourced or referred) Personal Data before, during and after the recruitment process.
Candidate Personal Data will be collected for the purposes specified in this Privacy Notice and only used accordingly. We will not collect more information than we need for the recruitment purposes described in this Privacy Notice. Candidate Personal Data will not be kept longer than is appropriate or necessary for recruitment purposes or local legal requirements. Candidate Personal Data will be collected, used and retained in accordance with your legal rights.
PURPOSE OF THE PROCESSING
The purpose of the processing of Candidates’ Personal Data is to find, hire and pre-board suitable Candidates to the Launchmetrics Group.
Provided that Candidates’ Personal Data have been anonymized, Launchmetrics may use it for statistical and diversity analysis and business reporting purposes.
LEGAL BASIS FOR THE PROCESSING
When a Candidate submits an application for a role at Launchmetrics, our legal basis for collecting, storing and processing his/her Personal Data and related information is Article 6(1)(b) of GDPR, i.e. “steps necessary to enter into a contract”. Candidates should be aware that we will store their information for a maximum of 2 years.
If Candidates sign an employment contract at the end of the recruitment process, Launchmetrics will start the pre-boarding process between the date of signing the employment contract and your first day at Launchmetrics (e.g. informing you about your office location, Launchmetrics’ ways of working, etc.). Our legal basis for collecting, storing and processing your information for the pre-boarding process is also Article 6(1)(b) of GDPR, i.e. “necessary for the performance of a contract”.
With reference to the case according to which Candidates have been approached by Launchmetrics with an invitation to apply for a role (so called “referred candidates” or “sourced candidates”), our legal basis for collecting, storing and processing your information is Article 6(1)(f) of GDPR, i.e. “legitimate business interest”. We will only process information which you have made publicly available yourself.
WHAT INFORMATION DO WE COLLECT?
We may collect and store any information you provide us when you submit an application.
The types of information Launchmetrics collects and processes in relation to Candidates may include (subject to local requirements) the following:
- Name and first name;
- Contact details, such as your address, phone, email, and other similar information;
- Resume or CV, cover letter, previous work experience, education, and transcripts;
- Desired salary, relevant work experience, type of employment sought, date available, employee referral or feedback;
- Nationality / visa / right to work permit information;
This list is not exhaustive and may be changed and/or added to from time to time. Please consider that you are under no statutory or contractual obligation to provide any information to Launchmetrics during the recruitment process. However, if you do not provide certain information, we may not be able to process your application properly or at all.
We also may obtain information about you from other sources, to the extent permitted by applicable laws, such as through your contact with us, including your interactions with members of our group, or from third parties such as employment research firms, identity verification services, and other websites on the Internet (subject to such third party’s privacy policies). For example, you may choose to provide us with access to certain personal information stored by third parties such as social media sites (e.g., LinkedIn). The information we may receive varies by each website and is controlled by the relevant website. By authorizing Launchmetrics to have access to this information, you agree that Launchmetrics may collect, store and use this information in accordance with this Privacy Notice.
Launchmetrics will also conduct background checks as a final step in the recruitment process. This background check includes processing additional information that is deemed relevant to the role that you have been offered. Your contact person at Launchmetrics will inform you about the specific contents of your background check.
The information contained in your application will be available to our People Operations Team and the recruiting manager within the Launchmetrics group on a need-to-know basis.
Launchmetrics shall only collects Personal Data falling within the scope of application of article 9 of GDPR (so called “Sensitive Data”) (i) where permitted by applicable laws and (ii) where necessary for recruitment for the role you are applying for (e.g. if the job opening is dedicated, by law, to Candidates with disabilities).
WHO MIGHT ACCESS CANDIDATES INFORMATION, AND WHERE THEY WILL BE PROCESSED?
