Demand Science, LLC and its operating groups, subsidiaries and divisions, along with its and their successors (“Company”) are committed to dealing responsibly with information we process (collect, use, and disclose) and hold about you.  The Company entity in the country in which you are applying (hereinafter “Demand Science”) is considered a data controller with respect to your Personal Data (as defined below).  We limit use of your Personal Data to managing recruitment and to ensure and monitor legal and regulatory compliance.  We work hard to ensure that your Personal Data is kept secure at all times, is provided only to those colleagues and third parties that have been properly informed to handle your Personal Data in accordance with all applicable privacy laws, and kept only as long as necessary for business or legal requirements.  At times, your Personal Data may be accessed by colleagues or third parties in a location outside your home country.  Regardless of location, Demand Science will ensure that safeguards are put in place to protect that Personal Data in accordance with all applicable privacy laws, including but not limited to the General Data Protection Regulation of the EU, as amended, and all the laws, regulations and collective agreements concerning data protection and labor law, in the countries, provinces and states in which it hires personnel and operates worldwide.

DATA PROCESSED, PURPOSES AND LEGAL GROUNDS 

“Personal Data” refers to any information related to a natural person (or “Data Subject”), that can be used to directly or indirectly identify the person.  Demand Science collects, processes and maintains the Personal Data of candidates for the purposes indicated below in parallel with the human resources activities as set forth below.  The Personal Data stored and processed will be used for management and administrative purposes.  Demand Science will store and use this information to enable it to carry out business activities and manage relationships with you effectively, lawfully and appropriately during the hiring process.  This includes the use of information to enable Demand Science to fulfill the obligations of the recruitment process as well as any legal requirements as well as also pursuing the legitimate interests of Demand Science and protecting its legal position in the event of a legal proceeding.

POSSIBLE LEGAL GROUNDSThis Policy

We will only process your Personal Data if there is a relevant legal ground. More concretely, we will mainly use the information because it is necessary to enable Demand Science to:

• perform the recruitment process, which may or may not include conclusion of an employment contract
• to comply with any legal requirements
• pursue the legitimate interests of Demand Science or those of a third party (e.g. protecting Demand Science’s legal position in the event of legal proceedings), insofar as your interests or fundamental rights and freedoms do not prevail. We will balance this case by case and will permanently monitor this

Besides those mentioned above, there are also some less common legal grounds based on which we may occasionally process your Personal Data, such as:

• your consent (which we will use only if strictly necessary in the context of the recruitment process, including but not limited to leading up to concluding an employment relationship);
• the necessity to protect your vital interests or those of another person, for example in case of a medical emergency;
• the necessity in matters of public interest or public authority that has been handed to us, for example the reporting of an alleged crime to the investigating authorities.

Occasionally we will also have to process sensitive data in the context of the recruitment process (e.g. health data such as information regarding work related disabilities etc.)^[1] in accordance with applicable law.

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The processing of these data is restricted and we will only do this in case it is:

• necessary for the purposes of carrying out the obligations and exercising specific rights of Demand Science or of yourself in the field of recruitment and social protection law;
• related to Personal Data which are manifestly made public by you;
• necessary for the establishment, exercise or defence of legal claims;
• necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, for medical diagnoses or the provision of health or social care or treatment (if applicable).

PROCESSED DATA AND THE RELATED PURPOSES AND LEGAL GROUNDS

Further information on the reasons for which we process your Personal Data is set out below. If you refuse to provide such data, Demand Science would find it impossible, under certain circumstances, to correctly perform the duties required, with all the implications arising from this decision. 

