Applicant Privacy Notice & Policy

Updated August 31, 2023

‍

Xurrent, Inc. (“Xurrent,” “we,” “us,” “our,” or the “Company”) is committed to ensuring that the personal data of job applicants is handled in accordance with sound data protection and privacy principles and applicable law. Every candidate for employment at Xurrent receives this notice, which describes, among other things:

• the information that we collect about you during our hiring process,
• the purpose collecting such information and how we use it, and
• what your rights are related to your personal information.

As a job applicant, the laws in various jurisdictions provide you with the right to know:

• how we use your personal data when you apply for a role at Xurrent, as well as
• the types of data we collect,
• who we share this information with,
• how long we keep the data,
• what security controls we have in place, and
• where the data is stored.

Please note that your use of any Xurrent service or website is also governed by our general Privacy Policy.

This Applicant Privacy Notice and Policy tells you what to expect when we collect personal information about you. It applies to all applicants who apply for a role at Xurrent. Unless otherwise noted, we are considered the controller (or the “business” under the California Consumer Privacy Act (CCPA)) of this personal information.

We do not sell or otherwise disclose or share your personal information for monetary or other consideration to any third parties, but we may need to share relevant information with service providers and sub-processors in order to comply with legal obligations, fulfill our business purposes, or for other purposes described herein.

Categories of Personal Information We Collect

We collect the following categories of personal information as part of the recruitment process, either directly from you or from third parties with your approval:

• Identifying information, such as your name/preferred name, date of birth, and SSN or other government identification number;
• Contact information, such as physical address, telephone number, and email address;
• Employment and education history, such as a resume or CV, cover letter, employment references, publicly available social media profiles (such as LinkedIn) or other information about your professional background;
• Citizenship information, such as your visa and right-to-works status;
• Educational records such as grades, transcripts, and class lists;
• information received from third parties, such as the results of a third party background check, and the information we receive from someone who refers you for a position;
• sensitive information you voluntarily provide during the recruitment process, such as demographic information or information about your gender, race, ethnicity, and disabilities, but only when permitted under applicable laws; and
• any other information that you may elect to submit to us as part of your application.

How We Use Your Personal Information

We will use the personal information about you collected as part of the recruitment process for the following business purposes only:

• To correspond with you and manage our relationship with you during the recruitment process;
• To conduct pre-employment screening, including reference & background checks;
• To provide assistance with immigration support (such as applying for a visa);
• To comply with legal requirements;
• To conduct data analyses to review, better understand and improve our recruitment process and the tools we use; and
• To evaluate your application and candidacy to make an employment decision.

Sharing of Personal Information

We will not sell, share, or otherwise disclose your personal information for purposes unrelated to those detailed in this Applicant Privacy Notice and Policy without the prior consent of you, the applicant. To that end, we will take reasonable precautions to allow access to your personal information to only our employees, agents, contractors, or similar entities to the extent necessary for the purposes set out in this Applicant Privacy Notice and Policy. We may share your personal information to:

• Third-Party Service Providers.  In the course of our recruitment activities, we may make certain personal information available to third parties who provide services to us to support those activities. We will only do so where such a transfer is necessary, and in accordance with applicable data protection rules.  Such service providers may include, for example, companies that provide or help to operate our applicant database, provide payroll support services, provide background checking or verification services, help manage candidates’ recruitment life cycle via cloud-based recruitment software solutions, or help us improve our job applicant website.
• Affiliates.  Your personal information may be disclosed among our various affiliated entities for the purposes set out in this Applicant Privacy Notice and Policy.
• Public bodies. We may be required by applicable law or regulation to share your personal information with governmental agencies or public bodies, such as labor authorities.

Retention of Personal Information

If you are offered and accept a position with us, your personal information will become part of your employment record.  If your candidacy for employment at Xurrent is unsuccessful, you decline our offer, or you withdraw your application, we will retain your personal information only to consider you for potential future positions at Xurrent, and as long as needed to comply with any applicable laws or for the establishment, exercise, or defense of a legal challenge related to our recruitment process or decision.

‍

If you do not want us to retain your personal information to consider you for potential future positions, you may request that we delete it as described as described below. Please note, however, that we may retain some information that we are required to retain by law or in order to defend ourselves in the event of a legal claim.

Security

The security of your personal information is very important to us. We have implemented and we continually maintain a variety of technical and organizational measures to protect your personal information from unauthorized access and against unlawful processing, accidental loss, destruction, and damage.  To learn more about Xurrent’s Security practices, please refer to https://www.xurrent.com/security.

Supplemental Notice for California

This section provides additional details about the personal information we process subject to the California Consumer Privacy Act, as amended (CCPA).

Your Rights

Subject to applicable law, you have the following rights with respect to your personal information.

• Right to access.You have the right to request that we disclose to you what personal information we collect, use, disclose, share, and sell about you.
• Right to delete.You have the right to request that we delete your personal information that we’ve collected.
• Right to update.You have the right to request that inaccurate personal information we hold about you be corrected.
• Right to restrict the use and disclosure of your sensitive information.You have the right to request that we limit our use and disclosure of your sensitive personal information.
• Right to nondiscrimination.You have the right not to receive discriminatory treatment because you’ve exercised any of your rights under the CCPA.

If you or your authorized agent wishes to exercise any of these rights, please contact us as outlined in the “Contact Us” section below. Please note that we may ask you or your agent to provide us with additional information to confirm your identity.