Launchmetrics is a global group with affiliates all over the world. When a Candidate applies to a job posting providing for a specific office location corresponding to one of the Launchmetrics affiliates, the local People Operations team member of that affiliate will take care of Candidates application. For the sake of clarity, the relevant affiliate will act as data processors for the entire application process, but if and when the employment relationship will be finalized it will act as data controller.
Candidates Personal Data may also be transferred outside the country of origin of the Candidates. In this case,Launchmetrics will comply with the applicable laws regarding data transfer. In particular, Launchmetrics will comply with all the applicable provisions set forth in articles 44 and subsequent of GDPR.
As a final remark, please consider that Launchmetrics will not disclose (or sell) Candidates Personal Data with any other third parties, unless legally compelled to do so by virtue of any applicable law, court or governmental request.
HOW DO WE PROTECT YOUR INFORMATION?
Launchmetrics adopts appropriate technical, physical & organizational measures to prevent unauthorized access, accidental loss, destruction or damage to Candidate Personal Data and any unauthorized organization, disclosure or processing. Launchmetrics ensures adequate security to protect manual and electronic processing of Candidate Personal Data and prevent its misuse, subject to local legal requirements. Launchmetrics ensures adequate security is observed by third parties and affiliates processing Candidate Personal Data on behalf of Launchmetrics.
HOW LONG DO WE INTEND TO STORE CANDIDATE’S PERSONAL DATA?
We would like to keep this data until our open role is filled, and in any case for a maximum period of 2 years. When that period is over, we will either delete your data or ask your permission to keep your Personal Data in our database for future roles, for an additional 2 years.
You can send us a request to obtain access to the data that we have collected on you, request us to delete your data before the data retention period expires, correct any inaccuracies or restrict our processing of your Personal Data.
You also have the right to lodge a complaint about the way we handle your data with the appropriate supervisory authority or you can contact our DPO at email@example.com for more information or concerns.
CONTACT DETAILS TO LAUNCHMETRICS
In case of any questions or doubts regarding the present Privacy Notice, please contact Launchmetrics at the following email address: firstname.lastname@example.org.
NOTICE FOR CANDIDATES AT LAUNCHMETRICS THAT ARE CALIFORNIA RESIDENTS
This section of the Privacy Notice applies only to residents of the state of California in the US. It describes the categories of personal information Launchmetrics collects and the purposes for which Launchmetrics processes that information in accordance with section 1798.100 (b) of the CCPA.
INFORMATION WE MIGHT COLLECT
The following paragraphs describe (in general terms) which Candidates personal information Launchmetrics might collect, share and retain for the purposes of recruitment through the Website.
- Personal information, (e.g. Name, alias, postal address, prior addresses, unique personal identifiers, online identifiers, IP address, email address, account name, social security number, passport number, or other similar identifiers) that we collect directly or indirectly (e.g. from references authorized by Candidates, from public website etc. ) from Candidates;
- Characteristics of protected classifications under California or federal law (e.g. Sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), age, race, religion, national origin, disability, medical conditions and information, citizenship, immigration status and marital status; veteran or military status;
- Professional or employment-related information; and
- Education information, defined as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).
NOTICE FOR CANDIDATES AT LAUNCHMETRICS THAT ARE LOCATED IN THE PEOPLE’S REPUBLIC OF CHINA
In particular, the purpose of this section is to inform Chinese Candidates that for the purposes indicated in section “PURPOSE OF THE PROCESSING”, we might transfer Chinese Candidates’ Personal Data outside China. Provided that, we will consider to have received Chinese Candidates explicit consent to the data transfer every time that he or she will submit his/her application to a job posting published on the Website.
For the sake of clarity, Chinese Candidates’ Personal Data might be transferred among the companies affiliated to Launchmetrics, as well as to its service provider, for the purposes indicated above. We will not sell any Chinese Users Personal Data to third parties. For further information, you can contact Launchmetrics at email@example.com.
This Privacy Notice may be subject to update and change from time to time. Any changes will be published on our website. We recommend that you check this Privacy Notice regularly.
Version 1.1, last updated, August 2021