• Recruitment and Employment: Demand Science processes Personal Data of candidates such as name, contact details, level of education, language (or languages) and special skills related to the profession; information on certifications; previous jobs and work experience; information regarding assessments on personal background to the extent permitted by applicable laws and convictions or criminal offenses, where such information is relevant for the purposes of the specific position, to pursue the legitimate interest in hiring only the most qualified candidates. The processing of criminal records data together with Demand Science’s recruitment and human resources operations will be carried out under the control of the competent authority or when authorized by law. Demand Science may collect Personal Data concerning the employment of third parties, such as personnel selection companies, government authorities, former employers, or from the references provided. Demand Science may also collect Personal Data from publicly accessible sources, such as public and professional profiles on social media.
• Execution of the employment contract: Demand Science processes Personal Data regarding remuneration and benefits, terms and conditions of employment, position and duties, bank details relating to pay slips, type and duration of the employment as well as other information useful for realizing the terms of the employment contract. Demand Science may collect this information from third parties, such as suppliers specialized in the management of payroll, employment services and government authorities.
• Fulfillment of obligations in accordance with applicable law and collective agreements: Demand Science processes Personal Data relating to national and government identification documents; passport; date and place of birth; citizenship; visa; driver’s license; withholding taxes and other information useful for the fulfillment of its obligations in compliance with applicable laws and collective agreements. Demand Science may collect this information from third parties, such as government authorities, trade unions, works councils or other employee representatives.
• Management, planning and organization: Demand Science processes Personal Data concerning business qualifications; type or code of use; site or company location; working hours, general conditions of employment (full time, part-time, permanent or temporary); duties and obligations; skills assessments; professional goals; acceptance of labor policies; indicators to pursue legitimate interests in the management of work relationships in compliance with the legal obligations of the employer, as well as to administer the employment contract. If the legal regulations of reference require your explicit consent in advance, Demand Science will process these data only after obtaining the appropriate consent from you.
• Equality and Diversity: Demand Science processes Personal Data such as racial or ethnic origin, sex, any disability and other characteristics protected by law in compliance with specific obligations and rights in the field of labor law, social security and social protection, where such treatment is authorized or mandated by law, regulation, or a collective agreement, as well as to pursue the legitimate interests of Demand Science in maintaining a diversified working environment without undue discrimination and to administer the employment contract.
• Health and Safety: Demand Science processes Personal Data regarding medical-health pathologies, drug tests, health insurance for preventive medicine or work purposes, assessments of work capacity, diagnosis, assistance or health or social therapy, or management of systems and services – sanitary, as well as, where specifically required or permitted by law, results of drug tests or alcohol tests. This information is treated for the purpose of protecting your vital interests or those of others in compliance with the specific obligations and rights of the laws on employment, social security and social security where permitted by law. Furthermore, use of such information can be treated as a collective agreement and legal obligations to offer a safe working environment. Demand Science may collect this information from third parties, such as social security service providers and third party performance administrators or government authorities.
• Exercise and enjoyment of rights and benefits concerning employment: Demand Science processes Personal Data concerning marital status, family status, information on dependents and designation of beneficiaries for performance purposes; data relating to the leasing program for company vehicles and registers.
• Defense of a right in court: Demand Science processes Personal Data that is necessary for ascertaining, exercising or defending a right in court.

RECIPIENTS OF YOUR PERSONAL DATA

Your Personal Data will or may have to be disclosed to:

• The management, the human resources (HR) and IT (IT) personnel present in your potential workplace, who need to know your Personal Data as part of the business and management operations related to your hire.
• The management, HR and IT staff present at Demand Science’s headquarters in the US, who need to know your Personal Data as part of the business operations and administration related to your hire.
• Management, HR and IT staff present at Demand Science’s headquarters have implemented specific safeguards for the transfer of your Personal Data to the United States and other non-EU countries, as allowed through standard contractual clauses. Further information regarding the above safeguard measures can be obtained from [email protected].
• Third parties in charge of workforce planning and management, such as suppliers engaged to manage any of the items in processing (e.g., suppliers of pay slips and services, personal background checks, computer suppliers and internet services, governmental authorities and the like), who need to process your Personal Data regarding hiring at Demand Science as part of the business and administrative operations of your recruitment process. Currently these third parties are:

Third Party	Information	Purpose
Greenhouse Software, Inc.	www.greenhouse.io/privacy-policy	Global recruitment system SaaS

You will be informed of any changes to third-party providers. If the aforementioned third parties in charge of processing are located in countries outside the EU, Demand Science has implemented specific safeguards for the transfer of its Personal Data in these countries through standard contractual clauses. Further information regarding these safeguards can be obtained from your HR representative.

• Furthermore, Demand Science may be required to disclose Personal Data in response to legal requests from public authorities to comply with national security or law enforcement requirements.

RETENTION OF YOUR PERSONAL DATA

Demand Science and any third party in charge of processing will store your Personal Data for: (1) the period of time necessary for the processing of Personal Data for the purposes for which they were obtained and processed, (2) the period required pursuant to the regulations on the conservation of archives, (3) the statute of limitations envisaged for labor disputes, or (4) the period of time necessary to ascertain, exercise or defend a right in court.

AUTOMATED DECISION-MAKING

Automated decisions are defined as decisions about individuals that are based solely on the automated processing of data and that produce legal effects or that significantly affect the individuals involved.

As a rule, we do not make use of automated decision-making as described above. If you are a prospective employee, we do not base our decision whether or not to hire you solely on automated processing of your Personal Data.