Categories of Personal Information Collected

The personal information that we’ve collected in the past 12 months fall into the following categories specifically established under the CCPA:

• Identifiers such as a real name, postal address, unique personal identifier, online identifier, internet protocol address, and email address.
• Information under Cal. Civ. Code §1798.80(e), such as your name, address, telephone number, or any financial information.
• Internet or other electronic network activity information, such information regarding your interaction with Xurrent’s products and services.
• Audio, electronic, visual, or similar information, such as audio recordings of calls with you.
• Your social security, driver’s license, state identification card, or passport number.
• Your racial or ethnic origin.
• Geolocation data

For more information about the categories of personal information we collect, please see the “Categories of Personal Information Collected” section above.

Categories of Personal Information Disclosed for a Business Purpose

The personal information that we’ve disclosed for a business purpose (including to our service providers) in the past 12 months fall into the following categories specifically established under the CCPA:

• Identifiers such as a real name, postal address, unique personal identifier, online identifier, internet protocol address, and email address.
• Information under Cal. Civ. Code §1798.80(e), such as your name, address, telephone number, or any financial information.
• Internet or other electronic network activity information, such information regarding your interaction with the Xurrent products and services.
• Geolocation data.
• Audio, electronic, visual, or similar information, such as audio recordings of calls with you.
• Inferences drawn on the information above, such as aggregated metrics.
• Your social security, driver’s license, state identification card, or passport number.
• Your racial or ethnic origin.

For more information about the categories of personal information we disclose to other parties, including to our services providers, please see the “Sharing of Personal Information” section above.

No Sale or Sharing of Personal Information

We do not sell or share (for the purpose of cross-context behavioral advertising) your personal information, as those terms are defined under the CCPA.

Supplemental Notice for the EEA, UK, and Switzerland

This section provides additional details about the personal information we process subject to the General Data Protection Regulation (GDPR) and UK GDPR.

‍

When you apply to a job with Xurrent, the personal data contained in your application will be collected by Xurrent (“Controller”) for the purposes and pursuant to the terms in this Applicant Privacy Notice and Policy.  Your personal data will be processed for the purposes of managing Controller’s recruitment related activities, which include setting up and conducting interviews and tests for applicants, evaluating and assessing the results thereof, and as is otherwise needed in the recruitment and hiring processes. Such processing is legally permissible under Art. 6(1)(f) of Regulation (EU) 2016/679 (General Data Protection Regulation) as necessary for the purposes of the legitimate interests pursued by the Controller, which are the solicitation, evaluation, and selection of applicants for employment. Your personal data will be shared with Greenhouse Software, Inc., a cloud services provider located in the United States of America and engaged by Controller to help manage its recruitment and hiring process on Controller’s behalf, and if applicable Xurrent’s subsidiary that is the hiring entity. Please review this Applicant Privacy Notice and Policy for further details, including contact information for Xurrent and a further description of your rights under the GDPR.

Controller of Your Information

Unless otherwise stated in a supplemental notice, Xurrent is the data controller of your personal information.

Your Rights

Subject to applicable law, you have the following rights with respect to your personal information.

• Right to access.You have the right to access your personal information that we hold, and receive it in a portable way.
• Right to update.You have the right to request that we update your personal information.
• Right to delete.You have the right to have your personal information deleted.
• Right to restrict processing.You have the right to request us to restrict or suppress the processing of your personal information where our processing is inappropriate.
• Right to object.You have the right to object to the processing of your personal information.
• Right to withdraw consent.You have the right to withdraw your consent at any time where we are processing your personal information based on your prior consent.

To exercise your rights, please contact us as outlined in the “Contact Us” section below. Please note that we may ask you to provide us with additional information to confirm your identity.

Legal Bases for Processing Personal Information

We collect and process your personal information when it’s necessary in order to consider your candidacy for employment with us and in preparation for potentially entering into a contract of employment with you. We may also collect your personal information in order to comply with our legal obligations, where you’ve consented to our collection and processing of your personal information, or based on our legitimate interest to ensure that we hire the best candidates.

Cross-Border Transfers

Your personal information may be collected in, transferred to, accessed from, or stored in a country other than the one you are in, including the United States, which may have data protection rules that are different from those of your country.  Your personal information is only transferred out of your country in accordance with applicable data protection law, including, for example, to third countries that adequately safeguard personal data, or under the European Commission-approved Standard Contractual Clauses.  As we are a US company, it is inevitable that we may transfer personal information about EU/EEA and UK residents outside of the EU/EEA/UK.

‍

Additionally, Xurrent, Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Xurrent has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Xurrent has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Applicant Privacy Notice and Policy or our Privacy Policy at https://www.xurrent.com/privacy/ and and the EU-U.S. DPF Principles and/or the Swiss U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Complaints

You may lodge a complaint with a data protection authority for your country or region where you have your habitual residence, where you work, or where an alleged infringement of applicable data protection law occurs. A list of EEA data protection authorities is available here, and the contact details for the UK Information Commissioner’s Office is available here.

‍

Please contact our privacy team at privacy@Xurrent.com with inquiries or complaints regarding our Applicant Privacy Notice and Policy.  The Company commits to promptly resolve complaints about our collection or use of your personal information.

Contact Us

If you have any questions or concerns regarding this Applicant Privacy Notice and Policy or the collection of your personal information in connection with the Xurrent recruitment process, please direct them to Xurrent by email at  privacy@Xurrent.com or by regular mail addressed to:

‍

Xurrent, Inc.
Attn: Data Protection Officer
555 Bryant Street #156
Palo Alto, CA 94301
U.S.A.

Changes to this Applicant Privacy Notice and Policy

We may occasionally update this Applicant Privacy Notice and Policy. The date at the top of this Applicant Privacy Notice and Policy indicates when it was last revised. Any changes will become effective when we post the revised Applicant Privacy Notice and Policy on this page.

‍