Contents
1. Scope and Overview
2. Application
3. Collection of Your Personal Information
4. Use of Your Personal Information
5. Personal Information Sharing
6. Cross-Border Data Transfers
7. Personal Information Security
8. Personal Information Retention
9. Your Rights
10. Data Privacy Officer
11. Changes to this Privacy Policy
12. Contact Us
1. Scope and Overview
Sharethrough is committed to protecting the privacy and security of your Personal Information (defined below). This Privacy Policy describes how Sharethrough Inc. and its subsidiaries, affiliates, and related entities (collectively, “Sharethrough,” “we,” or “us“) collect and use Personal Information about you during the employment application and recruitment process.
For clarity, Personal Information refers to any information that directly or indirectly identifies you (such as your name, email address, contact information, resume, and any other information you disclose to us in the employment process). Personal Information as referred to in this policy includes the definitions of “Personal Data” and “Personally Identifiable Information,” (collectively “Personal Information,”) as defined by applicable privacy laws applicable in all jurisdictions where Sharethrough operates.
2. Application
This Privacy Policy applies only to job applicants (not Sharethrough’s current employees) worldwide, including those candidates located in Canada, the United Kingdom (“UK”), within Europe, the United States, and other global regions in accordance with applicable privacy laws.
This Privacy Policy describes the categories of Personal Information that we collect, how we use your Personal Information, how we secure your Personal Information, when we may disclose your Personal Information to third parties, and when we may transfer your Personal Information outside of your home jurisdiction. This Privacy Policy also describes your rights regarding the Personal Information that we hold about you and how you can access, correct, and request erasure of your Personal Information.
We will only use your Personal Information in accordance with this Privacy Policy unless otherwise required by applicable law. We take steps to ensure that the Personal Information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.
3. Collection of Personal Information
Sharethrough may collect Personal Information directly from you, as a job applicant, or may receive Personal Information from third parties, for example, in connection with a background, employment, or reference verification, subject to your consent where required by law (e.g., Linkedin). We may collect, store, and use the following non- exhaustive categories of Personal Information in connection with our recruiting activities:
- Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses;
- Work history and other relevant experience including information contained in a resume, CV, cover letter, or job application;
- Education information including degrees awarded, transcripts, and other information provided in support of the job application;
- Compensation history;
- Information collected during phone screenings and interviews;
- Details regarding the type of employment sought, desired salary, willingness to relocate, job preferences, and other information related to compensation and benefits;
- Reference information and information received from background and reference verifications, where applicable, including information provided by third parties;
- Information related to previous applications to Sharethrough or previous employment history with Sharethrough.
4. Use of Your Personal Information
We may use your Personal Information for the following legitimate business purposes:
- Identifying and evaluating your job application, including assessing skills, qualifications, and interests;
- Verifying your information and carrying out employment, background, and reference verifications, where applicable, subject to your consent;
- Communicating with you about the recruitment process and your application;
- Keeping records related to our hiring processes;
- Creating and submitting reports as required by applicable laws or regulations;
- To comply with our legal, regulatory, or other corporate governance requirements;
- Analyzing and improving our application and recruitment process;
- Complying with applicable laws, regulations, legal processes, or enforceable government requests;
- To protect the rights and property of Sharethrough, other job applicants, employees, or the public, as required or permitted by law.
In addition to using your Personal Information for the position for which you have applied, we may retain and use your Personal Information to inform you about and consider you for other positions that may be appropriate for you in accordance with our document retention policy. If you do not want to be considered for other positions or would like us to remove your Personal Information, you may contact us as specified below under Contact Us.
We only use your Personal Information where applicable law permits or requires it in connection with carrying out our application and recruitment process. We will only use your Personal Information for the purposes we collected it for. If we need to use your Personal Information for an unrelated purpose, we will provide notice to you and, if required by law, seek your consent.
5. Personal Information Sharing
We will only disclose your Personal Information to third parties where required by law or to our employees, contractors, designated agents, or third-party service providers who require it to assist us with administering the recruitment process, including third-party service providers who provide services to us or on our behalf. We may use third-party service providers for various purposes, including, but not limited to, obtaining employment verification and background checks.
We may also disclose your Personal Information for the following additional purposes where permitted or required by applicable law:
- To other members of our group of companies (including outside of your home jurisdiction) for the purposes set out in this Privacy Policy and as necessary to administer the application and recruitment process;
- As part of our regular reporting activities to other members of our group of companies;
- To comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders. When we disclose your Personal Information to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum Personal Information necessary for the specific purpose and circumstances;
- During emergency situations or where necessary to protect the safety of persons;
- Where the Personal Information is publicly available;
- If a business transfer or change in ownership occurs;
- For additional purposes with your consent where such consent is required by law.
6. Cross-Border Transfers
Sharethrough is a global company. Where applicable law permits, we may transfer the Personal Information we collect about you to jurisdictions outside your home country. If we transfer your Personal data outside of your home country, we will ensure we take the appropriate measures to ensure your information is transferred in a secure manner. These measures are subject to the legal requirements of the jurisdictions to which we transfer Personal Information, including lawful requirements to disclose information to law enforcement and government agencies in those countries.
