Candidate Policy

Appcharge – Candidates and Employees Privacy Policy

Introduction

Appcharge Ltd. and its affiliated companies ("Appcharge", "we", "our" or "us") provide this Privacy Policy ("Policy") to explain our practices regarding the collection, use, transfer, storage, and other processing of Personal Data about job applicants and current and former employees, as described in more detail below.

It is important that you read this Policy, together with our general privacy policy, which we may provide on specific occasions when we are collecting or processing Personal Data about you, so that you are aware of the means and purposes for processing such data.

Employees are under a legal obligation to provide their employers with certain categories of their Personal Data, while the disclosure of other categories of Personal Data is done voluntarily. In these cases, the collection and processing of your Personal Data are based on your free will and consent. Without providing us with your Personal Data, as requested, we may not be able to appropriately perform our obligations towards you as your employer or to adequately perform your employment agreement with us.

Please note that this Policy does not form part of any contract of employment or other contract to provide services.

Specifically, this Policy describes the following:

Categories of Personal Data
Sources of Personal Data
Purposes of Processing Personal Data
Sharing Personal Data with Third Parties
Workplace Monitoring
Safeguarding Personal Data
International Transfers of Personal Data
Your Data Protection Rights
US Privacy Laws - Additional Information
Retention of Personal Data
Changes to this Policy
Contact Us

1. Categories of Personal Data

We collect two types of data from you: Personal Data ("Personal Data") and non-Personal Data ("Non-Personal Data"). Personal Data means any information that may potentially allow your identification with reasonable means (for example, email address or name). Non-Personal Data, by contrast, can be defined as any information that does not relate to an identified or identifiable natural person. This may include, for example, aggregated and technical information. Appcharge collects and processes the following categories of Personal Data of its employees and candidates:

1.1 Personal information: including name and contact information (full name, home address, phone number, and emergency contact information), date of birth, e-mail address, and passport data. Government identification numbers (such as social benefits information), citizenship/residency, personal status (marital status, dependents), and photos.

1.2 Sensitive data: such as health-related data, such as sickness absence, health and disability status, etc.

1.3 Employee status and compensation: if you become an employee of Appcharge, we will process certain information regarding your employment status (i.e. full-time, part-time, active, leave of absence etc.), current base salary and differentials, annual salary, pay scale and range, type of employee, average hours worked, incentive information, equity and other compensation program participation and salary history; similar information may also be processed if you provide it to us with respect to your candidacy application.

1.4 Career-related and organizational information: including but not limited to behavior-related details, work contact information, job title, department, location, hire data, and any previous hire or service date, work history, supervisor, and job function.

1.5 Payroll information: including bank information, tax information, garnishments and deductions, time worked, vacation information, and other paid time off information.

1.6 Performance and evaluations: including qualifications, evaluations, developmental planning, security policy permissions, communication data, and other talent management and team-based assessments.

1.7 Information of your attendance: including entry and exit data, from Appcharge's premises and surveillance cameras' footage (as further detailed in Annex 1), attendance records, and other data collection permitted or required by applicable law.

1.8 Applications and recruitment: Appcharge collects and maintains different types of Personal Data concerning candidates. This includes full names, e-mail address, phone number, photos, birthdates, address, CVs and their content (including information such as skills, work experience, education), notes submitted with the application, URL of your LinkedIn and other online profiles, the position for which you have been or are being considered, the source who submitted your candidacy (e.g., recruiting agency, referral), email correspondences between you, Appcharge and between Appcharge and other sources (such as recruiting agency and referrals) about your candidacy, information from references, events in the lifecycle of your candidacy, your responses to questionnaires sent to you by us, information about your candidacy and employment options (such as availability to be hired and salary expectations), evaluations of your candidacy, internal discussions within Appcharge about your candidacy, materials you or other parties (such as evaluators or background check providers) submitted in relation to your candidacy.

2. Sources of Personal Data

We generally collect Personal Data directly from employees or candidates. You may be under a legal obligation to provide us with some of the Personal Data, while disclosure of other Personal Data is done voluntarily.

From time to time, we may collect Personal Data about employees and candidates from third parties, such as:

2.1 Recruitment and screening agencies;

2.2 Regulatory bodies;

2.3 Past employers;

2.4 Social media platforms (e.g., LinkedIn).

In those circumstances, Appcharge will take reasonable steps to ensure that those third parties have represented to us that they have the right to disclose the Personal Data to us.

