Candidate Privacy Statement

Effective Date: September 14, 2021

Thank you for your interest in joining the Pacaso Family.  Pacaso, its subsidiaries and affiliates, as identified to you during your employment application process, (“Pacaso,” “we,” or “us”) respect your privacy and recognise the responsibility that we have to protect your Personal Information. This Job Candidate Privacy Notice (“Notice”) describes how Pacaso collects, uses, shares, or otherwise processes your Personal Information during the employment application and recruitment process. This Notice applies to job applicants only and covers all employment positions to which you apply. 

For purposes of this Notice, the term “Personal Information” refers to any information, or a combination of pieces of information, that allows you to be identified, and that is subject to, or otherwise afforded protection under, an applicable data protection law, statute, or regulation.

All information is provided by you on a voluntary basis and you determine the type of extent of information that you provide to Pacaso. However, if you do not provide us the Personal Information that is necessary for us to consider your application (e.g., evidence of qualifications or work history), then we will not be able to process your employment application. 

Collection of Personal Information

When you apply for a job at Pacaso, we will ask you (i.e., the candidate) to provide us with Personal Information about yourself so we can evaluate your application.  We may collect and process the following categories of Personal Information about you:

• Contact Information: such as your name, address, email address, telephone, other contact information.

• Employment details: information in your curriculum vitae (“CV”), resume, cover letter, or similar documentation, or during the course of your interview or other engagement with us.

• Background information: educational background including degrees, certificates, transcripts, credit history and/or criminal background screenings (where relevant to your application and permitted under applicable law).
• Financial data: salary, tax information, benefits, expenses, company allowances, stock and equity grants
• Other unique information in your application that you choose to share with us, such as personal preferences, hobbies, social preferences, etc.
• Sensitive Personal Information: Pacaso does not request or require sensitive Personal Information regarding your religion, sexual orientation or political affiliation in connection with your application. If you have a disability and would like for us to consider an accommodation, you may provide that information during the recruitment process. For some countries, Pacaso may also ask for information such as race, ethnicity, or gender for the purposes of monitoring our equal opportunity programme and compliance. However, for the purposes of your application this information is voluntary. If you provide us with this information, it will not be considered in the hiring or selection process.

Sources of Information 

Most often, we collect your Personal Information directly from you, such as through the application form or interview process.  We may also collect Personal Information about, or related to you, from our recruitment vendors, background and credit check providers, public agencies responsible for assisting in the employment eligibility and verification process, publicly available sources, and your identified references We may also obtain information about you from public sources or third parties. For example, you may also choose to provide us with access to certain Personal Information stored by third parties such as job-related social media sites (e.g., LinkedIn). We do not request, and please do not provide us with, any details that can be used to access or control any of your social media accounts.

Collection of Usage Data  

If you apply to a job through any of our websites, then we may collect certain usage data. For information regarding how we collect information on our websites or other online services, including applications submitted online, or during any other business or professional relationship with us, visit our website privacy policy.

How We Use Personal Information

We use your Personal Information, as applicable law permits, or requires, to satisfy our employment application and recruitment process, or for our other legitimate business interests. For example, we may use your Personal Information for the following purposes: 

• Identifying and evaluating job applicants, including assessing skills, qualifications, and interests.
• Verifying your information and completing employment, background and reference checks, which may be subject to your consent where required by applicable law.
• Communicating with you about the recruitment process and your application.
• Complying with our legal, judicial, regulatory, administrative, or other corporate requirements, including, but not limited to, requirements mandating that we conduct criminal record, or other background checks.
• Analysing and improving our application and recruitment process, including by executing satisfaction surveys.
• Accommodating individuals who may have specialised needs during the employment process.
• Protecting the rights, interests, and property of Pacaso, other job applicants, employees, or the public, as required, or permitted, by law.

We will only use your Personal Information in accordance with this Notice. If we need to use your Personal Information for an unrelated purpose, we will, to the extent practicable, provide notice to you and, if required by law, seek your consent. We may use your Personal Information without your consent, where permitted by applicable law or regulation. 

Data Sharing

We will disclose your Personal Information within Pacaso to appropriate officials who are involved in the employment application and recruitment process.  We may also disclose your Personal Information to our designated agents, or third-party service providers, who require such information to assist us with administering our employment application and recruitment process, including, but not limited to, obtaining employment verification and background checks. We will share your Personal Information with third-parties when required to do so by law, or by regulatory requirements to which you, or we, are subject. We may share Personal Information where it is necessary to administer our working relationship with you, or where we have another legitimate business interests in doing so, such as where it is necessary for the operation of our business or defend our business or legal interests. 