European Data Protection Regulations
We ensure any international transfers of your Personal data are compliant with the laws of that region, including the European General Data Protection Regulation (the “GDPR”). Specifically, with respect to the European Economic Area (“EEA”), we ensure appropriate legal protections are in place if we transfer your Personal data outside of the EEA to the United Kingdom (“UK”), Switzerland, or any other country, as provided for under European data protection legislation.
These protections include using technical security measures or a legal mechanism, such as, but not limited to, the Standard Contractual Clauses (“SCC”), which are approved by the European Commission. The SCCs standardize the protections for any international transfers of your data from the EEA to other countries, thus providing you with assurance that you will be able to access your rights for the protection of Personal data in a manner consistent with European data protection law.
7. Personal Information Security
We have implemented appropriate physical, technical, and organizational security measures designed to secure your Personal Information against accidental loss and unauthorized access, use, alteration, or disclosure. In addition, we limit Personal Information access to those employees, agents, contractors, and other third parties that have a legitimate business need for such access.
8. Personal Information Retention
Except as otherwise permitted or required by applicable law or regulation, we will retain your Personal Information for up to three (3) years following the completion of the hiring process, or for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, tax, accounting or reporting requirements. This allows you to inquire about our hiring process should you wish to do so. Under some circumstances we may anonymize your Personal Information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
If you are offered and accept employment with Sharethrough, the Personal Information we collect during the application and recruitment process will become part of your employment record, and we may use it in connection with your employment consistent with our employee Personal Information policies.
If you do not become an employee, or, once you are no longer an employee of Sharethrough, we will retain and securely destroy your Personal Information in accordance with our document retention policy and applicable laws and regulations.
Except as otherwise permitted or required by applicable law or regulation, we will retain your Personal Information for up to three (3) years following the completion of the hiring process, or for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, tax, accounting or reporting requirements. This allows you to inquire about our hiring process should you wish to do so. Under some circumstances we may anonymize your Personal Information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
If you are offered and accept employment with Sharethrough, the Personal Information we collect during the application and recruitment process will become part of your employment record, and we may use it in connection with your employment consistent with our employee Personal Information policies.
If you do not become an employee, or, once you are no longer an employee of Sharethrough, we will retain and securely destroy your Personal Information in accordance with our document retention policy and applicable laws and regulations.
9. Your Rights
I. Rights of Access, Correction, Erasure, and Objection
It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during the recruitment process. By law you have the right to request access to and to correct the Personal Information that we hold about you, or withdraw your consent to the use of your Personal Information under certain circumstances. If you want to review, verify, correct, or withdraw consent to the use of your Personal Information, please Contact Us. Any such communication must be in writing.
We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the Personal Information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the Personal Information that we hold about you, or we may have destroyed, erased, or made your Personal Information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your Personal Information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
II. Right to Lodge a Complaint
Sharethrough complies with our obligations under European privacy laws and makes every effort to ensure your rights are protected and respected. If you have any questions or complaints regarding our Data processing, please Contact Us directly, or through our Data Protection Officer (DPO).
You have a right to lodge a complaint with your local Data Protection Supervisory Authority if you wish to dispute the way we Access your Data. Please see the contact details of supervisory authorities below:
i. EU Data Protection Authorities
ii. The Swiss Data Protection Authority
iii. UK Information Commissioner’s Office
III. Right to Withdraw Consent
Where you have provided your consent to the collection, use, and transfer of your Personal Information, you have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at dataprotection@sharethrough.com.
10. Data Privacy Officer (DPO)
We have appointed a Data Privacy Officer to oversee compliance with this Privacy Policy. If you have any questions about this Privacy Policy or how we handle your Personal Information, or would like to request access to your Personal Information, please contact the Data Privacy Officer as per the Contact Us section below.
11. Changes to This Privacy Policy
We may change this Privacy Policy to accommodate new technologies, regulatory requirements, or for other purposes. If we make material changes to this Privacy Policy, we will post the revised version on our website and may take additional measures to inform you, as required by applicable data protection laws. The date at the top of this Privacy Policy reflects the most recent changes made to this Privacy Policy.
12. Contact Us
To Contact Sharethrough (Controller)
Sharethrough
5455 Gaspe Avenue, Suite 730
Montreal, Quebec, H2T 3B3
Canada
Attn: Legal & Compliance Team
Email: dataprotection@sharethrough.com
To Contact our Data Protection Officer
Chantal Bernier
99 Bank Street
Suite 1420
Ottawa, Ontario K1P 1H4
Canada
+1 (613) 783-9600
Email: chantal.bernier@dentons.com
To Contact our local EU Representative
Legal Army c/o Sharethrough Inc.
Enrique Extremera Maestro
C. de la Princesa, 31,
Moncloa – Aravaca,
Madrid, Spain, 28008
Email: dpo@sharethrough.com