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Last updated: October 8, 2025

Emplifi Recruitment Privacy Statement

Emplifi believes strongly in protecting the privacy of the personal data you provide to us. We also acknowledge that it is important to inform you about how we use your personal data. This Emplifi recruitment privacy statement (“Privacy Statement“) explains how Emplifi may process your personal data for recruitment purposes and the rights you have with respect to such processing. We encourage you to read this Privacy Statement carefully.

Scope of this Privacy Statement

This Privacy Statement applies to all personal data of job applicants processed by any Emplifi Group company which offers a job position to the job applicants; such employer company is the data controller with respect to the personal data of job applicants. Emplifi Group, for the purposes of this Privacy Statement, represents the following companies:

  • Emplifi Inc., with its registered office at 4200 Regent Street, Suite 200, Columbus, OH 43219, United States;
  • Emplifi Czech Republic a.s., with its registered office at Plzeň, Pod Všemi svatými 427/17, Severní Předměstí, 301 00, Czech Republic;
  • Emplifi Canada Inc., 3 Place Ville Marie, bureau 400, Montreal, QC H3B 2E3, Canada;
  • SYM-SYS Ltd. (trading as ‘Go Instore’), with its registered office at WA14 2DT Altrincham, Cheshire, 3rd Floor 1 Ashley Road, United Kingdom, ID No. 06069868;
  • Pixlee TurnTo, Inc., with its registered office at 4200 Regent Street, Suite 200, Columbus, OH 43219, United States;;
  • Astute Solutions (Australia) PTY LTD, with its registered office at Level 10, 530 Collins Street, Melbourne, VIC 3000, Australia , ID No. 14160077261;
  • Pixlee TurnTo Ltd., with its registered office at WA14 2DT Altrincham, Cheshire, 3rd Floor 1 Ashley Road, United Kingdom, ID No. 06069868;
  • Socialbakers UK Limited, with its registered office at WA14 2DT Altrincham, Cheshire, 3rd Floor 1 Ashley Road, United Kingdom, ID No. 06069868;
  • Socialbakers France, with its registered office at 8 rue d’Athènes, 75009 Paris, France, ID No. 804803427;
  • Socialbakers Germany GmbH, with its registered office at Amelia-Mary-Earhart Straße 8, 60549, Frankfurt am Main, Germany, ID No. HRB 98478;
  • Socialbakers Singapore Pte. Ltd., with its registered office at 16 Raffles Quay, #33-03, Hong Leong Building, Singapore 048581, ID No. 201326967M;
  • (any of the companies above hereinafter as “Emplifi”).

Type of personal data we collect

When you interact with Emplifi in connection with the recruitment process, we may ask you to provide or receive certain personal data, including, but not limited to:

  • personal data allowing identification of the candidate: first name, surname, address and country of residence, email address, telephone number;
  • personal data allowing the verification of the eligibility and selection criteria as laid down in the job opportunity notices: your CV and individual information regarding education and training (diploma awarded), professional experience (job title, length, previous company names, main tasks and responsibilities), linguistic and job-related skills and competencies and areas of interest, work and residence permits, link to your LinkedIn or another social media profile or portfolio, the content of any messages sent via the application form and, to the extent required or permitted by applicable law, identification data necessary in order to perform the background checks (first name, surname, email address) and reports of such background checks (including reports of criminal felony and misdemeanor registers, OFAC lists, social security number history, reports of driving history, confirmation of highest degree of education and employment history up to 2 previous employers) (“Personal Data”).

The exact scope of Personal Data processed in connection with recruitment for a specific position will depend on the type of position offered and on the market practice and local law requirements applicable to the recruiting Emplifi Group employer company.

How we process your Personal Data and for what purposes

Emplifi collects Personal Data directly from you or from our collaborating partners depending on the type of recruitment. Emplifi may process and store your Personal Data either manually, digitally, or by other means.
We process your Personal Data for the purposes of processing your job application. In the EU and UK, our legal basis is our legitimate interest in hiring suitable candidates. We have carried out a balancing test to ensure these interests are not overridden by your rights. Where you consent to join our talent pool and be informed of future job opportunities at Emplifi, the legal basis is your explicit consent. In Canada, we rely on consent (express or implied) where permissible under PIPEDA and applicable provincial laws. In the United States, we process personal information to evaluate candidates and comply with equal employment and recordkeeping obligations.

Third parties

Your Personal Data may be processed and stored by Emplifi’s trusted third party suppliers involved in providing software programs, tools and related services for the recruitment process. Any other disclosures to third parties will only be made when required by applicable law.

