Kenshoo Ltd. d/b/a Skai Recruitment Privacy Policy

Last updated: 14th August 2023

About this Policy

We, at Kenshoo d/b/a Skai (“Company”), put great efforts in making sure that we secure your personal information and use it properly. This policy explains our privacy practices and how we handle your personal information when you apply for a job with Company. Specifically, this policy will provide details about:

what personal information needs to be submitted by job applicants (“Candidates”);
what we do with that information and how we process it; and
the rights that you as a Candidate have in connection with the personal information and job application materials that you submit during the process, as applicable in your jurisdiction.

Personal information means any information relating to an identified or identifiable natural person.

Please take the time to read this policy and the general Company Privacy Policy, and do not hesitate to contact us if you have any questions about the job application process, your privacy rights, or our privacy policy in general. You can contact Company’s Privacy Officer at: privacy@clearskai.com.

Purposes for Collecting and Processing Your Personal Information

We collect your personal information for recruiting purposes – so that we could assess your candidacy and suitability for a job with Company, whether it is the position that you applied for, or other vacant positions, to be in contact with you during the recruitment process and to prepare to offer you an employment contract if we decide to hire you.

We may also use your personal information for Company’s human resources’ management in general –

to maintain Company’s HR record keeping;
to perform analysis and obtain insights about the recruitment process carried out by the Company;
to comply with diversity, inclusion and other legal requirements and to protect Company’s legal rights;
to combine your personal information with information such as criminal background checks (where permitted by law) that Company receives from third party service providers; and
when Company believes in good-faith that using your personal information is necessary to protect the life, health, safety or other vital interest of Company or any other person.

Personal Information That We Collect

When you apply for a job at Company, we will ask you to provide certain personal information that will help us evaluate your qualifications and candidacy and to stay in touch with you during the application and recruitment process. Where permitted by law, we will collect the following information:

Personal information connected to the identification of a Candidate such as: first name, surname, title, date of birth, place of birth;
Contact information such as: address (street, zip code, country), phone number, email address;
Eligibility information such as: resume/CV, cover letter, employment history (employers, job titles, length of employment) and educational background and training, linguistic capabilities, seniority, job skills, personal interests and your portfolio if relevant;
Reference materials and documents such as: job references and letters of recommendation, job salary/payment history, military records, titles and licenses, immigration visa status, security clearance;
background checks including criminal history, where permitted by law;
Social media information such as your LinkedIn Profile;
Information that you provide us about your work and personality traits such as answers during an interview, or answers to essay questions, or information about your salary expectations and work preferences;
Tests and assignments – we may ask you to pass exams, tests or perform assignments in order for us to assess your professional capabilities. In this context, we will collect the answers you will provide as part of these tests and assignments, the scores that you will receive and the insights that our representatives will gain, as a result of the examination of your performance in the tests or assignments, and particular matters that arose during such tests or assignments.

When you visit our ‘Careers’ page on our Site, or view job positions, or click on the Apply button for specific positions, we and our third party service providers, collect information such as the IP address of your device, which provides your device location, and other non-identifiable information that is used for analytical purposes, such as the type of browser, browser language, type of operating system, domain name of Internet service provider, web pages visited, times and dates of visits and the content you access on and/or through the Site.

How we Collect your Personal Information

If you use our online application system to apply for a job with Company, our HR platform service provider will collect your personal information on our behalf. Comeet is our third-party service provider that handles our job recruitment process (see further information in the Sharing Personal Information section below.)
We also collect your personal information when you apply for a job position through our Site.
Third party recruiting firms and websites such as Glassdoor.
With your permission, we may contact your job references and ask them to provide a reference about you.
We may also gather information about you through social media pages, such as from your LinkedIn Profile.
In addition to the information that you provide us with when you submit your candidacy for a position in the Company, we also record the information that you shall provide or that we shall gather throughout the process of examination of your candidacy.

Legal Basis for Processing Your Personal Information

Our legal basis for processing personal information collected about you in the EEA/EU is based on the following:

Processing your personal information is a legitimate interest of Company as it is necessary for us to fulfill our hiring and employment needs, for us to evaluate the qualifications and backgrounds of Candidates, and to communicate with you throughout the recruitment process.
Processing your personal information is necessary for our compliance with legal obligations such as complying with immigration and employment laws and regulations.
Processing your personal information is necessary in order to take steps at your request prior to entering into an employment contract with you.
In certain circumstances, the processing of your personal information will be based on the receipt of your consent to processing your personal information. In such a case, you can withdraw your consent at any time with future effect (although this may have an effect on our ability to consider your job application) by sending a notice free of charge to the following email address: privacy@clearskai.com.

