Recruitment Privacy Notice

This Privacy Notice applies to Waverley Software Inc. and all its affiliated companies, each trading as “waverleysoftware.com” or “Waverley (“we”, “our” or “us”).

Waverley (“We”, “Us”) are committed to protecting and respecting your privacy. This Privacy Notice (together with any other documents referred to) sets out the basis on which the personal data collected from you, or that you provide to Us, will be processed by Us in connection with Our recruitment processes. Please read the following carefully to understand Our views and practices regarding your personal data and how We will treat it.

This notice applies to all applicants who submit personal data in the form of CVs, cover letters, application forms and copies of training records/certification, either speculatively or in response to a job advertisement to any of the Waverley entities.

We are committed to handling personal data responsibly and in accordance with the applicable privacy laws including, but not limited to the European General Data Protection Regulation (GDPR), (UK GDPR) and the California Consumer Privacy Act (“CCPA”).

As data controller, that entity is responsible for ensuring that the processing of your personal information complies with applicable EU/UK/CA data protection law.

We use Zoho Recruit, an online application provided by Zoho Corporation Pvt. Ltd., to assist with Our recruitment process. We use Zoho Recruit to process personal information as a data processor on Our behalf. Zoho Recruit is only entitled to process your personal data in accordance with Our instructions.

When you apply for a job opening posted by Us, these Privacy Notice provisions will apply to Our processing of your personal information.

When you apply for a job opening via the application function on a job site or similar online service provider (“Partner”), you should note that the relevant Partner may retain your personal data and may also collect data from Us in respect of the progress of your application. Any use by the Partner of your data will be in accordance with the Partner’s Privacy Notice.

Your Personal Information

Information We Collect From You

We collect and process some or all of the following types of information from you:

  • Information that you provide when you apply for a role. This includes information provided through an online job site, via email, in person at interviews and/or by any other method.
  • In particular, We process personal details such as name, email address, address, telephone number, date of birth, qualifications, experience, information relating to your employment history, skills experience that you provide to Us, as well as your video in case you conduct your interview using the Video Interview feature.
  • If you contact Us, We may keep a record of that correspondence.
  • A record of your progress through any hiring process that We may conduct.
  • Details of your visits to Waverley’s Website including, but not limited to, traffic data, location data, weblogs and other communication data, the site that referred you to Waverley’s Website and the resources that you access.

Information We Collect from Other Sources

Zoho Recruit provides Us with the facility to link the data you provide to Us, with other publicly available information about you that you have published on the Internet – this may include sources such as LinkedIn and other social media profiles.

The Zoho Recruit technology allows Us to search various databases – some publicly available and others not, which may include your personal data (including your CV or Resumé), to find possible candidates to fill Our job openings. When We find you in this way We will obtain your personal data from these sources.

We may receive your personal data from a third party who recommended you as a candidate for a specific job opening or for Our business in general.

Uses Made Of Your Information

Lawful Basis for Processing

We collect and use your personal data in order to take steps prior to entering into a contract for the purposes of the recruitment of staff for Our business.

Where you apply for a job opening through the Waverley website’s Apply functionality, We rely on your consent, which is freely given by you during the application process, to disclose your personal data to Waverley on the basis described below.

Purposes of Processing

We use information about you in the following ways:

  • To consider your application in respect of a role for which you have applied.
  • To consider your application in respect of other roles.
  • To communicate with you in respect of the recruitment process.
  • To enhance any information that We receive from you with information obtained from third party data providers.
  • To find appropriate candidates to fill Our job openings.
  • To help Our service providers (such as Zoho Recruit and its processors and data providers) and Partners (such as the job sites through which you may have applied) improve their services.

Automated Decision Making/Profiling

We may use the Zoho Recruit technology to select the appropriate candidates for Us to consider based on the criteria expressly identified by us, or typical in relation to the role for which you have applied. The process of finding suitable candidates is automatic, however, any decision as to who We will engage to fill the job opening will be made by Our staff.

Disclosure of Your Information

As set out above, We pass your information to Our third party service providers, including Zoho Recruit, who use it only in accordance with Our instructions and as otherwise required by law.

