Global Applicant Privacy Notice

Certain jurisdictions require that we provide you this notice about the collection and use of your personal information.  We encourage you to read it carefully.

Effective Date: August 1st, 2024

1. Introduction

   This notice (“Notice”) describes how Wurl, LLC (“Company”, “Wurl”, “we”, “us” and “our”) collects, uses, shares, and otherwise processes personal information about applicants who apply for a job with Wurl or join our Talent Community to be considered for future jobs that become available.
   
   This Notice does not create or form part of any employment contract.

2. Information we collect about applicants
   1. Categories of personal information
      The categories of personal information we may collect and process before, during and after your employment include:
      • Contact information, such as your work and home address, telephone number, email address and social media handles;
      • Information from job application materials or recruiters, such as your job application, resume or CV, cover letter, writing samples, references, work history, whether you are subject to prior employer obligations, and information that referrers provide about you;
      • Professional qualifications, such as 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;
      • Biographical information, such as name, gender, date of birth, professional history, references, language proficiencies, education details, and information you make publicly available through job search or career networking sites;
      • Job preferences, such as desired position and compensation, location preferences and willingness to relocate;
      • Employment history;
      • Background check information, such as information necessary to complete background, credit, drug/alcohol and/or other checks when permitted by law, and information received during these checks; and
      • Other information you provide to us. 
        In some circumstances and consistent with applicable law, we may collect or allow you to provide voluntarily certain “Equal Opportunity information” or “sensitive personal information” due to legal requirements, for other legitimate recruitment purposes, or for reporting purposes, including:
      • Social Security Number, driver’s license number, or state identification card;
      • Racial or ethnic origin;     
      • Preferred pronouns; 
      • Criminal history data; and
      • Information needed to understand and assess accommodation requests regarding potential disabilities or other health conditions.
        References in this Notice to “personal information” include “sensitive personal information”. 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 will do so only where permitted by applicable law. 
   2. 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 or other publicly-available sources;
      • Online activity information that we and our service providers collect using server logs, “cookies” and similar technologies on the Careers Site. Please see https://www.wurl.com/privacy-notice/ and Wurl’s website cookie banner for more information; and 
      • Other Company personnel.
3. How we use personal information about applicants
   1. 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 https://www.wurl.com/careers/ or any other site to which this Notice is posted (“Careers Site”);
        • recruiting, interviewing and evaluating job applicants;
        • 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 candidacy, opportunities with the Company or about the Careers Site and any changes to applicable terms or policies; and
        • other business operations.
      • Compliance, safety and fraud prevention, such as:
        • complying with or monitoring compliance with legal and other requirements, such as reporting 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;
        • investigating and deterring against fraudulent, harmful, unauthorized, unethical or illegal activity, or conduct in violation of our policies or procedures; and
        • sharing information with 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 share to analyze our application and recruitment activities, business and for other lawful business purposes.
   2. Lawful basis for processing your personal information
      
      If applicable law requires a lawful basis for processing, our lawful basis for collecting and using the personal information described in this Notice will depend on the type of personal information concerned and the specific context in which we collect or use it. Depending on the jurisdiction in which you live, there may be other applicable lawful bases for processing your personal information that are not listed here.
      
      We normally collect or use personal information from you or others where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms (e.g., to communicate with you, to evaluate your application, to manage our recruitment processes efficiently and fairly), or where applicable, where we have obtained your consent to process for a specific purpose. In certain situations, we may have a legal obligation to collect or retain personal information (e.g., to comply with applicable employment and works council laws and regulations) or need the personal information to protect your vital interests or those of another person. 
      
      When we process sensitive personal information about you, we will make sure that one or more of the lawful bases for processing sensitive personal information, as referenced above, applies. 
      
      If you have questions about or need further information concerning the lawful bases on which we collect, use, store, or otherwise process your personal information, please contact us at [email protected]. 
      
