Candidate Privacy Notice

CANDIDATES PRIVACY NOTICE

 

[Last Updated: May 15, 2024]

 

This job candidates’ privacy notice (“Candidates Privacy Notice”) describes what Personal Data (as defined below) we, Perion Network Ltd. (“Perion”), including our affiliated companies and subsidiaries (collectively “we” or “us” or “our” and each affiliate or subsidiary a “Business Unit”) collect and process on individuals applying to our offered job positions (“Candidates”, “you” or “your”) during the recruitment process and thereafter. This Candidates Privacy Notice applies to Candidates in the territory where we offer job opportunities, and is subject to applicable data protection laws (“Data Protection Laws”).

This Candidates Privacy Notice applies to the processing, sharing, and storing of Personal Data (as defined below) during, or after, the recruitment process, and is in addition to, and does not replace the privacy policies governing the use of our websites and services.

Please note that you are not obliged by law to provide us with Personal Data. However, we must obtain certain types of Personal Data to process and examine your job application. In addition, if following the recruitment process a Candidate is hired or otherwise engaged by us, the Personal Data collected through the course of recruitment will be subject to our internal privacy policies, as provided to its employees and staff members.

Perion and the applicable Business Unit are considered the “data controller” (or any equivalent definition under Data Protection Laws) of the Personal Data collected from Candidates. This means that we are responsible for deciding how we process, hold, and use Personal Data about you, as well as to implement applicable measures in order to secure the Personal Data we store, and where applicable, enable you to exercise your rights.

It is important that you read this Candidates Privacy Notice, together with any other notices that might be provided on specific occasions when we are collecting Personal Data about you so that you are aware of how and why we are collecting and using such Personal Data. For any questions or concerns you might have regarding your Personal Data please contact our Data Protection Officer at:  privacy@perion.com

 

1.THE TYPES OF PERSONAL DATA WE COLLECT AND THE PURPOSE

 

Personal Data” refers to information that identifies, relates to, or could reasonably be linked with an individual by reasonable means. For example, it could include your name, email address, and other contact information (address, telephone number), etc. Personal Data may further include types of information defined under applicable Data Protection Laws as “Sensitive Data” which may include information such as governmental identification number or certificate, information that reveals racial or ethnic origin, religion, health/sex related information, etc.

We will collect, store, and use various types and categories of Personal Data about Candidates, which may further include Sensitive Data. Those categories are detailed in the table below. Please note that the specific categories or types of Personal Data collected may vary depending on the position and legal requirements. Personal Data is provided on a voluntary basis; however, some Personal Data may be necessary to complete an evaluation of your application, and if it is not provided, our ability to consider you as a candidate may be limited.

This table represents the Personal Data that may be collected by us:

 

TYPES OF PERSONAL DATA THAT MAY BE COLLECTED (DEPENDING ON APPLICABLE LAWS) PURPOSE OF COLLECTION AND USE Categories under the CCPA[1] LAWFUL BASES (APPLICABLE FOR CANDIDATES LOCATED IN THE EEA OR UK*[2])
▪       Personal identification information: such as name, date of birth, government-issued identification number, and copy of identification certificate (e.g., ID, passport, SSN).

▪       Contact information: such as email address, phone number, and address.

▪       Employment history: such as previous employers, job titles, dates of employment, responsibilities, achievements, etc.

▪       Education and qualifications: such as information on educational institutions attendance and dates, degrees or certifications obtained, fields of study, etc.

▪       Skills, abilities, and expertise:  such as information related to the Candidate’s relevant competencies, skills, language proficiency, and any other expertise that may be pertinent to the position being applied for.

▪       Assessment results: information gathered from tests, interviews, or assessments conducted during the recruitment process to evaluate the Candidate’s suitability for the role.

▪       Background check information: information obtained through background checks (including information about criminal convictions and offences, subject to applicable laws, such as verification of employment and education history.

▪       Eligibility to work: information regarding the Candidate’s legal right to work in the relevant country, such as citizenship or visa status.

▪       Communication and internal records: such as correspondence, and records of phone calls or other interactions between the Candidate and us during the recruitment process.

▪       Any additional information voluntarily included by the Candidate in its resume (CV), and supporting documents submitted by the Candidate.

▪       Job Application evaluation: to assess the Candidate’s qualifications, skills, and suitability for the position applied for, and to identify potential matches with other open positions offered by us.

▪       Communication: to facilitate our correspondence with the Candidate during the recruitment process, including scheduling interviews, providing updates, and addressing inquiries.