When you have applied for a job opening through the Apply functionality, and where you have consented to this disclosure, We will disclose to the Waverley staff certain personal data that We hold, including but not limited to a unique identifier used by Waverley to identify you, and information about your progress through Our hiring process for the applicable job opening, as well as tangible, intangible, visual, electronic, present, or future information that We hold about you, such as your name, contact details and other information involving analysis of data relating to you as an applicant for employment (collectively “Disposition Data”). 

Where you have applied to a job opening through another service provider, We may disclose data similar to the Disposition Data defined above to such service provider. The service provider shall be the data controller of this data and shall therefore be responsible for complying with all applicable law in respect of the use of that data following its transfer by Us.

How We Store Your Personal Data

Security

We take the appropriate measures to ensure that all personal data is kept secure including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do Our best to protect your personal data, We cannot guarantee the security of your data transmitted through any online means, therefore any transmission remains at your own risk.

Where We Store Your Personal Data

The communication of your personal data between Waverley’s companies may imply the international communication of your personal data. To this end, the Company guarantees that these communications comply with all legal requirements and obligations established in applicable regulations at all times.

In addition, those security measures necessary to ensure your personal data are correctly safeguarded have been adopted.

The data that We collect from you and process using Zoho Recruit Services may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for Us or for one of Our suppliers.

By submitting your personal data, you agree to this transfer, storing or processing.

In particular, your data may be accessible to i) the Zoho Recruit staff in the USA or ii) may be stored by the Zoho Recruit hosting service provider on servers in the USA as well as in the EU. The USA does not have the same data protection laws as the United Kingdom and EEA. A Data Processor Agreement has been signed between Zoho Corporation Pvt. Ltd. and its overseas group companies, and between Zoho Corporation Pvt. Ltd. and each of its data processors. These data processor agreements are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data.

If you would like further information please contact Us (see ‘Contact’ below). We will not otherwise transfer your personal data outside of the California state OR EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

How Long We Keep Your Personal Data

We will hold all the data for 24 months.

Your personal information will be deleted on one of the following occurrences:

  • deletion of your personal information by you (or by another person engaged by you); or
  • receipt of a written request by you (or another person engaged by you) to us.

Your Rights

In certain circumstances (for example, if you are a “data subject” in the EEA), and subject always to verification of your identity, you may request access to and have the opportunity to update and amend your personal data. You may also exercise any other rights you enjoy under other applicable global data protection laws.

Data subjects in the EEA and UK have the right (among others) to:

  • Request access to any personal data we hold about them (“Subject Access Request”) as well as related data, including the purposes for processing the personal data, the recipients or categories of recipients with whom the personal data has been shared, where possible, the period for which the personal data will be stored, the source of the personal data, and the existence of any automated decision making.
  • Obtain without undue delay the rectification of any inaccurate personal data we hold about them.
  • Request that personal data held about them is deleted provided the personal data is not required by an entity of the Euronet Group for compliance with a legal obligation under applicable law or for the establishment, exercise or defense of a legal claim.
  • Under certain circumstances, prevent or restrict processing of their personal data, except to the extent processing is required for the establishment, exercise or defense of legal claims.
  • Under certain circumstances, request transfer of personal data directly to a third party where this is technically feasible.

If you would like to exercise any of those rights, please:

  • contact Us using Our Contact details below,
  • let Us have enough information to identify you,
  • let Us have proof of your identity and address, and
  • let Us know the information to which your request relates.

How to Complain

We hope that We can resolve any query or concern you raise about Our use of your information.

If you believe that we have not complied with our obligations under this Data Privacy Notice, or the applicable law, you have the right to make a complaint to a relevant Data Protection Authority or through the courts.

The Data Protection contact details:

  • Europe (EEA) Members | European Data Protection Board (europa.eu)
  • Rest of World https://www.cnil.fr/en/data-protection-around-the-world

Contact
All questions, comments and requests regarding this Privacy Notice should be addressed to DPO@waverleysoftware.com.