We may also share your Personal Information with potential acquirers or investors of Pacaso, or the business area in which you work. We may share your Personal Information in the event of a merger, divestiture, restructuring,reorganisation, dissolution, or other sale or transfer of some, or all, of Pacaso’s practice or assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Pacaso, in any form or format, is among the assets transferred.

We Do Not Sell Your Personal Information

We do not sell, rent, or lease Personal Information that we have collected or retain about you to any other third-party for any purpose. Accordingly, we do not offer individuals the ability to “opt-out” of the selling of Personal Information because we do not engage in those practices.

Data Location

Pacaso is global company, with its headquarters in the United States. The information (including Personal Information) that Pacaso collects and processes is stored in the United States, the local office to which you applied for employment, and any other country in which Pacaso operates. Please be aware that the United States and these other countries may not provide the same level of protections as the laws in your country. By continuing to provide us such information you hereby consent to your Personal Information being transferred to, and stored in, the United States and any other country in which Pacaso operates. 

Retention Schedule

If your application does not lead to employment with us, Pacaso will retain your application (and Personal Information therein) on file for twenty four (24) months from the date of your original application for consideration for future employment opportunities. At the end of the twenty four (24) months, your application (and the Personal Information therein) will be erased from our records. If your application for employment results in employment, the Personal Information gathered during the recruitment process will be transferred to an electronic HR file set up in your name and retained during your employment. The periods for which your Personal Information will be retained and how it will be processed will be provided to you in a new employee data privacy policy.

Security

Pacaso is committed to protecting the security of your Personal Information, and we use a variety of security technologies and procedures to help protect your Personal Information from unauthorised access, use or disclosure. However, no information system can be fully secure, so we cannot guarantee the absolute security of your personal information. Moreover, we are not responsible for the security of information you transmit to Pacaso over networks that we do not control, including the Internet and wireless networks.  You provide us with any information and data at your own risk. The safety and security of your Personal Information also depends on you.  Where we have given you (or where you have chosen) a user ID and password to access a Pacaso platform, you are responsible for maintaining the security and confidentiality of those log-on credentials and not revealing them to others. You must contact us immediately if you have to reason to believe that your user ID or password to our online platforms have been compromised.

Disclaimer: Your Obligations to Us

With regard to any Personal Information that you provide Pacaso, regardless of whether that Personal Information relates to you or a third-party, you must ensure, on a continuing basis, that (i) such Personal Information is accurate, relevant, and complete, (ii) you have the lawful basis to provide Pacaso with such Personal Information, and (iii) you have provided this Notice to, and/or received, consent from, any third-party whose Personal Information you have provided Pacaso. If you choose not to provide us with the Personal Information identified herein, then Pacaso may not be able to satisfy our own contractual or legal obligations, and, in such circumstances, employment with Pacaso may not be permissible. You acknowledge and agree that Pacaso shall not be held liable for any consequence directly resulting from these circumstances. 

Data Privacy Rights

Depending on the jurisdiction in which you reside or Pacaso operates, you may have certain data protection rights. To exercise any of these data privacy rights, please contact us, or have your authorised agent contact us, in accordance with the “Contact Us” section listed below. However, please note that the rights afforded under data protection laws are not absolute and often do not cover Personal Information collected or processed in accordance with the employment recruitment and application processes.  Accordingly, Pacaso may be permitted to refrain from undertaking any action or changing its data processing activities, in response to a data request you submit to us.

Canadian Applicants. Where, in accordance with this Notice, we export your Personal Information to a country other than the country in which you are rendering services for Pacaso, that Personal Information may be available to the applicable foreign government or its agencies under a lawful order made in that foreign country for purposes other than described herein.

Persons with Disabilities. Pacaso strives to ensure that every person has access to information related to our products and services, including this Notice. Please contact us if you would like this Notice provided in an alternative format and we will seek to meet your needs

Changes to this Notice

We will only use your Personal Information in the manner described in this Notice. However, we reserve the right to change the terms of this Notice at any time by posting revisions to our website. If at any time, we decide to use your Personal Information in a manner that is different from that stated at the time it was collected, you will, to the extent required by law, be given notice of the same.

Contact Us

If you have questions, concerns, or comments related to how Pacaso processes your Personal Information, including whether you would like to exercise the rights and privileges described herein, please contact us at the following: 

• In writing: ATTN: Privacy Council, 2021 Fillmore St. Suite 183, San Francisco, CA 94115, USA

Amendment Date: This Notice was last amended on September 14, 2021.