▪       Verification and reference checks: to verify the accuracy of the information provided by the Candidate, including employment history, education, and professional references, as well as conducting background checks where necessary and subject to applicable laws.

▪       Compliance with legal requirements: to ensure adherence to relevant employment laws, regulations, and industry standards.

▪       Eligibility to work: to confirm the Candidate’s legal right to work in the relevant country and comply with immigration requirements, if applicable.

▪       Decision-making and selection: to facilitate the decision-making process, compare Candidates, and ultimately select the most suitable individual for the position.

▪       Record-keeping and documentation: to maintain a record of the recruitment process, including Candidate evaluations, assessments, and decisions, which may be used for future reference or to address potential disputes or legal claims.

▪       Administration and performance of human resources related duties, obligations, and procedures.

▪       Continuous improvement: to analyze and refine our recruitment strategies, practices, and processes.

Category A – Identifiers.  

 

Category B –

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

 

Category G

Geolocation data

 

Category I – 

Professional or employment-related information.

 

Category J –

Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)

 

The lawful bases depend on the purpose for which we collect, use, and retain Personal Data.

We mainly collect and use the Personal Data under our legitimate interest, as needed to decide if to appoint a Candidate to a certain job position.

We may further retain certain types of Personal Data, under our legitimate interest, for the purpose of record keeping, compliance with applicable laws, evaluating our recruiting processes, and addressing potential disputes or legal claims.

Where required under applicable Data Protection Laws, we will obtain your consent in order to retain and further use Personal Data for future job opportunities. You have the right to withdraw consent at any time.

 

▪       Sensitive Data, Equal opportunity data: information provided voluntarily by the Candidate related to gender, race, ethnicity, national origin and citizenship, disability and medical or health condition, veteran or military status.

 

▪       Record-keeping and documentation: to maintain a record of the recruitment process, which may be used for internal and external reporting responsibilities (e.g., legal and regulatory requirements), future reference or to address potential disputes or legal claims.

▪       Equal opportunity monitoring: we may ask for such information for the purpose of monitoring equal opportunity and ensuring diversity and inclusion.

▪       Administration and performance of human resources related duties, obligations, and procedures.

Note that, we do not discriminate, either directly or indirectly, on the grounds of sex, sexual orientation, gender, ethnic origin, religion, belief, marital status, nationality, national origin, color, age, or similar protected characteristics.

Category C –

Protected classification characteristics under California or federal law.

 

 Category L –

Sensitive personal information.

 

Category B – 

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

 

We collect these types of Personal Data subject to your consent. You have the right to withdraw consent at any time.

 

We may further retain certain types of Personal Data, under our legitimate interest, for the purpose of record keeping, compliance with applicable laws, evaluating our recruiting processes, and addressing potential disputes or legal claims.

 

 

[1] This table also represents the categories of Personal Data, as classified and required under the California Consumer Protection Act (“CCPA”) which has been collected by Perion Group in the preceding 12 months.

[2]* Where the EU or UK General Data Protection Regulations apply, and as required under these regulations.

** Where the PIPEDA and/or other Canadian Privacy provincial laws apply, and as required under these laws.

[1] This table also represents the categories of Personal Data, as classified and required under the California Consumer Protection Act (“CCPA”) which has been collected by Perion Group in the preceding 12 months.

[2]* Where the EU or UK General Data Protection Regulations apply, and as required under these regulations.

** Where the PIPEDA and/or other Canadian Privacy provincial laws apply, and as required under these laws.

 

2. CATEGORIES OF SOURCES OF PERSONAL DATA

 

We typically collect Personal Data about Candidates, as follows:

  • Provided directly by the Candidate – this includes information you share when you submit your application, and/or at any other stage of the process, such as your name, email address, postal address, telephone number, age, education history, etc.; and
  • Information provided by third parties – recruitment agencies, criminal records checks, publicly available sources (including any social media platforms you use) or your references former employers, etc.

 

3. WITH WHOM WE SHARE YOUR PERSONAL DATA

 

We share your Personal Data with third parties, including within our company group and with our employees, contractors, consultants, and service providers that help us with our business operation as well as administration and performance of human resources related duties, obligations, and procedures, including where needed to establish the recruitment process. We take applicable measures to ensure your Personal Data will be accessed only by those who really need to in order to perform their tasks and duties, and to third parties who need such access in order to provide their services as required by us and in accordance with our instructions.

