Recruiting Privacy Policy

1. Introduction

At Turnkey Labs we prioritise your privacy and are committed to the protection of personal data. This Recruiting Privacy Policy (the “Policy”) explains how we process personal data during our recruitment processes in compliance with the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), Brazilian General Data Protection Law (LGPD), Federal Law on the Protection of Personal Data Held by Private Parties, Mexico (LFPDPPP) and other applicable data protection laws.

This Policy applies to all candidates applying for a position at Turnkey Labs. We created this Policy using straightforward and clear language, ensuring our privacy principles are both transparent and easily understood. Our goal is to give you all the necessary information to be well informed about your personal information safety measures. If you have any questions regarding this Policy, please contact us at: legal@turnkeystaffing.com.

2. Data controller

TurnKey Labs is the controller of the personal data of prospective employees and contractors, and is subject to applicable data protection laws.

3. Lawful basis for processing

We collect and process your information where it is necessary in order to take steps prior to potentially entering into a contract or employment with you.

We may also seek your consent to process your personal information in specific circumstances or process it where necessary to comply with a legal obligation or for purposes connected to legal claims. If we use your information to improve our application or recruitment process, we do so on the basis that it is in our legitimate interests to ensure we recruit the best possible candidates.

4. Purposes of processing

We use your personal data for the purpose of evaluating candidates for employment and/or cooperation, and to fulfill our legal or regulatory obligations 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 open positions.

List of Sub-Processors

The controller has authorised the use of the sub-processors listed at https://turnkeystaffing.com/sub-processor-list/

5. What personal data we collect

Personal data you give us

You may give us personal data about you by filling in forms online, corresponding with us by phone, email, in person, or otherwise, or through another third party.

Personal data we collect

The personal data that we collect about you includes, but is not limited to, the following:

• Your full name;
• Home/Legal address;
• Contact details (telephone number, email address, etc.);
• Date of birth;
• Gender;
• Your image and/or recording of you;
• Copies of your passport, ID documents;
• Education history;
• Current and past employment history;
• Immigration status and current work permits;
• Languages spoken and level of proficiency;
• Criminal record information;
• Information required to prepare the employment or any relevant contract;
• Other information given in your CV;
• Interview notes and recordings.

Personal data collected from third-party sources

In some cases, we may collect personal data about you from third parties, including:

• TurnKey employees, contractors, vendors, who refer you for the open positions at TurnKey;
• Your named referees who you’ve asked to provide us with references;
• Where allowed by law, third-party background screening providers, sanction screening and criminal convictions screening agencies;
• Where allowed by law, other publicly available sources, such as social media networking sites (such as LinkedIn, Instagram, Twitter).

6. Consent to Record Interviews

During the recruitment process, we might record job interviews for evaluation purposes. By participating in such interviews:

• You expressly consent to the recording of the interview;
• You acknowledge that the recordings will be used exclusively for recruitment purposes;
• You have the right to request access, rectification, or erasure of the recording.

7. Data Retention

We retain personal data for as long as necessary to fulfil the purposes outlined in this Policy unless otherwise required by law. We will only keep your personal data for as long as it is necessary for the purposes set out in this privacy notice unless a longer retention period is required or permitted by law.

When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymize such data, or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.

8. Data Security

We implement appropriate technical and organisational measures to safeguard your personal data against accidental loss, destruction, or damage.

9. Your Rights under applicable privacy laws

Under applicable privacy laws, including, but not limited to the GDPR, Brazil’s LGPD, and Mexico’s LFPDPPP, you have the right to:

• Request access to your personal data;
• Request correction of your personal data;
• Request erasure of your personal data;
• Object to the processing of your personal data;
• Request restriction of processing your personal data;
• Request the transfer of your personal data;
• Withdraw consent where we rely on consent to process your personal data;
• Request information on entities with whom your data has been shared (according to LFPDPPP in Mexico);
• Be informed about the possibility of not providing consent and the consequences of such refusal (as per LGPD requirements).

10. CCPA Notice for California Residents

If you are a resident of the State of California, the following additional provisions apply to you in accordance with the California Consumer Privacy Act (CCPA):

a. Categories of Personal Information

Under the CCPA, personal information is classified into categories. During our recruitment process, we may collect:

• Identifiers: This includes your full name, home/legal address, telephone number, email address, and IP address.
• Professional or Employment-Related Information: We may collect details such as your employment history, current and past job roles, CV, cover letter, and additional employment-related information.
• Education Information: This encompasses degrees, certifications, qualifications, and school records.

Additional Identifiers and Personal Information:

• Date of birth
• Gender
• Image and/or any recordings of you, where applicable
• Copies of passport, ID, or similar identification documents
• Education and training history
• Immigration status and any relevant work permits
• Languages spoken and levels of proficiency
• Criminal record information, as permitted by law
• Information Required for Contract Preparation: Details necessary for drafting employment or other relevant agreements
• Other Information Provided in Your Application
• Any other data included in your CV or application documents
• Interview notes and recordings collected during the recruitment process

b. Use of Personal Information

We collect and use the above categories of personal information for business purposes, including evaluating candidates for potential employment or business cooperation, ensuring compliance with legal requirements, and maintaining records related to the recruitment process.

c. Your CCPA Rights

As a California resident, you have the right to:

• Know: Request disclosure of the personal information we collect, use, and disclose about you.
• Delete: Request the deletion of your personal information stored by us, subject to certain exceptions.
• Non-discrimination: Exercise your CCPA rights without being denied goods or services, being charged different prices or rates, receiving a lower quality of goods or services, or being suggested that you will receive a different rate or level of quality of goods or services.

d. Exercising Your Rights

To exercise any of the above rights, please contact us at legal@turnkey-labs.com. Verification of your identity may be required before processing your request.

11. Data Sharing and Transfers

We might share your personal data with our employees, contractors, affiliates, trusted third parties relevant to the recruitment process, such as professional advisors (including lawyers, accountants and auditors), third party service providers, including our data hosting service provider, background screening check provider or if we are under a duty to disclose or share your personal data in order to comply with any legal obligation. Any transfers of data will be conducted in line with GDPR or any other applicable requirements.

Affiliated company (affiliate) means our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

12. International Transferring of Data

Your personal data will be stored on servers located in the United States, UK or EEA. As a U.S. company, we may transfer, store, and process your information in countries where our employees, contractors, affiliates, and third parties responsible for data processing are located. We will take all reasonable steps to ensure that such transfers are conducted in compliance with applicable data protection laws and that adequate safeguards are in place to protect the privacy and security of your information during such international transfers.

13. Changes to this Policy

We will update this notice as necessary to stay compliant with relevant laws. Should significant modifications occur in this privacy notice, we will inform you either by displaying a noticeable announcement or through direct communication.

14. Contact Us

As we are the “data controller” of your personal information, we have appointed our Legal Department to be our representative according to GDPR rules. If required and applicable, we will also appoint a Data Protection Officer or an EU-based representative to ensure stringent adherence to GDPR regulations.

You have the right to contact us as your personal information data controller. For any questions or concerns regarding this Policy or our data practices, please contact us at legal[@]turnkeystaffing.com