Emplifi requires these third parties to provide at least a comparable level of protection to your Personal Data as Emplifi provides, to keep your Personal Data confidential, to only process your Personal Data for the purposes for which it was disclosed and to only access the minimum amount of Personal Data they need to deliver specific services related to the recruitment process. All third party supports act as processors under written contracts. Personal data may be transferred outside your country. Where such transfers occur from the EU, UK or Canada, we use appropriate safeguards such as the EU-U.S. Data Privacy Framework, the UK Extension, or Standard Contractual Clauses, along with supplementary measures as required

List of third party suppliers:

  • Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA and its respective affiliates, used in particular as e-mail client and as document storage;
  • Greenhouse Software, Inc., 18 West 18th Street, 11th Fl., New York, NY 10011 USA, supplier of applicant tracking and recruiting software;
  • Certn 1006 Fort St, Victoria, BC V8V 3K4, Canada, provider of background check services;
  • LMC s.r.o., Jankovcova 1569/2c, 17000 Prague 7, Czech Republic, provider of job-offering and job-searching platforms.

Apart from the third-party suppliers, your Personal Data may be shared with:

  • Other Emplifi Group companies (please see the full list above in section Scope of this Privacy Statement) if you have provided your consent with such sharing for the purposes of receiving notifications about future job opportunities at Emplifi Group.
  • Emplifi Companies. as the data processors for other Emplifi Group entities where another is the data controller.

Data Retention

Emplifi will take reasonable steps to ensure that we retain your Personal Data only for so long as is necessary for the purpose for which it was collected, or for such time period provided in your consent.

By submitting the application form, you acknowledge that Emplifi may store and process your Personal Data for the duration of the recruitment process, and your Personal Data will be deleted without delay after completion of the recruitment process, unless a longer storage period is required or permitted by law (for example, if you become an employee of Emplifi or for the purposes of our defense against legal claims). Typical retention periods are therefore:

  • EU/UK: Unsuccessful applications are retained for up to 24 months after the recruitment process ends, to defend against potential legal claims (e.g. discrimination, unfair hiring).
  • Canada: Candidate data is retained only as long as necessary to complete recruitment and to comply with applicable employment and record-keeping obligations.
  • U.S.: Candidate data is typically retained for 1–2 years in line with EEO, OFCCP, and applicable state requirements.
  • Talent Pool: If you consent to join our talent pool, we retain your data for up to 3 years to contact you about future opportunities, after which we may ask you to renew your consent.

You may withdraw consent or request deletion at any time by emailing hrdataprivacy@emplifi.io.

Data Security

Emplifi recognizes its responsibility to protect the information you entrust to us. Emplifi maintains, and requires its third party suppliers to maintain, technical and organizational measures to protect your data as required by the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council (“GDPR”) and any other applicable law or regulation. We have implemented internal controls and information security routines, including trainings on personal data protection, in accordance with good industry practice and we regularly verify the appropriateness of these measures. We have also implemented Information Security Management in accordance with the requirements of ISO 27001, including data access management, supplier management and compliance processes.

Automated processing and use of AI

We may use limited forms of automated tools during our recruitment process (for example, systems that help screen applications, parse résumés, or identify skills that match a role’s requirements). These tools are designed to assist our recruiters, not replace them.

No fully automated decision-making:

We do not make hiring or rejection decisions based solely on automated processing or profiling. Every hiring decision includes human review and judgment by our recruitment or hiring teams.

Purpose and safeguards:

Any automated tools we use are configured to enhance efficiency, reduce human error, and support fair and inclusive hiring. We regularly review these systems to ensure they remain accurate, transparent, and free from unlawful bias or discrimination.

Legal context:

In the EU/EEA and UK, we comply with Article 22 of the GDPR and Part 3 of the UK Data Protection Act 2018, which protect individuals from decisions based solely on automated processing that produce legal or similarly significant effects.
We align our practices with the EU Artificial Intelligence Act (Regulation (EU) 2024/1689), treating recruitment tools as “high-risk AI systems.” This means we ensure appropriate human oversight, transparency, risk management, and record-keeping in connection with such systems.

In Canada, we apply the principles of the proposed Artificial Intelligence and Data Act (AIDA) and Bill C-27, ensuring transparency, accountability, and fairness in any AI-supported evaluation.
In the United States, we monitor and comply with relevant state-level AI and anti-discrimination laws (including those in California, Illinois, New York City, and Colorado) that regulate automated employment decision tools and require bias testing and disclosure.