Below you can find information about the categories of such third-party recipients.

 

CATEGORY OF RECIPIENT CATEGORY OF PERSONAL DATA PURPOSE OF SHARING
Perion Company Group All types of Personal Data

(Category A, B, C, G, I, J, L)

 

We may share Personal Data within our company group to allow us to manage our recruitment process as a business, at the organizational level, and for human resources management. This will include information shared with a third party including by way of merger, acquisition, bankruptcy, or purchase of all or part of its assets, your Personal Data may be shared with the parties involved in such event.
Contractors and Service Providers

 

 

All types of Personal Data

(Category A, B, C, G, I, J, L)

 

We may disclose Personal Data to our trusted agents and service providers (including, for example, human resources agencies, recruitment management SaaS providers, cloud providers, legal counsel, etc.). We share your Personal Data with such third parties so that they can perform the requested services on our behalf. These entities are prohibited from using your Personal Data for any purposes other than providing us with requested services or to comply with applicable laws.
Governmental agencies, or authorized third parties Subject to law enforcement or a competent authority request. In the event of legal and law enforcement, we may disclose certain Personal Data, such as in response to verified requests relating to criminal investigations or alleged illegal activity, or any activity that may expose us, you, or any other third party to legal liability, and solely to the extent necessary to comply with such purpose.

 

We may further share Personal Data where and to the extent needed to protect you, or third parties; enforce our policies and agreements or defend our rights, including the investigation of potential violations, alleged illegal activity, or addressing fraud or security issues; as well as in response to disputes, claims, demands, or legal proceedings involving you and us or any third party as required to defend our legitimate interests and as permitted under law. In addition, we may disclose Personal Data to third parties, in the event you request us to do so. In such event, the provision of your Personal Data will be subject to such third parties’ policies and practices only.

 

We do not “sell” your Personal Data to any third party nor “share” it, as defined under the CCPA, meaning, we do not disclose or share your personal information in exchange for money or other form of consideration.

 

4. INFORMATION SECURITY & CROSS BORDER DATA TRANSFER

 

We take great care in implementing and maintaining the security of your Personal Data. We employ industry standard procedures and policies to ensure the safety of your Personal Data and prevent unauthorized disclosure or use of any such. In addition, we limit access to your Personal Data to those employees, agents, contractors, and other third parties who have the “need to know”. They will only process your Personal Data on our instructions. We have implemented technical, physical, and administrative security measures to protect the Personal Data we collect and store, including procedures to detect and manage suspected or actual security breaches.

Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our systems and network, and will not always be able to prevent such access.

Subject to applicable Data Protection Laws requirements, we will notify you and the appropriate authorities in the event that we discover a security incident or breach related to your Personal Data.

Due to our global operation, your Personal Data may need to be processed or accessed in provinces, states, territories or even countries other than your jurisdiction, including, for example, when shared or accessed by our service providers or other affiliates. This may include the transfer of Personal Data from and to the State of Israel, the US, Canada or the EEA. As a result, your Personal Data may be subject to the laws of the jurisdictions in which the entities to which it will be disclosed are located and may be made available to the courts and law enforcement authorities of those jurisdictions.  We only transfer Personal Data to another country in accordance with applicable Data Protection Laws. We take appropriate measures to ensure that your Personal Data receives an adequate level of protection, including by using contractual obligations or other data transfer mechanisms that were pre-approved by applicable data protection authorities to ensure your Personal Data is protected.

 

5. DATA RETENTION

 

In general, we will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, administrative, record keeping, or reporting requirements.

The criteria used by us to determine the retention periods are as follows:

  • The type of Personal Data and purpose of the collection – we consider the scope, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means. If and where we no longer have a legal justification for retaining Personal Data, we will delete it or de-identify it so it can no longer be associated with you by reasonable means.
  • Compliance with our legal obligations – we are required to retain certain types of Personal Data in order to comply with our obligations under applicable laws. In addition, we may retain certain types of Personal Data in the event we are required to do so subject to a binding legal request or a court order.
  • Dispute, claims, and legal proceedings – if you have a dispute with us, we may retain certain types of Personal Data as necessary and applicable to your claims, including any legal proceedings between you and us until such dispute is resolved, and following, if we find it necessary, in accordance with applicable statutory limitation periods. In addition, in the event you request to exercise your rights, we will maintain the applicable correspondence for as long as needed to demonstrate compliance, usually in accordance with applicable statutory limitation periods.

