Privacy Notice for Applicants
PRIVACY NOTICE FOR APPLICANTS
Last updated and effective date: 17 December, 2022
This Privacy Notice for applicants describes how Pactum AI group entities listed below (“Pactum”, “we”, “us” or “our”) process and safeguard your personal data in the recruitment process. This Privacy Notice applies both in cases where you submit a job application to us directly as well as when you apply through a recruitment agency. If applicable, this Privacy Notice shall also apply to internship applications.
Controller of personal data (responsible entity)
The controller and responsible entity for the processing of your personal data is the entity listed below who is responsible for the recruitment process:
| Location | Controller | Contact details |
| United States | Pactum AI, Inc.
800 West El Camino Real, Suite 180 Mountain View, California, 94040 United States |
[email protected] |
| Estonia (Europe) | Pactum AI OÜ
Rotermanni tn 12, Tallinn city, Harju county, 10111 Estonia |
[email protected] |
Categories of personal data and sources of collection
As your prospective employer, we collect and process your personal data in a variety of ways. The following provides the list of the types and sources of personal data that we may collect in the course of the application and recruitment process.
| Category of personal data | Source of collection |
| General personal data and contact details, such as your name, personal identification code, home address, e-mail address, phone number, date of birth. | We collect this information when you apply for a position of employment in Pactum or communicate with us about the recruitment process. We may also receive this data from recruitment agencies. |
| Information contained in your application, such as your level of education, educational institution, previous work experience, qualifications, trainings, language skills, information about your desired salary, information about the possibility of relocation. | We collect this information when you apply for a position of employment in Pactum. We may also receive this data from recruitment agencies. |
| Other information collected and processed in the course of the recruitment process, such as the status of the recruitment process, communications about the recruitment process, requested and committed salary, information disclosed in recruitment interviews, information of voluntary personality tests, information of suitability tests/assignments, information concerning reference checks (including the data on person making the reference), information concerning rejection and the reasons thereof. | We collect this information when you apply for a position of employment in Pactum or communicate with us about the recruitment process. We may also collect references from your referees, including via third party service providers. |
| If applicable: information about your background check, such as your criminal record, information concerning pending court cases. Please note that background checks are conducted only if you apply to Pactum AI, Inc. | We collect this information from third party service provider(s) who carry out background checks on behalf of Pactum. |
We may also collect other personal information about you that you voluntarily provide to us by submitting the application or in the course of or after the recruitment process.
To the extent permitted by applicable law, we may also collect your personal information that we believe is relevant to your application or a potential future position of employment from other third parties, such as public databases and recruitment portals.
Purposes and legal bases for processing personal data
We process your personal information for a variety of purposes. The following provides the list of the purposes and legal grounds for processing your personal information you have provided to us by submitting the application or in the course of the recruitment process.
Legitimate interest
| Purpose of Processing | Processed Types of Information |
| Evaluate your application and suitability for the position of employment. | General personal data, information contained in your application, other information collected and processed in the course of the recruitment process, information on background check. |
| Contact you about your application and recruitment process. | Contact details. |
| Establish, exercise or defend any potential legal claim. | All types of personal information collected in the course of the application and recruitment process. |
| Internal analysis and management of our talent pool. | All types of personal information collected in the course of the application and recruitment process. |
Compliance with a legal obligation
| Purpose of Processing | Processed Types of Information |
| Evaluate your suitability for the position of employment by conducting background checks where this is required by applicable law. | Information on background check. |
In order to take steps prior to entering into an employment contract
| Purpose of Processing | Processed Types of Information |
| Prepare an employment contract. | General personal data, contact details, information contained in your application, other information collected and processed in the course of the recruitment process. |
Consent in specific circumstances
| Purpose of Processing | Processed Types of Information |
| Contact you about any vacant future position of employment. | Contact details. |
| Evaluate your suitability for the position of employment. | Information of voluntary personality tests. |
Your personal data will only be processed for the purposes listed above in this section if you have provided a respective consent to us. You may revoke such consent at any time by contacting us at the contact details provided in the beginning of this Privacy Notice described below.
Retention of personal data
We store the personal data of job applicants during the recruitment process and for as long as necessary to fulfill the purpose for which it was collected. However, if necessary, we may retain personal data for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and accounting requirements set by a legislature, regulator, or other government authority. To determine the appropriate duration of retention of personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations. Once retention is no longer necessary for the purposes outlined above, we will either delete or de-identify the personal data for reporting purposes only to help us better understand, analyze and improve our recruitment process. Or, if this is not possible (for example, because personal data has been stored in backup archives), then we will securely store the personal data and isolate it from further processing until deletion or deidentification is possible.