In some circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

3. Purposes of Processing Personal Data

Appcharge uses and otherwise processes Personal Data to the extent necessary or appropriate for the following purposes:

Purpose	Legal basis
Assessing, administering and managing all aspects of candidate recruitment, and an employee’s employment relationship, including, but not limited to, payroll, benefits, corporate travel and other reimbursable expenses, workforce administration and planning, finance, accounting and compensation management, absence monitoring, performance appraisal, disciplinary and grievance processes and other general company, administrative and human resource related processes.	The legal bases for processing this data are your consent (for example, when you provide Personal Data), the performance of our contractual obligations to you, our legal obligations and our legitimate interests. Our legitimate interests in this case are organisation and distribution of work, maintaining an efficient employee benefits program, maintaining a well-managed and orderly workforce and business.
Training and employee development, including but not limited to security and data protection training, anti-money laundering training, employee development etc.	The legal bases for processing this data are your consent (for example, when you provide Personal Data), the performance of our contractual obligations to you, our legal obligations and our legitimate interests. Our legitimate interests in this case are career development, management forecasting and maintaining a well-managed and orderly workforce and business.
Security reasons, including ensuring the security of company-held information, detecting fraudulent or illegal behaviour, etc.	The legal bases for processing this data are our legal obligation and legitimate interests. Our legitimate interests in this case are protection of Appcharge property and property belonging to third parties, enforcing our policies and keeping the safety of our services, employees and end-users.
Assessment of candidacy, conducting performance reviews and determining performance requirements, as well as assessing qualifications for a particular job or task, including appraisal and verification of the employee's references and qualifications.	The legal base for processing this data is your consent (for example, when you provide Personal Data) and our legitimate interests. Our legitimate interests in this case are recruitment and succession planning, maintaining a well-managed and orderly workforce and business and management forecasting.
Establishing, managing or terminating the employee's employment.	The legal bases for processing this data are your consent (for example, when you provide Personal Data), the performance of our contractual obligations to you, our legal obligation and our legitimate interests. Our legitimate interests in this case are recruitment and succession planning, organisation and distribution of work, management forecasting and maintaining a well-managed and orderly workforce and business.
Managing recruitment process and job applications.	The legal bases for processing this data are your consent (for example, when you provide Personal Data), our legal obligations and our legitimate interests. Our legitimate interests in this case are recruitment and succession planning, organisation and distribution of work, management forecasting and maintaining a well-managed and orderly workforce and business.
Processing employee work-related claims (e.g., employee's compensation, insurance claims, etc.).	The legal bases for processing this data is the performance of our contractual obligations towards you and compliance with our legal obligations.
Gathering evidence for disciplinary action or termination.	The legal bases for processing this data are our legal obligations and legitimate interests. Our legitimate interest in this case is enforcing our policies.
Complying with applicable laws, including labour and employment laws, including judicial or administrative orders regarding individual employees (e.g., garnishments, child support payments, statutory reporting requirements, etc.).	The legal base for processing this data is the performance of our legal obligations.
Conducting legal disputes, If Appcharge receives a notice of legal proceedings against it for actions taken by a candidate or an employee in the context of any dispute, claim, suit, demand or legal proceedings, if any, between it and Appcharge.	The legal base for processing this data is the performance of our legal obligations and our legitimate interests. Our legitimate interests in this case are to establish and defend our legal claims.
Conducting a due diligence of Appcharge in the event of a third party contemplating the purchase or investment in Appcharge.	The legal base for processing this data is our legitimate interests. Our legitimate interest in this case is to enable future investments, mergers and acquisitions.

4. Sharing Personal Data with Third Parties

Appcharge shares Personal Data with the following categories of third parties:

4.1 Third-party service providers, including:

4.1.1 Human resource information system or human resource management system;

4.1.2 Enterprise resource planning (ERP) and record management tools;

4.2.3 Payroll and attendance providers;

4.1.4 Travel agencies.

4.2 Affiliated companies and business partners.

4.3 External advisors: e.g., lawyers, accountants, and auditors, subject to confidentiality provisions.

4.4 Governmental authorities and regulatory bodies: to meet local statutory requirements (e.g., tax authorities, regulatory registration bodies, etc.), such as with governmental agencies, authorities and regulators, social organizations, courts and other tribunals, to the extent permitted or required by applicable law.

4.5 Recruitment agencies: for the purpose of recruitment and assessing your fitness for a specific role.

4.6 Business transaction: We may share your Personal Data if we enter into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets. Any party that acquires our assets as part of such a transaction may continue to use your data in accordance with the terms of this Policy.

These third-party service providers have access to Personal Data as needed to perform their functions, but they are not permitted to use it for other purposes. To ensure your Personal Data is secured, Appcharge exercises appropriate due diligence in the selection of such service providers and enters into contractual obligations requiring such service providers to maintain adequate technical and organizational security measures to safeguard the Personal Data, and process the Personal Data only as instructed by Appcharge (as applicable).

5. Workplace Monitoring

We monitor certain candidate, employee, worker, or contractor activities in our premises and property, such as by installing CCTV surveillance cameras, as well as monitoring employees' and workers’ computer and email use.

This monitoring is carried out for the following purposes:

5.1 To detect, investigate, and prevent crime, such as theft, fraud, or illegal use of software or the intellectual property of Appcharge or a third party;

5.2 To prevent the unauthorized or unlawful disclosure of confidential business information, for example, trade secrets;

5.3 To comply with obligations to prevent discrimination or sexual harassment under applicable laws, and prevent or reduce company exposure to liability for the unlawful acts of employees, particularly in relation to racist or sexist communications in the workplace;

5.4 To ensure the quality of products and services, and avoid damage to Appcharge’s reputation and goodwill;

5.5 To comply with laws and regulations, e.g., workplace safety, labor, tax, and other requirements;

5.6 To ensure the integrity of information systems and compliance with company security and data protection policies.

6. Safeguarding Personal Data

Appcharge takes excellent care in ensuring and maintaining the security of employees' and candidates' Personal Data. To ensure the safety of your information and prevent unauthorized use of such information, Appcharge employs industry-standard practices and procedures, such as compliance checks, to maintain the integrity and confidentiality of your Personal Data and to ensure compliance with this Policy and our data protection obligations.

