Job Candidates Privacy Notice

Legal Centre

Thank you for considering a position at Torq!

This Job Candidate Privacy Notice (“Notice”) describes what personal data we – Torq Technologies Ltd. and our affiliates, (“Torq”, “we”, “our” or “us”) collect and process from our job candidates and applicants (“Candidates” or “you”) with respect to your application and recruitment process, why we collect it and how we use and protect it. It also describes how you may exercise your rights to such data held with us.

This Notice outlines our data practices across all locations and complies with applicable data protection laws, including the Israeli Protection of Privacy Law, the EU and UK General Data Protection Regulation (“GDPR”), and the California Consumer Privacy Act (“CCPA”) (collectively, “Data Protection Laws”). Certain jurisdictions may impose additional restrictions on the types of data we collect or how we process it. Specific parts of this Notice, such as the “legal basis” section and certain data subject rights, apply only to individuals covered by the GDPR.

Please note the information contained in this Notice supplements the information contained in our Privacy Policy and Cookie Notice regarding your use of our website from which you submitted your application.

We urge you to read this Notice and make sure that you fully understand and agree to it. If you do not agree to this Notice, please avoid providing us with your personal data. You are not legally required to provide us with any personal data, but without it we will not be able to examine and process your application.

1. What data do we collect, how do we collect it, and how do we use it?

By using the term “personal data” or “Personal Information” under this Notice we refer to information that identifies, relates to, or could reasonably be linked with an individual using reasonable means. We may collect, store, and use various types of personal data about Candidates, including sensitive information as defined by applicable Data Protection Laws (e.g., governmental ID numbers or professional qualifications). The table below outlines the categories of personal data we process, their purposes, and, where applicable, the lawful basis under the GDPR.

Types of personal data	Purpose of collection and use	Lawful basis (where applicable)
Personal identification information: your full name and identifying information such as date of birth, government-issued identification number, copy of identification certificate (e.g., ID, passport, SSN) and your photo. Contact information: such as your phone number, email and residence address. Education, qualifications, skills, and expertise: such as educational institutions you studied, degrees or certifications, skills, and any other expertise which may be applicable to the position you apply to. Employment history: such as previous employers, job titles, dates of employment, responsibilities, etc. Eligibility to work: information related to your legal right to work in the applicable territory or country where the position is offered (e.g., citizenship or visa status). Assessments and results, our communications with you, and internal records: information we collect and gather as part of the recruitment process including interviews, tests and assessments conducted by Torq to evaluate the suitability for the position, internal notes taken by Torq, as well as our correspondence with you, and phone calls recordings, video interview or other interactions between the you and Torq. Background check information: information obtained through background checks, where required and as permitted under applicable laws, such as verification of employment and history. Any additional information provided by you voluntarily: such as information included in its resume (CV) and supporting documents you provide or submit.	To evaluate your qualifications: e.g., assess your eligibility for the applied position, support decision-making, and, where permitted by law, consider you for other openings at Torq. To communicate with you: We process your information to manage recruitment communications, such as scheduling interviews, providing updates, and informing you of decisions regarding your application. To verify the information you provided and for reference checks: we may need to verify the accuracy of certain information you have provided to us, for example information related to your education, employment history, and similar professional references. To ensure your eligibility to work: Where applicable, we may verify your legal right to work in the relevant country and follow immigration laws. To comply with legal requirements: we process certain information to ensure we adhere to and comply with relevant laws and regulations, including labor, privacy laws, etc. Internal documentation and record-keeping purposes: we process and retain the information we need to maintain records of the recruitment process, including evaluations, assessments, and decisions, which may be used for future reference or to handle potential disputes or legal claims. Administration and human resources procedures, performance and improvement: we process the information to track the application through the recruitment process and to further analyze and refine our recruitment strategies, practices, and processes.	Legitimate Interests: We primarily process personal data to support our recruitment activities, including assessing candidates, conducting selection processes, and making hiring decisions. This may also involve retaining certain types of personal data, even after a candidate is not selected, for purposes such as record-keeping, compliance with applicable laws, evaluating and improving our recruitment processes, and defending against potential legal claims. Legal Obligations: In some cases, we process personal data to follow applicable laws, including employment, social security, and other regulatory requirements. Consent: Where Data Protection Laws require it, we will seek your explicit consent to process your personal data. You retain the right to withdraw your consent at any time; however, this may affect our ability to consider you for certain roles. Contractual Necessity: If we are working towards a contract with you, we may process your personal data as necessary to fulfil our obligations under that contract or to take steps at your request prior to entering into it.
Additional and Special Types of Data: This includes (to the extent and in the jurisdictions legally permitted) information such as national origin, citizenship, military status, past salary, and criminal history, which may be considered sensitive data under different laws and we will treat it accordingly.	To monitor equal opportunity: we may ask for Candidates to provide such information where needed to monitor equal opportunity and for us to ensure diversity and inclusion. To ensure compliance with applicable laws or security standards: to the extent required or permitted by applicable law, we may conduct background checks that may involve criminal record information. Internal documentation and record-keeping purposes: we may process this information to maintain a record of the recruitment process, which may be used for internal and external reporting responsibilities (e.g., legal, and regulatory requirements), and to address potential disputes or legal claims. Recruitment Process: We may collect information such as past salary to understand and align with your salary expectations and to inform our proposal.	Legitimate Interests: We may process this data to facilitate recruitment activities, such as assessing your suitability for a role, ensuring compliance with diversity and anti-discrimination principles, and addressing potential disputes or legal claims, where permitted by law. Legal Obligations: Processing may be required to follow applicable laws, including employment, social security, or regulatory requirements. Consent: Where required by law, we will obtain your explicit consent to process these types of data. You may withdraw your consent at any time; however, this may affect our ability to consider you for certain roles.