Withdrawing consent will not affect the lawfulness of any processing we conducted prior to the withdrawal and will have no effect on mandatory processing of your information under applicable law.

Your Choice

Applying for a job and submitting your job candidacy materials is voluntary and at any time, if you have already applied for a job and would like to withdraw your job candidacy, you can contact us and request that we stop considering your application and that we delete your profile and any materials we collected.

Our deletion of your personal information and job application materials will be completed in accordance with our Retention policy as described below in this policy.

If you were required to provide explicit consent before submitting your job application materials and personal information, you can revoke your consent at any time. You can exercise your choice by contacting us at:
privacy@clearskai.com.

Yes, we use Cookies.

Cookies are small packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Company uses Session Cookies for legitimate purposes, such as facilitation of the use of our Site and its features and tools. Your device removes session cookies when you close your browser session.

We also allow third parties, such as Google analytics and social media websites to place cookies on your device. These are persistent cookies. A persistent cookie has an expiry date. It remains on your device until it is expired or removed. You can find the information about how Google collects and processes data at “How Google uses data when you use our partners’ sites or apps”, located at www.google.com/policies/privacy/partners/.

Part of our online recruiting process are performed and hosted by third party service providers. When you access their sites, they may place cookies or other tracking means on your device, consistent with our general privacy policy, which is available at: https://clearskai.com/privacy-policy/.

For further information about Cookies please see our Cookies and Tracking Technologies Policy at: https://clearskai.com/cookies-policy/.

Accessing Your Personal Information

If you are entitled to exercise the rights of access, rectification and deletion of inaccurate data (collectively: the right of access), you can contact us at: privacy@clearskai.com and request to access the personal information that we keep about you.

We will ask you to provide us certain information about you to make sure that you are who you claim to be and will make good-faith efforts to locate your personal information that you request to access, delete or correct.

In responding to your request, we will apply limitations available under applicable law, for example to protect our trade secrets and confidential information and to protect the privacy of others.

To the extent that you are entitled to a right of access under the applicable law, you can receive a copy of your personal information that we hold about you and request the correction, amendment or deletion of your personal information if it is inaccurate or if you believe that the processing of your personal information is in violation of applicable law.

We will use judgement and due care to redact from the data which we will make available to you, personal information related to others.

Your Additional Rights as a Candidate in the EU/EAA

If you are a Candidate in the EU/EEA, you have the additional following rights subject to the exceptions under any applicable law:

Right to Erasure – You have the right to request that we erase some or all of your personal information.
Right to restriction of processing – You have the right to request that we restrict or limit processing of your personal information.
Right to object – You have the right to object to our processing of your personal information.
Right to data portability – You have the right to have your personal information transmitted to another controller.
Right not to be Subject to a Decision Based Solely on Automated Processing – We may use our service providers’ automated platforms to identify appropriate Candidates and process their personal information. However, all the decision-making process carried out by the Company as part of the recruitment process is made by our HR staff.
Right to file a complaint – You have a right to lodge a complaint with a data protection supervisory authority of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

Please contact us if you wish to make a request to exercise your rights or if you have a question about your rights; You can contact us at: privacy@clearskai.com.

If you would like further additional information about your rights in association with your personal information or if you believe that we are misusing or have misused your personal information, please contact your local data protection authority. Here is a link to the contact details of EU data protection authorities: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

Specific Provisions for California Residents

If you are a California resident, the following terms also apply to our processing of your personal information, as defined under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) (the “Californian Privacy Laws”):

In the preceding twelve (12) months we have collected the following categories of personal information:

Identifiers and personal information categories listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e)), as described in the “Personal Information That We Collect” section in this policy.
Biometric information, such as photos and voice records, based on your interaction with us during the recruitment process.
Internet activity information, as described in the “Personal Information That We Collect” section in this policy.
Professional or employment-related information and educational information, as described in the “Personal Information That We Collect” section in this policy.
Inferences drawn from the collected personal information listed above.

We obtain the categories of personal information listed above from the following categories of sources:

Directly from you and as part of your use of our online application system, through the use of our Site or oral interviews.
Indirectly from you when contacting your job references or from publicly available sources, such as LinkedIn®.
Third party service providers, as described in “How we Collect your Personal Information” section in this policy.