If you are selected and conclude an employment contract with us, we will retain your personal information in the manner and for the period applicable to the processing of Pactum’s employees’ personal information. The relevant information will be made available to you when we enter into an employment contract.
Once the established retention time period for a particular purpose expires, we will delete or anonymize the personal information, so it can no longer be associated with you.
Sharing of personal data
In addition to the specific situations discussed elsewhere in this Privacy Notice, we may disclose information in the following situations:
- Affiliates and acquisitions. We may share information within and between Pactum group companies. In addition, if we are involved in a merger or if another company acquires, or anticipates acquiring, our company, business, or our assets, we may share information with that company, including at the planning and negotiation stages.
- Other disclosures. We may disclose information in response to lawful requests by state authorities, court orders, or in connection with any legal process, or if permitted or required by applicable law. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the provision of services by a third party intermediary. For these reasons, your personal data may be disclosed to courts, state authorities, legal advisors, etc.
- Service providers. We may share your information with third party service providers who provide services to us or on our behalf in accordance with our instructions. Among other things, service providers help us to administer our website, administer the recruitment process, carry out background checks, assist with technical support, and send communications. In these cases, we will control and remain responsible for the use of your personal information at all times.
- Recruitment agencies. We may share your information with recruitment agencies if your job application was originally submitted via platforms of these recruitment agencies.
How we protect personal data
We use adequate technical and organisational security measures to protect your personal data. For example, we only grant access to your personal information to authorised employees. We make our best efforts to keep your personal information safe and always require the high level of security and confidentiality from our employees.
Please note that no method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from loss, destruction, unauthorised access, misuse, or disclosure, we cannot fully guarantee the security of your personal information. In the event that we are required by law to inform you of any unauthorised access to your personal information, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
Transmission of personal data to other countries
Pactum group includes entities established in European Union and in the United States. We transmit information between and among our group of companies and we use service providers who may be established outside of EU/EEA. As a result, your personal information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country. Nonetheless, we take steps to treat personal data using the same privacy principles that apply pursuant to the law of the country in which we first received it. By submitting your personal information to us you acknowledge the transfer, storage and processing of your personal information in a country other than your country of residence including, but not necessarily limited to, the United States. With respect to transfers from the European Economic Area to foreign countries not providing an adequate level of data protection, we base the transfer on appropriate safeguards, such as standard data protection clauses adopted by the European Commission. If you would like to receive more information regarding the transfers of your personal data and the safeguards applied by us, you can contact us at the contact details provided in the beginning of this Privacy Notice.
Your rights
Subject to the restrictions and conditions set out in applicable law, you may exercise the following rights as a data subject:
- Access to your personal data. You may request access to your personal information at any time.
- Rectification to your personal data. You may request that we update, correct or rectify any inaccurate or incomplete personal information.
- Deletion of your personal data. You may request that we delete your personal information, by contacting us at the address described below. However, please note that certain information is strictly necessary in order to fulfil the purposes defined in this Privacy Notice and may also be required by law. Therefore, such personal information may not be deleted.
- Revocation of consent and right to object. You may revoke consent to our processing (where our processing is based upon consent), or object to our processing (where our processing is not based upon your consent). In some cases we may limit or deny your request if we are required or permitted by law to do so. Please note that revocation of consent does not affect the lawfulness of the processing of personal information carried out on the basis of consent before revocation.
- Data portability. You may request a copy of the personal information that you have provided to us. In some cases we may limit or deny your request if we are required or permitted by law to do so, e.g. if it is necessary for the purpose of our legitimate interest to protect our trade secrets or any other confidential information.
You may exercise these rights by contacting us at the contact details provided in the beginning of this Privacy Notice. We will respond to your requests and to provide you with additional privacy-related information within the timeframes specified in applicable law. Please note that we may ask you for additional information to adequately verify your identity before actioning your request to exercise your rights as a data subject.
If you are not satisfied with our response or have a concern that your privacy rights have been infringed, and you are in the European Union, you have the right to lodge a complaint with your local supervisory authority. List and contact details of European supervisory authorities can be found here.
Changes to this Privacy Notice
We may change our Privacy Notice and practices over time in order to adapt it to any updates that might arise.
This Privacy Notice is available on our Careers Website. Kindly note that we may modify the Privacy Notice from time to time. If we make any material changes, we will notify you by posting this Privacy Notice on the Careers Website and we will update the “Last Update” date. You are advised to review this Privacy Notice periodically for any changes. Changes to this Privacy Notice are effective when they are posted on this page. You can see when this Privacy Notice was last updated by checking the date indicated in the beginning of the Privacy Notice.