7. International Transfers of Personal Data

Since Appcharge operates globally, it may be required to transfer Personal Data to service providers, authorities, and affiliates in countries that may be outside the country in which you reside.

The data protection and other laws of these countries may not be as comprehensive as those of the country in which you reside. In these instances, and where applicable, Appcharge takes ongoing measures to ensure that such service providers and affiliates have implemented appropriate safeguards to protect the security of Personal Data. This includes, for example, standard contractual clauses that have been “pre-approved” by the relevant authorities, or the existence or absence of an adequacy decision, or implementing other appropriate safeguards as necessary in accordance with applicable laws.

8. Your Data Protection Rights

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your working relationship with us. We encourage you to keep your Personal Data up to date on all platforms made available to you in the course of your employment or recruitment process.

This section addresses certain rights you may have regarding your Personal Data, depending on the jurisdiction in which you reside.. You may contact us at any time and request the following:

Right of access: The right to know which Personal Data we collected, including the categories of Personal Data, the sources from which the Personal Data is collected, the business or commercial purpose for collecting, selling, or sharing Personal Data, the categories of third parties to whom we disclose Personal Data, and the specific pieces of Personal Data that we collected about you;
Right of data portability: The right to request to receive your Personal Data in a structured, commonly used and machine-readable format and to transmit this data to another party, where possible;
Right of rectification: You have the right to amend or rectify inaccuracies in your Personal Data, or request to record a supplementary statement to your Personal Data in certain circumstances;
Right of restriction or objection to processing: In certain cases, you have the right to request that Appcharge restrict or cease to conduct certain Personal Data processes at any time;
Right of Deletion: The right to request that Appcharge erase or delete Personal Data held about you at any time.
Right to withdraw your consent: To the extent we process Personal Data on the basis of your consent, you have the right to withdraw your given consent at any time.
Right not to be subject to automated decision-making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects you.

Kindly note that the above rights are not absolute, and different rights may apply under different data protection legislation. There are instances where applicable law or regulatory requirements allow or require us to refuse your request. In addition, in certain instances, your Personal Data may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

In the event that we cannot fulfill your request, we will endeavor to inform you of the reasons, subject to any legal or regulatory restrictions. You are welcome to contact us with any questions or requests using the contact details below. We will make an effort to reply within a reasonable timeframe. If you are unsatisfied with our response, you can complain to the applicable data protection supervisory authority.

9. US Privacy Laws - Additional Information

This part of the Policy addresses the specific disclosure requirements under the applicable US privacy laws (“US Privacy Laws”).

9.1 Collection of Personal Information

In the preceding twelve (12) months, we have collected the following categories of Personal Information:

Category	Personal Data collected	Sources
Identifiers	Name and contact information (full name, home address, phone number and emergency contact information), date of birth, government identification numbers (such as social security numbers, tax payer id's and driver’s license), etc.	Information you provided with us; Information collected from third parties.
Employee/candidate records	Financial information, name, telephone number.	Information you provided with us; Information collected from third parties.
Characteristics of protected classifications under California or federal law	Gender, age, race, religion, sexual orientation, health related information.	Information you provided with us;
Professional or employment-related information.	Current or past job history or performance evaluations.	Information you provided with us; Information collected from third parties
Education Information	Including information about an employee’s educational background, such as education records and transcripts that are not publicly available.	Information you provided with us; Information collected from third parties.

We use the data types described in the table above, as described in section ‎3 of this notice.

9.2 Disclosing Personal Information

We disclose your Personal Information to third parties, as described in section ‎4 above. When we disclose Personal Information to third parties, we enter into a contract that describes the purpose and requires both parties to keep that Personal Information confidential and not use it for any purpose except in the performance of the contract.

In the preceding twelve (12) months, we have disclosed the above-mentioned categories of Personal Information to our affiliates and service providers, as described in Section ‎4 herein, for business purposes.

9.3 Selling and Sharing Personal Information

We do not "sell" or “Share” Personal Information (as these terms are defined under the US Privacy Laws. We only disclose Personal Information as described in this notice.

10. Retention of Personal Data

Except as otherwise permitted or required by applicable law or regulatory requirements, Appcharge retains your Personal Data only for as long as it believes it is necessary to fulfill the purposes for which the Personal Data was collected (including, for the purpose of meeting any legal, accounting or other reporting requirements or obligations). We may, instead of destroying or erasing your Personal Data, make it anonymous such that it cannot be associated with or traced back to you.

11. Changes to this Policy

We reserve the right to update this Policy at any time. The most current version will be available on Appcharge's systems. In case of a material change, we will notify you about such changes via email or any other way we deem appropriate.

12. Contact Us

If you have any questions about this Policy, or our Personal Data processing activities, please contact us at