Feedzai California Candidates Privacy Policy

CALIFORNIA LAW REQUIRES THAT WE PROVIDE YOU THIS NOTICE ABOUT THE COLLECTION AND USE OF YOUR PERSONAL INFORMATION.  WE ENCOURAGE YOU TO READ IT CAREFULLY.

Effective as of 19 December, 2024

Introduction

This California Candidates Privacy Policy (“Policy”) describes the categories of personal information that Feedzai, Inc., and its group companies, (“Company”, “we”, “us” and “our”) collect about California residents who apply or are recruited for a job with us (“candidates”), and how we use and disclose that information.

This Policy applies to personal information collected about you in your capacity as a job candidate. See our Privacy Policy for information about our practices when you use our website or otherwise interact with us offline or online in the same manner that a website visitor or someone who is not a job candidate may interact with us.

For the purposes of this Policy, “personal information” and “sensitive personal information” have the meanings given in the California Consumer Privacy Act of 2018 (as amended from time to time, the “CCPA”).

This Policy does not create or form part of any contract for employment or otherwise.

If you have questions about this Notice, please contact privacy@feedzai.com.

Information we collect about candidates

Categories of personal information

We may collect and process the following categories of personal information during the application and recruitment process:

• Identity information, such as first name, middle name(s), surname, title, national identification and/or passport details, national insurance / social security number or other tax-related information, driver’s licence, photographs
• Contact information, such as home address, work address, telephone number, and email address;
• Information from job application materials or recruiters, such as your job application, resume or CV, cover letter, writing samples, references, work history, education transcripts, whether you are subject to prior employer obligations, and information that referrers provide about you;
• Biographical information, such as first name, middle name(s), surname, maiden name, marital/civil partnership status, title, date of birth, gender (if you choose to provide this information), ethnicity (if you choose to provide this information), education history, professional history, professional qualifications and memberships, references, information relating to references such as referees’ names and contact details, information contained within letters of application and CVs, language proficiencies and other skills, certifications, certification expiration dates and information necessary to complete background checks
• Professional information, such as title and description of your prior roles, department, work location, dates of prior employment/engagement, employment/engagement status and type (e.g., full-time/part-time), terms of employment/engagement, contracts, work history (current, past, or prospective), training and learning program participation, termination date(s) and reason, length of service, current salary, desired salary, employment/engagement preferences, information necessary to complete background checks, licenses, permits, memberships, and certifications;
• Information from the application process, such as any phone-screens, interviews, evaluations and outcomes of recruiting exercises;
• Immigration status and other information that would allow us to verify your employment eligibility, such as national identification and/or passport number, details of residency and/or work permit and other information that would allow us to verify your eligibility to work for us in your relevant role;
• Job preferences, such as desired position and compensation, location preferences and willingness to relocate;
• Information needed to understand and assess accommodation requests regarding potential disabilities or other health conditions;
• Medical information if you meet with us in-person, such as your body temperature, health symptoms, vaccination status and other screening information in connection with the Company’s health and safety plans and protocols, including screening required to access Company offices/facilities and other measures designed to prevent the transmission of COVID-19 or other infectious diseases; and
• Other information you provide to us. 

Providing personal information to us is voluntary.  However, if you do not provide sufficient information, we may be unable to consider your application or, if you are hired, your subsequent promotion, transfer or relocation.

In certain cases we may ask you for additional information for purposes of complying with applicable laws.  We may also inquire about criminal and/or credit records. We will do so only where permitted by applicable law.

Sensitive personal information and protected classification characteristics 

We do not use or disclose sensitive personal information in ways subject to California residents’ right to limit use or disclosure of sensitive personal information under the CCPA.

Sources of personal information

We collect personal information from you when you apply for a job and throughout the job application or recruitment process. We may also collect your personal information from other sources and combine it with the personal information you provide us.  For example, we may collect your personal information from:

• Job board websites you may use to apply for a job with us;
• Prior employers that provide us with employment references;
• Professional references that you authorize us to contact;
• Pre-employment screening services, such as background check providers (where permitted by law);
• Employment agencies and recruiters;
• Your educational institutions;
• Your public social media profile such as LinkedIn or other publicly-available sources;
• Other Company personnel.

This section generally describes our practices currently and during the preceding 12 months.

How we use personal information about candidates

Purposes for which we use personal information

We may use the categories of personal information above for the following purposes:

• Recruitment management. Managing recruitment generally, such as:
  • operating the careers website we maintain at Feedzai Careers or any other site to which this Policy is posted (“Careers Website”);
  • recruiting, interviewing and evaluating job candidates;
  • conducting background checks and other pre-employment screening (where permitted by law);
  • analyzing and improving our application and recruitment processes;
  • accommodating disabilities or health conditions;
  • communicating with you regarding your current or future candidacy, opportunities with Feedzai or about the Careers Website and any changes to applicable terms or policies;
    and
  • other business operations.
• Compliance, safety and protection, such as:
  • complying with or monitoring compliance with legal and other requirements, such as tax, audit, recordkeeping, reporting, verifying identity and eligibility to work, and equal opportunities monitoring requirements, where applicable;
  • complying with internal policies and procedures;
  • complying with lawful requests and legal process, such as to respond to subpoenas or requests from government authorities;
  • protecting our, your or others’ rights, safety and property, including by complying with applicable public health guidelines and requirements, including, without limitation, guidance from the Centers for Disease Control or other public health authorities relating to the prevention and control of COVID-19 or other infectious diseases;
  • investigating and deterring against fraudulent, harmful, unauthorized, unethical or illegal activity, or conduct in violation of our policies or procedures;
  • controlling access to and monitoring our physical premises (e.g., by requiring health screenings to access offices/facilities;
  • pursuing legal rights and remedies, including investigating, making and defending complaints or legal claims; administering and enforcing internal policies and procedures; and
  • providing information to government authorities, law enforcement, courts or private parties where we have a good-faith belief it is necessary for the foregoing purposes.
• Analytics.  Creating anonymous, aggregated or de-identified data that we use and disclose to analyze our application and recruitment activities, business and for other lawful business purposes. We do not attempt to reidentify deidentified information derived from personal information, except for the purpose of testing whether our deidentification processes comply with applicable law.

