Flexe, Inc. Recruiting Privacy Notice

Last Updated: December 29, 2022

Flexe, Inc. (“Flexe”, “we”, “us”, or “our”) is committed to respecting the privacy of individuals, including its candidates for employment.

This Recruiting Privacy Notice (this “Notice”) describes how Flexe collects, uses, and discloses personal information about job applicants in connection with the recruitment process and when considering such applicants for employment opportunities. For purposes of this Notice, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular job applicant or household. Personal information does not include information that does not and cannot reveal an individual’s specific identity, such as information that has been de-identified or aggregated.

We may update this Notice at any time. We may also provide you additional privacy notices regarding our collection, use or disclosure of information.

This Notice does not form part of any employment contract or contract to provide services. If you provide information to us through or in connection with another company, we are not responsible for that company’s privacy practices.

To review Flexe’s Privacy Policy addressing information that Flexe collects outside of the hiring/employment context (such as information collected about you as a consumer), please visit https://www.flexe.com/privacy-policy.

NOTICE AT COLLECTION (FOR CALIFORNIA JOB APPLICANTS) #

Below is an overview of how your personal information is collected and used. We do not sell or share your personal information (as defined in applicable privacy laws). If you are a California resident, see the California Privacy Rights section of this Privacy Policy for information about your rights pursuant to California law. We will retain your personal information for as long as is needed to carry out the purposes we’ve described, or as otherwise required by law. The criteria used to determine the applicable retention period for your personal information includes the length of time we have an ongoing relationship with you as a recruiter and whether there is a legal obligation to which we are subject that requires us to retain your personal information.

Personal Information We Collect & How We Use Your Personal Information

  • Contact Information
    • Offer of employment
    • With your Consent or at your direction
  • Applicant Information

    • Offer of employment

    • Hiring, recruitment, HR management and administration

    • Voluntary demographic survey submitted through our application system

    • Legal compliance

    • With your consent or at your direction

  • Employment and Job Preferences

    • Offer of employment

    • Hiring, recruitment, HR management and administration

    • Voluntary demographic survey submitted through our application system

    • Legal compliance

    • With your consent or at your direction

  • Protected Classifications under the Law, including ethnic origin, veteran status, disability status, etc., all of which are considered sensitive personal information.

    • Offer of employment

    • Hiring, recruitment, HR management and administers

    • Voluntary demographic survey submitted through our application system

    • Legal compliance

    • With your consent or at your direction

  • Internet, Network, and Activity Information

    • Security operations

  • Inferences

    • Offer of employment

    • Hiring, recruitment, HR management and administration

  • Any Other Information You Provide us in the Context of Job Recruiting

    • Offer of employment

    • Hiring, recruitment, HR management and administers

    • Voluntary demographic survey submitted through our application system

    • Legal compliance

    • With your consent or at your direction

COLLECTION OF PERSONAL INFORMATION #

We may collect, store, and use the following types of personal Information about job applicants (either directly or through a recruiter or a contact) for the purposes set out below:

  • Contact Information, such as your name, telephone number, email address, etc.

  • Application Information, such as your resume/CV, application cover letters, employment history, education, qualifications and skills, references, candidate assessments (including interview notes), board memberships, background check results, and outside business affiliations.

  • Employment/Job Preferences, including details of the type of employment you are or may be looking for, current and/or desired salary and other terms relating to compensation and benefits packages, willingness to relocate, or other job preferences.

  • Protected Classifications under the Law , such as information about your date of birth, ethnic origin, veteran status, disability status, etc. for equal opportunity monitoring and reporting, purely on a voluntary basis.

  • Internet, Network, and Activity Information, such as cookie and device identification (IP address) details if you conduct a job search on the Flexe website and third-party websites, including job platforms like LinkedIn and Indeed, as well as images or video footage captured by security video equipment if you visit the premises

  • Inferences, which have been drawn to reflect your preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

  • Any Other Information you Provide us in the Context of Job Recruiting in order to administer aspects of your recruitment (or employment) or to comply with legal obligations or company policies.

USE OF YOUR PERSONAL INFORMATION #

We collect, use, share, and store personal information for our and our service providers’ business purposes, which include, where applicable:

  • Offer of Employment, including as required to enter into and perform the employment contract with you. This may include conducting certain verification and background checks; making informed decisions on your recruitment and ensuring your suitability for the role or to keep you in mind for future roles; and to answer your questions.

  • Hiring, Recruitment, HR Management and Administration, including to improve our recruitment process; provide internal training and assessments, compensation or benefits planning in connection with recruitment and hiring.

  • Voluntary Demographic Survey Submitted Through Our Application System, which will only be used by our Recruiting and Human Resources teams to ensure our applicant flows help meet our goal of a diverse, equitable and inclusive workplace and better understand applicant flows. Any voluntary demographic information you submit through our application system will be kept strictly confidential. The individual(s) responsible for making the hiring decision for the role in which you have applied will not have access to your responses and any information submitted will not be used in any hiring decisions.

  • Security Operations, including detecting security incidents, debugging and repairing errors, and preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution; monitoring and controlling access to our premises and locations (including through use of CCTV).

  • Legal Compliance, in order to comply with applicable laws and to protect our legal and regulatory interests. Specifically, we may use this information in connection with responding to legal claims, compliance, regulatory, investigative and disciplinary purposes. This includes verifying that you have the right to work in the country in which you are applying for a job with Flexe.