Your rights:

You may:

  • Request human intervention in relation to any decision that involves automated processing;
  • Express your point of view and request clarification on how such tools are used; and
  • Contest any decision you believe has been made in error or unfairly influenced by automated assessment.

Requests can be made by contacting our Privacy Team at hrdataprivacy@emplifi.io. We will review and respond in accordance with applicable law.

Your Rights

Once you have provided us with your Personal Data, you will be able to access this information and exercise your following rights:
Depending on your location, you may have specific rights in relation to your personal data under applicable privacy and data protection laws. These may include the right to:

  • Access the personal data we hold about you;
  • Rectify or correct inaccurate or incomplete information;
  • Delete (erase) your personal data, subject to applicable retention and legal obligations;
  • Restrict or object to certain types of processing (for example, where processing is based on our legitimate interests);
  • Request data portability, to receive your data in a structured, commonly used, and machine-readable format; and
  • Withdraw your consent at any time where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal.

We will respond to all verified requests in accordance with applicable laws and within the statutory time limits. To exercise any of these rights or raise a privacy concern, please contact our Privacy Team at hrdataprivacy@emplifi.io.

European Union (EU)

If you are located in the European Union, your rights arise under the EU General Data Protection Regulation (GDPR). This includes the right to lodge a complaint with your local Data Protection Authority (DPA) if you believe your personal data has been processed in violation of the GDPR.

A list of EU supervisory authorities can be found here

Germany

If you are located in Germany, your data protection rights arise under both the EU GDPR and the Bundesdatenschutzgesetz (BDSG), Germany’s Federal Data Protection Act.

In addition to the rights listed above, German law provides specific guidance on the processing of employee and candidate data under § 26 BDSG, which allows processing of personal data where it is necessary for recruitment or employment purposes.

You may lodge a complaint with your competent Landesdatenschutzbeauftragte (State Data Protection Authority), a list of which is available here.

France

If you are located in France, your rights arise under the EU GDPR and the French Data Protection Act (Loi Informatique et Libertés) as amended.

You have the right to access, correct, delete, and object to the processing of your personal data, and to lodge a complaint with the Commission Nationale de l’Informatique et des Libertés (CNIL).

You can contact the CNIL or file a complaint online here.

Czech Republic

If you are located in the Czech Republic, your rights arise under the EU GDPR and the Czech Act No. 110/2019 Coll. on the Processing of Personal Data.

This Act supplements the GDPR and regulates how employers and organizations may handle candidate and employee data in the Czech Republic.

You may lodge a complaint with the Office for Personal Data Protection (Úřad pro ochranu osobních údajů – ÚOOÚ), the Czech supervisory authority, via its official website here.

United Kingdom

If you are located in the United Kingdom, your rights arise under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

You may contact the Information Commissioner’s Office (ICO) for further information or to raise a complaint: www.ico.org.uk.

Canada

If you are in Canada, your rights arise under the Personal Information Protection and Electronic Documents Act (PIPEDA) or applicable provincial privacy laws (e.g., Alberta PIPA, British Columbia PIPA, Quebec Law 25).

You may contact our Privacy Officer at hrdataprivacy@emplifi.io to access or correct your personal information, withdraw consent, or raise concerns.

United States

If you are located in the United States, your rights depend on the state in which you reside.

Residents of certain U.S. states including California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Florida, Montana, Tennessee, Delaware, Iowa, New Hampshire, and Nebraska have rights under their respective state privacy laws (collectively, “State Privacy Laws”). These laws, such as the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), and the Virginia Consumer Data Protection Act (VCDPA), may provide individuals with rights to access, correct, delete, or obtain a copy of their personal information, and to opt out of certain data uses.

Where applicable, Emplifi honors these rights through a single U.S. Privacy Request process, which you can access by emailing hrdataprivacy@emplifi.io. For California residents, please refer to our California Notice at Collection for further details on your rights and how to exercise them.

Global

We take privacy seriously and handle all privacy requests consistently across our global operations. While local rights and processes may vary, our underlying principles remain the same: transparency, fairness, and respect for your personal data.
After verifying your identity, we will respond to your request as soon as possible and always within the timelines required by applicable law.

If you have any privacy concerns or questions or wish to exercise your rights stated above, you can contact us at hrdataprivacy@emplifi.io.

If you have provided your consent with the processing and retention of your Personal Data in Emplifi’s candidate database in order to receive notifications about future job opportunities at Emplifi you may request to have your Personal Data removed by sending an email request to hrdataprivacy@emplifi.io.