   3. Sharing personal information
      
      We may share your personal information with other parties as necessary for the purposes described above. For example, we may share your personal information with:
      • Affiliates. Our corporate parent, subsidiaries, and other affiliates under the control of our corporate parent, for purposes consistent with this Notice or to operate shared infrastructure, systems and technology.
      • Company service providers. Companies that provide us with services that help us manage the recruiting process and operate our business, such as job boards, recruiters, interviewing and testing, pre-employment screening, interview travel booking and expense reimbursement (where applicable), relocation (where applicable), and recruitment analytics.
      • Government authorities, law enforcement and others. Government authorities, law enforcement, courts, and others as described in the compliance, safety and fraud prevention section above.
      • Business transfers. Parties to transactions and potential transactions whereby we sell, transfer or otherwise share 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.
      • Professional advisors. Lawyers, immigration advisors, and other outside professional advisors.Wurl does not “sell” to third parties, or “share” with third parties for targeted advertising purposes, the personal information that it collects or processes as part of the recruitment process, nor have we done so in the preceding 12 months (including as those terms are defined under the California Consumer Privacy Act).
   4. International transfers of personal information
      
      Wurl is headquartered in California, and in most cases, we need to securely transfer and store your personal information to the United States. All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your personal information consistent with the requirements of applicable laws. If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses. In certain situations, Wurl may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. For more information about the safeguards we use for international transfers of your personal information, please contact us at [email protected].     
      
4. Your obligations
   
   Among other obligations, including without limitation the obligation to provide complete and accurate information in recruiting documents and processes, it is your responsibility to ensure that information you submit does not violate any third party’s rights. You should keep your personal information on file with the Company up to date and inform us of any significant changes to it.
   
5. Your Privacy Rights
   
   Under applicable law, you may have the following rights regarding personal information that we collect about you in relation to your candidacy with Wurl:
   • You have the right to request that we disclose to you the personal information we collect, use, or disclose, and information about our data practices;
   • You have the right to access the personal information we collect, use, or disclose about you; 
   • You have a right to request that we correct inaccurate personal information maintained about you; 
   • In certain situations, you can ask that we erase your personal information, object to or restrict the use of your personal information, or export your personal information to another controller; and
   • You have a right to non-discrimination against you for exercising any of these rights.To protect your information and the integrity of your personal information, we may need to verify your identity before processing your request. In some cases we may need to collect additional information to verify your identity, such as a government-issued ID.
     
     Some laws allow you to designate an authorized agent to make these requests on your behalf. Please note, we will request your authorized agent to provide a signed permission from you as proof that they are authorized to submit the request on your behalf. We may also request that you verify your own identity with us directly or confirm directly with us that you provided the authorized agent permission to submit the request.
     
     To exercise any of your rights under applicable law, please contact us at [email protected].
6. Retention
   
   We will store the personal information we collect about you for no longer than necessary and in accordance with our legal obligations and our legitimate interests.
   
   If your application is successful and you become an employee, where permitted by local law, the personal information we collect during the application process may be transferred to your personnel file and stored in accordance with our Worldwide Employee Data Protection Policy, which will be made available to you at the start of your employment with us.
   
   If your application is not successful, your personal data will be kept for the duration of the application process, plus a reasonable period of time after confirmation that your application was unsuccessful to allow us to record the reasons for our decision in relation to your application (including so that we can exercise, establish, or defend any legal claims). Where permitted by local law, we may also retain your personal data for up to 24 months to consider you for other relevant employment opportunities, unless you request that we delete your application. To request the deletion of your application, please email [email protected].   
    
7. Data Security
   
   We maintain appropriate technical and organizational measures to protect the confidentiality of your personal data, including security measures to protect against unlawful or unauthorized processing of personal data, and against the accidental loss of, or damage to, your personal data.
   
8. Other information about this Notice
   1. Third parties
      This Notice 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. 
   2. Changes to this Notice
      We reserve the right to change this Notice at any time.  The “Effective Date” heading at the top of this Notice indicates when it was last revised.  Any changes will become effective when we post the revised notice on our Careers Site.
9. Children
   The Careers Site may not be used by individuals under the age of 18.
   
   If you have questions about this Notice, please contact [email protected].