RIGHTS RELATED TO YOUR PERSONAL DATA

As an interested party and in relation to your Personal Data, you have the following rights:

• Right of Access: You have the right to obtain confirmation from Demand Science that your Personal Data is being processed. You also have the right to obtain the following information, provided such Personal Data does not infringe the rights and freedoms of others: (1) purpose of processing, (2) categories of the Personal Data in question, (3) any recipients or categories of recipients your Personal Data have been or will be disclosed, (4) period of retention of your Personal Data provided, (5) the right to request the rectification or cancellation of your Personal Data, (6) the right to file a complaint with a supervisory authority, (7) the source from which your Personal Data was obtained if you did not provide, (8) the existence of any automated decision-making process, including profiling and the logic used in that process decision-making, as well as the importance and expected consequences of such processing, and (9) the country to which Personal Data is transferred, in the case of a third country. Demand Science will provide a copy of the Personal Data processed in an electronic format of common use which you can access electronically.
• Right of Rectification: You have the right to request and obtain the rectification of inaccurate Personal Data and the integration of incomplete Personal Data, also by providing a supplementary declaration. Demand Science will notify all recipients of its Personal Data of the rectification, unless this involves a disproportionate effort. Demand Science will inform you of these recipients at your request.
• Right to Deletion (Right to be Forgotten): You have the right to request and obtain the deletion of your Personal Data in the following cases: (1) Personal Data are no longer necessary with respect to the purposes for which they were collected or otherwise processed, (2) You revoke your consent to all processing for which you had previously expressed specific consent, (3) You object to the processing of Personal Data on the legitimate interest of Demand Science and there is found to be no legitimate reason prevailing for the processing, (4) your Personal Data has not been processed lawfully, or (5) the deletion of Personal Data is required based on Demand Science’s legal obligation to delete Personal Data. However, the right to deletion does not apply to the extent that the processing is necessary (1) for the exercise of the right to freedom of expression and information, (2) for the fulfillment of a legal obligation of Demand Science which requires the processing of Your Personal Data, (3) for reasons of public interest in the field of public health, or (4) for the establishment, exercise or defense of a right in court. Demand Science will notify you of all recipients of Personal Data concerning the deletion, unless this involves a disproportionate effort. Demand Science will inform you of these recipients at your request.
• Right to Treatment Limitation: You have the right to obtain limitation of the processing of your Personal Data in the following cases: (1) for the period of time necessary for Demand Science to verify the accuracy of your Personal Data, if you dispute the accuracy, (2) the processing is unlawful and you object to the deletion of Personal Data, (3) Demand Science no longer needs Personal Data for the reasons for which it was processed, but you require Demand Science to keep the information for ascertaining, exercising and defending a right in court, (4) You are opposed to a legitimate interest of Demand Science in the processing of data and, therefore, while waiting for Demand Science to determine if the legitimate interest prevails over your right to privacy. During the period in which the limitation is in place, Demand Science will retain and process such Personal Data with your consent, to ascertain, exercise or defend a right in court, to protect the rights of others or for reasons of significant public interest. Furthermore, Demand Science will give you prior notice in the event of revocation of the limitation. Demand Science will notify this limitation to all recipients of your Personal Data, unless this involves a disproportionate effort. Demand Science will inform you of these recipients at your request.
• Right to Portability: You have the right to receive the Personal Data provided by you to Demand Science and to forward them to another data controller where the processing of such Personal Data is based on consent or a contract and is processed in an automated manner. You also have the right to request Demand Science to transmit such Personal Data directly to another data controller, if technically feasible. This right is not applicable if it violates the rights and freedoms of others.
• Right of Opposition: You have the right to object to the processing of your Personal Data if it is based on the legitimate interest of Demand Science, including any profiling based on such processing. Demand Science will refrain from processing the aforementioned Personal Data, except to prove the existence of legitimate cogent reasons that prevail over your interests, rights and freedoms, or the continuous processing is necessary for ascertaining, exercising and defending a right in court.
• Right to not be subjected to automated decision-making, including profiling: You have the right not to be subjected to a decision based solely on automated processing, including profiling, which produces legal effects that affect you or that significantly affect your person. However, this right does not apply if the decision is necessary for the conclusion or execution of a contract between you and Demand Science, is authorized by the regulations in force or is based on your explicit consent. If it is based on consent or a contract, Demand Science will provide a person to whom it can express its opinion and contest the decision.

QUESTIONS AND CLAIMS

Demand Science Group, LLC

Data Protection Officer
222 Rosewood Drive
Danvers, MA 01923

1-978-887-0010

[email protected]

Employees in the countries identified below also have the right to file a complaint with the authority and/or commission appointed or designated for the protection of Personal Data based in:

Australia:  https://www.oaic.gov.au/privacy/privacy-complaints/

Ireland:  https://www.dataprotection.ie/

Philippines: https://www.privacy.gov.ph/citizens-charter/filing-a-complaint/

The United Kingdom:  https://ico.org.uk/

The United States:  applicable State Attorney General’s office

If in the future the Company intends to process your Personal Data for purposes other than those for which they were obtained, it will provide you with information regarding this purpose and any other relevant information.