  • With Your Consent Or At Your Direction, including marketing and recruiting communications to inform you of other positions available at Flexe if you have opted in to receive such information.

We may also use your personal information for legitimate business purposes, such as: assessing or executing mergers, acquisitions, divestitures, or business transfers; managing business tools and information technology systems, including Internet and software access; ensuring compliance with applicable regulatory and self-regulatory obligations, and detecting instances of non-compliance with Flexe policies, terms and conditions, or other agreements; managing disputes and disciplinary proceedings; procuring benefit plans; conducting workforce analyses; and contacting you or your household when needed.

SOURCES OF PERSONAL INFORMATION #

We collect your personal information from:

  • You. We collect information when you provide it to us directly offline or online, through the application and recruitment process, or direct communication with us by email, phone or other message.

  • Our Service Providers. We work with service providers who collect personal information on our behalf in order to provide services to us, including employment agencies, screening services, or other sources that supply employment verification services. We only allow our service providers to collect and use your Personal Information in connection with the services they provide us.

Third Party Sources. We may collect Personal Information about you from certain third party sources, including credit reporting agencies and/or background-check providers, former employers, financial institutions and government sources.

DISCLOSURE OF YOUR PERSONAL INFORMATION #

During the past 12 months, we have disclosed your personal information for the following business purposes.

  • All categories of personal information listed above are disclosed to Flexe employees as necessary to carry out the purposes described in this Notice, including to your potential manager (except for voluntary demographic information submitted), human resources, as well as personnel within Flexe, such as payroll, IT, legal and finance;

  • All categories of personal information listed above are disclosed to service providers that perform services on our behalf such as professional advisors, external counsel, software providers, recruiting information systems provider, IT consultants carrying out management of our IT systems; and providers that may perform services on our behalf such as providing back-end (IT and other) support services;

  • All categories of personal information listed above may be disclosed to business partners, investors, purchasers, their advisors, or our advisers in connection with a potential or actual sale or merger with another business; and

  • All categories of personal information listed above may be disclosed to government authorities and/or regulatory or law enforcement officials if mandated by law or required to protect the rights and safety of our system, its users or other third parties, in compliance with applicable laws.

YOUR CALIFORNIA PRIVACY RIGHTS #

The California Consumer Privacy Act or “CCPA” (California Civil Code Section 1798.100 et seq) gives Personnel who are California residents the right to receive notice of the following information with respect to our collection of personal information:

  • Access. You have the right to request that we disclose to you the categories of personal information collected about you, the categories of sources from which the personal information is collected, the categories of personal information sold or disclosed, the business or commercial purpose for collecting and selling the personal information, the categories of third parties with whom we share the personal information, and the specific pieces of personal information collected about you.

  • Correction. You have the right to request that Flexe correct inaccurate personal information collected from you, subject to certain exceptions allowed under applicable law. If we determine, based on the totality of the circumstances, that the information is not accurate, we will respond to the request by correcting the information or deleting the information (if deletion of the information does not negatively impact you). You have the option to submit a 250-word written statement per alleged inaccurate piece of personal information if it is considered health information or is concerning your health and if you request, this statement will be made a part of your consumer record with us.

  • Deletion. You can request that we delete your personal information that we maintain about you, subject to certain exceptions.

  • Sensitive Personal Information. You also have the right to limit the use of your Sensitive Personal Information to those uses that are necessary to perform the services reasonably expected by an average person and to certain other permitted business purposes. These business purposes include helping to perform services reasonably expected by users of this Site who have requested such services, ensure security and integrity (to the extent the use of the information is reasonably necessary and proportionate for these purposes), ensure physical safety of natural persons (to the extent the use of the information is reasonably necessary and proportionate for these purposes), short-term, transient use (subject to certain conditions), performing certain services, and engaging in certain activities related to quality or safety of our services or products. We do not use or disclose Sensitive Personal Information for purposes other than permitted business purposes such as those described above.

  • No Discrimination. You have the right not to be discriminated against for exercising these rights.

  • Appeals. You have a right to appeal decisions concerning your ability to exercise your consumer rights.

Submitting your Requests

We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain personal information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests. Employment-related information will not be included in fulfillment of your requests.

We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the personal information and whether you have an account with us.

You may designate an authorized agent to make a request on your behalf. When submitting the request, please ensure the authorized agent identifies himself/herself/itself as an authorized agent and can show written permission from you to represent you. We may contact you directly to confirm that you have authorized the agent to act on your behalf and confirm your identity.

You may exercise the above rights by emailing us at privacy@flexe.com.

SECURITY #

The security of your personal information is important to us. Please be aware that despite our best efforts, no data security measures can guarantee 100% security. While we strive to protect information transmitted on or through our website, we cannot and do not guarantee the security of any information you transmit on or through this website.

LINKS TO OTHER WEBSITES #

If you click on a link to a third party site, you will be taken to a website we do not control. This Policy does not apply to the privacy practices of that website, which may collect information from you. Read the privacy policy of other websites carefully. We are not responsible for these third party websites or their policies.

CHILDREN #

We do not hire children under the age of 18. We do not knowingly collect information from children under the age of 16.

CHANGES TO THIS PRIVACY NOTICE #

Any changes we make to this Notice will be posted on this page. Please check back frequently to see any updates or changes. If we change this Notice in a material way, we will notify you.

CONTACT INFORMATION #

If you have any questions about this Notice, please contact us at privacy@flexe.com.