Types of personal data

Purpose of collection and use

Lawful basis (where applicable)

Personal identification information: your full name and identifying information such as date of birth, government-issued identification number, copy of identification certificate (e.g., ID, passport, SSN) and your photo.

Contact information: such as your phone number, email and residence address.

Education, qualifications, skills, and expertise: such as educational institutions you studied, degrees or certifications, skills, and any other expertise which may be applicable to the position you apply to.

Employment history: such as previous employers, job titles, dates of employment, responsibilities, etc.

Eligibility to work: information related to your legal right to work in the applicable territory or country where the position is offered (e.g., citizenship or visa status).

Assessments and results, our communications with you, and internal records: information we collect and gather as part of the recruitment process including interviews, tests and assessments conducted by Torq to evaluate the suitability for the position, internal notes taken by Torq, as well as our correspondence with you, and phone calls recordings, video interview or other interactions between the you and Torq.

Background check information: information obtained through background checks, where required and as permitted under applicable laws, such as verification of employment and history.

Any additional information provided by you voluntarily: such as information included in its resume (CV) and supporting documents you provide or submit.

To evaluate your qualifications: e.g., assess your eligibility for the applied position, support decision-making, and, where permitted by law, consider you for other openings at Torq.

To communicate with you: We process your information to manage recruitment communications, such as scheduling interviews, providing updates, and informing you of decisions regarding your application.

To verify the information you provided and for reference checks: we may need to verify the accuracy of certain information you have provided to us, for example information related to your education, employment history, and similar professional references.

To ensure your eligibility to work: Where applicable, we may verify your legal right to work in the relevant country and follow immigration laws.

To comply with legal requirements: we process certain information to ensure we adhere to and comply with relevant laws and regulations, including labor, privacy laws, etc.

Internal documentation and record-keeping purposes: we process and retain the information we need to maintain records of the recruitment process, including evaluations, assessments, and decisions, which may be used for future reference or to handle potential disputes or legal claims.

Administration and human resources procedures, performance and improvement: we process the information to track the application through the recruitment process and to further analyze and refine our recruitment strategies, practices, and processes.

Legitimate Interests: We primarily process personal data to support our recruitment activities, including assessing candidates, conducting selection processes, and making hiring decisions. This may also involve retaining certain types of personal data, even after a candidate is not selected, for purposes such as record-keeping, compliance with applicable laws, evaluating and improving our recruitment processes, and defending against potential legal claims.

Legal Obligations: In some cases, we process personal data to follow applicable laws, including employment, social security, and other regulatory requirements.

Consent: Where Data Protection Laws require it, we will seek your explicit consent to process your personal data. You retain the right to withdraw your consent at any time; however, this may affect our ability to consider you for certain roles.

Contractual Necessity: If we are working towards a contract with you, we may process your personal data as necessary to fulfil our obligations under that contract or to take steps at your request prior to entering into it.

Additional and Special Types of Data: This includes (to the extent and in the jurisdictions legally permitted) information such as national origin, citizenship, military status, past salary, and criminal history, which may be considered sensitive data under different laws and we will treat it accordingly.

To monitor equal opportunity: we may ask for Candidates to provide such information where needed to monitor equal opportunity and for us to ensure diversity and inclusion.

To ensure compliance with applicable laws or security standards: to the extent required or permitted by applicable law, we may conduct background checks that may involve criminal record information.

Internal documentation and record-keeping purposes: we may process this information to maintain a record of the recruitment process, which may be used for internal and external reporting responsibilities (e.g., legal, and regulatory requirements), and to address potential disputes or legal claims.

Recruitment Process: We may collect information such as past salary to understand and align with your salary expectations and to inform our proposal.

Legitimate Interests: We may process this data to facilitate recruitment activities, such as assessing your suitability for a role, ensuring compliance with diversity and anti-discrimination principles, and addressing potential disputes or legal claims, where permitted by law.

Legal Obligations: Processing may be required to follow applicable laws, including employment, social security, or regulatory requirements.

Consent: Where required by law, we will obtain your explicit consent to process these types of data. You may withdraw your consent at any time; however, this may affect our ability to consider you for certain roles.

2. What are our data sources?

We collect personal data directly from you (e.g. when you voluntarily provide it as part of your CV, etc.) or from third parties (e.g., another person or entity) such as an employment agencies, recruitment or professional networking website, background check provider or references, etc.