We may further retain your Personal Data where you were not hired, to allow us to reconsider your application for alternative or future positions, and where required under applicable Data Protection Laws, we will obtain your consent. In addition, we may retain limited Personal Data as a reference for any future applications submitted.

 

6. YOUR RIGHTS RELATED TO YOUR PERSONAL DATA AND HOW TO EXERCISE THEM

 

We respect your privacy and your rights to control your Personal Data. You have the right to control and request certain limitations or rights to be executed with regard to the Personal Data we hold and process. Depending on where you live and the applicable Data Protection Laws, these rights may include one or more of the following principal rights:

  • The right to know what Personal Data we collect about you, the purpose of collection, with whom we share it, and additional information such as the categories of sources from which the Personal Data is collected – all as provided under this Candidates Privacy Notice;
  • The right to request access and inspect your Personal Data, which entitles you to review or receive a copy of certain Personal Data we hold about you;
  • The right to correct (“rectify”) inaccuracies in your Personal Data, which entitles you to have any incomplete or inaccurate Personal Data corrected;
  • The right to request deletion of your Personal Data, which entitles you to request us to delete Personal Data (subject to applicable Data Protection Laws, which permits the retention of certain Personal under certain circumstances);
  • The right to request to restrict processing of Personal Data, which entitles you to request to limit the purposes for which we process your Personal Data (subject to certain conditions under Data Protection Laws);
  • The right to object to processing of your Personal Data, which entitles you to object to our processing of your Personal Data (subject to certain conditions under Data Protection Laws);
  • The right to data portability, which entitles you to receive the Personal Data you have provided, in a structured, commonly used and machine-readable format and transmit it to another controller;
  • The right to withdraw consent, where we are processing your Personal Data based on your consent;
  • The right to be informed of automated decision making, which entitles you to be informed of instances where your Personal Data is used to render a decision based exclusively on an automated process;
  • Exercise your privacy rights without receiving discriminatory treatment by us; and/or
  • The right to appeal or lodge a complaint. If we decline to take action on your request, we will inform you without undue delay as required under applicable Data Protection Laws. For EEA/UK Candidates*, you have the right to lodge a complaint with the applicable Data Protection Authorityin the EU or the Information Commissioner in the UK.  For Canadian Candidates**, you have the right to lodge a complaint with the local Data Protection Authority as follows: (1) If you reside in Quebec, contact https://www.cai.gouv.qc.ca/; (2) If you reside in British Columbia, contact https://www.oipc.bc.ca/; and (3) If you reside in Alberta. Contact https://www.oipc.ab.ca.

The rights described above are not absolute rights and may be subject to certain legal, business or contractual requirements. Applicable laws may allow or require us to deny or partially deny your request. For detailed information on your rights and how to exercise your rights, please see the Data Subject Request (“DSR”) form available HEREand send it to our privacy team at: privacy@perion.com.

If you are an EEA or UK resident, you may also submit the request to exercise your right to our Data Protection Representative, Prighter Group, at https://prighter.com/q/11106546394.

Attn: Andreas Mätzler

Email: rep_perion@prighter.co

 

We sometimes need to request specific information from you to help us confirm your identity and ensure the requested rights apply to you. This is another appropriate security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. Information provided in connection with such a request will be processed only for the purpose of processing and responding to your request, and it may be shared with our legal and administrative teams.

 

 

7. AMENDMENTS

 

We reserve the right to periodically revise this Candidates Privacy Notice, which will have immediate effect upon posting of the revised Candidates Privacy Notice. We recommend you review this Candidates Privacy Notice periodically to ensure that you understand our privacy practices and to check for any amendments.

If the changes we make are significant, we will provide a more prominent notice and/or obtain consent where required by applicable laws. By continuing to use this recruiting website and/or engage with us on or offline in the context of employment after we post any such changes, you accept this Candidates Privacy Notice as modified.

8. EXTERNAL LINKS

 

This website may provide links to third party websites, services, social networks, applications or social media features (“Third Party Features”). Connecting with such Third Party Features may allow the applicable third party to process your Personal Data and we encourage you to read the applicable privacy policies and terms and conditions of such Third Party Features. This Candidates Privacy Notice does not cover the Third Party Features (including their content and the processing activities by such third parties) and we Disclaim any and all liability related to them.

 

9. PERION CONTACT DETAILS    

 

Perion Network Ltd.

26 HaRokmim Street, Azrieli Center, Building A, 4th Floor

Holon 5885849, Israel

 

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