We use the personal information that we collect or receive for the businesses purposes as described under the “Purposes for Collecting and Processing Your Personal Information” section in this policy.

We disclose personal information to third parties for business purposes as described under the “Sharing and Transferring Your Personal Information” section in this policy. In the preceding twelve (12) months, we have disclosed all the categories of personal information as listed above for business purposes.

Among the types of personal information that the Company collects from Candidates as detailed in this Privacy Policy, the following types are considered “sensitive personal information” by virtue of the Californian Privacy Laws: racial or ethnic origin and disability. Although such types of data are not collected directly, they can be reasonably inferred from certain personal information that the Company collects from Candidates.

In the preceding twelve (12) months, we have not sold personal information.

If You are a resident of California or certain US states (e.g. Virginia, Colorado), you may be entitled to the following rights:

Right	Scope
Right to Know	You have the right to receive the following information: What types of personal information collected; What are the types of sources of the personal information collected; To what end we collect sell or share the personal information; Types of third parties to whom we disclose personal information; and The specific pieces of personal information we have collected about you.
Right to Correct	Taking into account the nature of the personal information and the purposes of the processing thereof, you have the right to request that we correct inaccurate personal information about you.
Right of Erasure	You may ask us to delete your personal information and direct our service providers to do so. Please note that we may not delete your personal information if it is necessary for us to protect our legal rights, comply with an existing legal obligation; or use your personal information, internally, in a lawful manner that is compatible with the recruitment purposes.
Right to Limit Use and Disclosure of Sensitive Personal Data	You have the right to request that we limit our use or disclosure of your “sensitive personal information” that we collected from you as mentioned above. We may deny your limitation request if the use and/or disclosure of the information is necessary for us to assess your candidacy for a position in the Company.
Right to Non-Discrimination for the exercise of your privacy rights	You have the right to not be discriminated by us because you exercised any of your rights under the Californian Privacy Laws.
Right to designate an authorized agent to submit Californian privacy Laws’ requests on your behalf	You may designate an authorized agent to make a request under the Californian Privacy Laws on your behalf. To do so, you need to provide the authorized agent written permission to do so and the agent will need to submit to us proof that such agent has been authorized by you. We will also require that you verify your own identity, as explained below.

In order to exercise your Privacy rights, please contact us by sending us a message to the following address: privacy@clearskai.com.

Retention of Your Personal Information

We store your job application documents and information for as long as necessary to fulfil the purposes of using such information and as permitted by law.

We will delete your information from all our systems, when we no longer need to process your application documents, except for relevant information about your submission of the application with us, such as your name, interview dates and locations, and our decision whether to hire you or not, for archival purposes, to establish exercise and defend legal claims and if we are required under law to retain your personal information.

Retention periods can vary based on how long the recruitment process lasts and the time period between when you first apply and when a hiring decision is made in connection with your application. In case that you will not fill the position for which you will be a candidate, certain personal information about you may continue to be relevant in order for us to consider your candidacy for a position in the Company in the future. In such cases, we may strive to continue to keep your personal information, and we will do so in accordance with the requirements of the applicable laws.

Sharing and Transferring Your Personal Information

We will share your personal information only to the extent necessary for the purposes of the recruitment process, and in the following instances or to the following third parties:

With any of our affiliate entities, which will process the personal information subject to the terms of this Privacy Policy.
With our third-party service providers, such as Comeet which is a data processor that handles our job recruiting, hiring, and on-boarding process.
- Besides Comeet, the Company engages additional third party service providers that provide legitimate business functions for Company in connection with the recruitment process, which will include processing your personal information.
- With a competent governmental authority, if we believe doing so is in accordance or otherwise required by an applicable law, regulation, judicial or legal process.
- With law enforcement or other authorities (including immigration, health, tax, national security) when it is necessary to protect the interests of our company or individuals.
- With another entity when it is required as part of a merger, acquisition or assignment of part or all of our business with that entity.
Transfer of Your Personal Information Outside Your Territory

We are a global company with sites including in Israel and the United States. We transfer your personal information between these territories to operate our business efficiently, to improve performance, and to create redundancies in order to protect information in the event of an outage or other malfunctions.

Whenever we transfer your personal information beyond the country of your origin, we will do so in accordance with applicable laws. If you are a resident in a jurisdiction where transfer of your personal information to another jurisdiction requires your consent, then you provide us your appropriate consent to such transfer.

Contact Us

If you have any questions about this privacy policy or have any concerns about how we handle your personal information, please contact us at: privacy@clearskai.com.