3. Where do we store your data?

Torq operates globally and as such we may transfer or store your personal data in countries other than the country in which you are from. If personal data is transferred for any Candidate that resides in the European Economic Area to countries that are not deemed adequate by the European Commission, then Torq will ensure appropriate safeguards are in place such as standard contractual clauses.

4. For how long may we keep your data?

We retain your personal data as necessary to fulfill the purposes for which it was collected, as outlined above, and to meet legal, administrative, and record-keeping requirements. The criteria according to which we determine the retention periods depend on the type and sensitivity of the data, the stage of your recruitment process, and applicable legal obligations. Retention schedules will also depend on statutory limitation periods, where personal data will be retained to resolve any future disputes which may arise, defend against legal claims, etc. Additionally, where applicable, we may retain your data to consider you for future roles, based on reasonable expectations or explicit consent.

Once the retention period ends, and we no longer have a legal or legitimate basis to retain your data, it will take steps to securely delete, anonymize, or de-identify to prevent association with you. If you are hired, your personal data will be retained and managed in accordance with our employee data policies and applicable legal requirements. If unsuccessful, your personal data may be retained for an additional §time period to address potential disputes or consider you for future opportunities.

5. How will we secure your data?

Torq has implemented security measures designed to protect the personal data of our candidates, including physical, procedural, and electronic measures. We also regularly seek new ways and tools for further enhancing the security of our services and the integrity of the personal data that we hold. Please note however, that regardless of the measures we take and the efforts we make, we cannot and do not guarantee the absolute protection and security of any personal data stored with us, just like the security of any data stored online cannot be guaranteed.

6. Who will have access to your data?

We disclose your personal data internally with personnel involved in the recruitment and hiring process (i.e., human resources, managers, affiliates), with relevant third parties who support our recruitment processes and other third parties where needed to comply with our legal obligations or to exercise and defend our rights.

The categories of such third parties with whom we share personal data are as set forth below:

Torq Group Companies- Torq may share your personal data with subsidiaries and other companies within the Torq group to facilitate and manage the recruitment process and for other purposes details in this Policy.
Mergers, Acquisitions, and Restructuring: In the event of a merger, acquisition, or corporate restructuring involving Torq (including bankruptcy), or the evaluation of such transactions involving Torq, your personal data may be shared with the merged or acquiring company. This ensures the continuity of the recruitment process and the proper handling of your application in accordance with Data Protection Laws. Any sharing of data in such circumstances will be subject to appropriate safeguards to protect your privacy and rights.
Governmental agencies authorized third parties or disclosure due to a legal process – Torq may disclose or otherwise allow access to any Candidates’ personal data pursuant to a legal order, such as a subpoena, search warrant or court order, or in compliance with applicable laws, with or without notice to you, if we have a good faith belief that we are legally required to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud or other wrongdoing.
Service Providers – Torq may share your data with several selected service providers whose services and solutions complement, facilitate and enhance our own. These include any local recruitment firms that have referred you to us (or vice versa), candidate evaluation centers, background check providers, recruitment software providers, video recruitment service providers, cyber security services, and if needed our business, legal, compliance and financial advisors. These service providers receive limited access to our Candidates’ personal data and may only use it for designated purposes. We ensure to contractually obligate our service providers to address safeguarding and properly using personal data solely for the purpose of providing us with requested services (unless they are otherwise required under applicable laws).

No Sale or Sharing of Personal Information- We do not sell or share candidates’ information as defined under the CCPA (e.g., for targeted advertising or cross-context behavioral advertising). Any sharing of personal information is strictly limited to purposes directly related to recruitment and conducted in accordance with this Policy and Data Protection Laws.

7. How can you exercise your Candidate privacy rights?

You have the right to exercise certain choices, rights, and controls in connection with your personal data. Depending on the applicable Data Protection Law, these rights may include one or more of the following principal rights:

The right to access your personal dataThe right to correct inaccuracies in your personal data
The right to request deletion
The right to request to restrict processing, which entitles you to request to limit the purposes for which we process your personal data (subject to certain conditions under Data Protection Laws).
The right to object, which entitles you to object to our processing of your personal data (subject to certain conditions under Data Protection Laws).
The right to data portability, which entitles you to receive the personal data you have provided, in a structured, commonly used and machine-readable format and transmit it to another controller.
The right to withdraw consent, where we are processing your personal data based on your consent.
The right to submit a complaint to the relevant supervisory data protection authority.
The right not to be discriminated against exercising your rights.

If you wish to exercise any of these rights, please contact us at [email protected]. Please note that we may be required to ask you for further information to confirm your identity before we provide the requested information. In addition, you may be allowed to designate an authorized agent to submit requests to exercise rights on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.

7. Will this Notice be updated?

We may update this Notice to reflect changes in our privacy practices. If we make any changes that we consider “material,” we will strive to update this Notice before the changes take effect.

8. Questions?

If you have any comments or questions regarding this Notice, our data practices or your privacy, or if you have any concerns regarding your personal data held with us, or if you wish to make a complaint about how your personal data is being processed by Torq, you can contact us at [email protected].

Last updated: December 1st, 2024