Who we share your personal information with

We may disclose your personal information to the following parties to facilitate one or more of the purposes described above:

• Group Companies. Our group companies/other affiliates under the control of our corporate parent, for purposes consistent with this Policy or to operate shared infrastructure, systems and technology.
• Service Providers. Providers of services to Feedzai or our group that provide us with services that help us manage the recruiting process and operate our business, such as job boards, recruiters, interviewing and testing, IT systems and support, information and physical security, pre-employment screening, interview travel booking and expense reimbursement (where applicable), relocation (where applicable), and recruitment analytics.
• Professional advisors. Accountants, auditors, lawyers, immigration advisors, insurers, bankers, and other professional advisors.
• Compliance and protection related sharing. We may need to or may have a legitimate interest in, sharing your personal data with entities that regulate or have jurisdiction over us (such as regulatory authorities, public bodies and judicial bodies). We may also share your personal data in the context of protecting our, your or others’ rights, privacy, safety or property (including by establishing, making and defending legal claims).
• Business transfer participants.  Parties (and their advisors) to transactions and potential transactions pursuant to which we sell or transfer some or all of our business or assets, including your personal information, such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.
• Other parties not listed above but that are identified at or before the point at which we collect your personal information.

This section generally describes our practices currently and during the preceding 12 months. You should assume that each category of personal information we collect may be disclosed and may have been disclosed during the preceding 12 months, to each category of parties listed above in this section.

Personal information that we collect, use and disclose 

The table below describes our personal information practices by reference to the categories in the “Information we collect about candidates” section above and the categories described in the CCPA (Cal. Civ. Code Section 1798.140(v)) and describes our practices currently and during the 12 months preceding the effective date of this Policy.

How long we store your personal information

The criteria for deciding how long to retain personal information is generally based on whether such period is sufficient to fulfill the purposes for which we collected it as described in this Policy, including complying with our legal record retention obligations and for other compliance, protection, and safety purposes described above.

California privacy rights

California residents have the rights listed below under the CCPA. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

• Information.  You can request the following information about how we have collected and used your personal information during the past 12 months:
  • The categories of personal information that we have collected.
  • The categories of sources from which we collected personal information.
  • The business or commercial purpose for collecting or selling personal information.
  • The categories of third parties to whom we disclose personal information.
  • The categories of personal information that we sold or disclosed for a business purpose.
  • The categories of third parties to whom the personal information was sold or disclosed for a business purpose.
• Access.  You can request a copy of the personal information that we have collected about you.
• Deletion.  You can ask us to delete certain personal information that we have collected from you.
• Correction.  You can ask us to correct inaccurate personal data that we have collected about you.
• Opt-out of sales or sharing of personal information.  California residents can opt-out of any “sale” of their personal information or “sharing” of personal information for cross-contextual behavioral advertising as such terms are defined under the CCPA.  We do not sell or share personal information of applicants in the manner restricted by the CCPA and have not done so in the preceding 12 months. However, we encourage you to review our Privacy Policy for information covering the scenarios when you interact with us offline or online in the same manner that a website visitor or other non-candidate may interact with us. We do not recruit, and have no actual knowledge of having sold or shared the personal information in the past 12 months of, candidates under age 16.
• Nondiscrimination.  You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA, including exercising such rights without retaliation.

How to exercise your California privacy rights

You may submit requests to exercise your right to information, access, correction, or deletion by sending us an email at privacy@feedzai.com.

We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. We may need to verify your identity to process your information, access, deletion, and correction requests, and we reserve the right to confirm your current California residency. To verify your identity, we may require government identification, a declaration under penalty of perjury, or other information, where permitted by law.

Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent pursuant to California Probate Code Sections 4000-4465.  If you have not provided your agent with such a power of attorney, you must provide your agent with written and signed permission to exercise your CCPA rights on your behalf, provide the information we request to verify your identity, and provide us with confirmation that you have given the authorized agent permission to submit the request.

Third parties

This Policy does not address, and we are not responsible for, the practices of any third parties, which have their own rules for how they collect and use your personal information.  Our links to third party websites or services are not endorsements.

Changes to this Policy

We reserve the right to change this Policy at any time.  The “Effective Date” heading at the top of this Policy indicates when it was last revised.  Any changes will become effective when we post the revised notice on our Careers Website.

Your obligations

Apart from your obligation to provide complete and accurate information in the recruiting process, it is your responsibility to ensure that information you submit does not violate any third party’s rights.

You should keep your personal information up to date and inform us of any significant changes to it.