Job Applicant Privacy Notice

Effective date: 1st January, 2021

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Pax8 and its subsidiaries and affiliated companies (“Pax8”, “we”, “us”, “our”), are committed to fulfilling our responsibilities under the European Union’s General Data Protection Regulation (“GDPR”) and other applicable legislation, such as national and local data privacy, data protection, and cybersecurity laws and regulations in all applicable jurisdictions, in relation to the collection, retention, use, and other processing of personal data that is obtained through the recruitment and hiring process.
This Privacy Notice sets forth how we process EU personal data in our role as a data controller in the job recruitment and hiring process. It also tells you how you can exercise your rights (including the right to object to certain processing activities). More information about your rights and how you can exercise them is set out in the “Your Rights and Choices” section below.
Note that as part of our job recruitment and selection process we will share your personal data with the manager(s) responsible for the position you are applying for. Depending on the position, this may mean that we share your personal data with managers employed by another Pax8 entity, including Pax8 entities located outside the European Economic Area (“EEA”). For example, for certain positions we may share your personal data with manager(s) located at our headquarters in the United States. When sharing personal data with managers employed by an entity other than Pax8 UK, Pax8 International, LLC and the other Pax8 entity will act as joint controllers of your personal data.

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What personal data we collect and process

This Privacy Notice describes how Pax8, Inc., (“Pax8,” “we,” “our,” or “us”) collects, uses, and shares Personal Information about you through our websites and applications, including the Pax8 Portal, social media pages, and email messages (“the Services”). This Privacy Notice also informs you of your rights regarding your approval of our use of your Personal Information.

When you apply for a job at Pax8, we may collect and process the following information about you:

  • Your identification details, for example your name, address, date of birth, gender, and contact details, including email address and telephone number.
  • Details of your qualifications, skills, experience, and education and employment history, including your ability to fulfill job requirements.
  • Information about your current compensation, including benefit entitlements to the extent permitted by applicable law.
  • Data you submit in résumés / CVs, letters, writing samples, or other written materials necessary for evaluation of employment.
  • Data generated by interviewers and recruiters based on interactions with you.
As appropriate and relevant to the job you are applying for, we may conduct background checks, including criminal background checks, to the extent permitted by applicable law. Background checks are performed in accordance with applicable law.
You are under no legal or contractual obligation to provide your personal data to Pax8 during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly, or at all.

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How and why we use your personal data

We may process personal data to:

  • Assess your suitability for employment for the role for which you are applying, as well as future roles that may become available.
  • Perform recruitment-related administrative functions.

Our processing of such personal data is carried out pursuant to the following legal bases:

  • The processing is necessary for hiring decisions (GDPR Art. 6(1)(b)) in particular for deciding whether to enter into an employment relationship with you.
  • We have a legal obligation to process your personal data (GDPR Art. 6(1)(c)) such as to comply with applicable tax and other government regulations or to comply with a court order or binding law enforcement request.
  • We have a legitimate interest in using your personal data (GDPR Art. 6(1)(f)). In particular, we have a legitimate interest in the recruitment of suitable personnel and the effective administration and management of staff.
  • You have consented to the use of your personal data (GDPR Art. 6(1)(a)).

Pax8 may process special categories of personal data as required and permitted by applicable Member State law (e.g., under German data protection law we may process special categories of personal data for employment-related purposes if such processing is necessary for the specific job, to exercise rights, or comply with legal obligations pursuant to labor, social security, or social protection law, where the employee does not have an overring legitimate interest). At this time, Pax8 does not make any decisions in the hiring process using automated means. If we make a material change to how we process your personal data, we will notify you and may also modify this Privacy Notice.


How we may share your personal data

We may share your personal data:

    • Internally with our parent company, affiliates, subsidiaries, and other business units and departments within Pax8 for the recruitment and job selection process. This may include, for example, members of the human resources and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy, and IT staff if access to the data is necessary for the performance of their roles.
    • With third parties, including third parties located in the U.S., whom we engage to provide services such as hosting, supporting, and maintaining any recruiting platforms. These service providers are subject to strict contractual data processing obligations and do not use the data for their own purposes but process it only on our behalf and in accordance with our instructions.
    • Should we make you an offer of employment, we may contact former employers to obtain references for you (if we have a reasonable interest in verifying your information and this is necessary for verification purposes or if you have allowed us to contact your former employer) and with employment background check providers to obtain any necessary background checks, to the extent such background checks are permitted by applicable law and necessary to assess your suitability for the role/job for which you are applying.
    • If we are involved in a reorganization, merger, acquisition, or sale of some or all of our assets, in which case we may disclose your personal data to the prospective seller or buyer (and/or its advisors). The recipient of the personal data will process the data as described in this notice and/or provide additional notice in accordance with applicable law.
    • To abide by applicable law or protect our rights and interests. For example, we may disclose your personal data if we determine that such disclosure is reasonably necessary to comply with the law, protect our or others’ rights, property, or interests, or prevent fraud or abuse.


How long we retain your personal data

We will retain your personal data for no longer than is necessary for the performance of our obligations or to achieve the purposes for which the information was collected, or as may be permitted under applicable law. Unless otherwise required or prohibited by law, we may retain the personal data of unsuccessful job applicants for up to four months after the recruitment decision. In some cases, you may consent to us maintaining your personal data for longer if you wish to be considered for future positions.

If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice.

Personal data transfers to countries outside the EEA

If we transfer your personal data out of the EEA, we will put in place suitable safeguards to ensure that such transfer is carried out in compliance with applicable data protection laws and regulations. To ensure this level of protection for your personal data, Pax8 may use a data transfer agreement with the third-party recipient based on standard contractual clauses approved by the European Commission or ensure that the transfer is to a jurisdiction that is the subject of an adequacy decision by the European Commission.

As part of the recruitment and hiring process, Pax8 may transfer your personal data to other Pax8 entities, including our headquarters located in the United States. Pax8 has executed intracompany standard contractual clauses to cover personal data transfers between and among our businesses globally.

Please contact us if you want further information on the specific mechanism we have used to transfer your personal data.


Your rights and choices

The GDPR provides EU data subjects with certain rights regarding their personal data. Subject to certain conditions, you may have the right to ask Pax8 to:

  • Provide you with information about our processing of your personal data and give you access to your personal data (GDPR Art. 15).
  • Update or correct inaccuracies in your personal data (GDPR Art 16).
  • Delete your personal data (GDPR Art. 17).
  • Transfer a machine-readable copy of your personal data to you or a third party of your choice (GDPR Art. 20).
  • Restrict the processing of your personal data (GDPR Art. 18).
  • Withdraw consent that you have previously given us (GDPR Art. 7(3)). You may make this request at any time. Note that revocation of your consent will only apply to future processing activities and will not apply retroactively.
  • Object to reliance on our legitimate interests as the basis for processing of your personal data (GDPR Art. 21).

Note that these rights are not unlimited; there are exceptions to these rights under the GDPR and applicable local laws. For example, it will not be possible for us to delete your data if we are required by law to keep it (e.g., for tax and account purposes), or if we hold it in connection with a contract with you. Similarly, access to your data may be refused if making the information available would reveal personal data about another person or if we are legally prevented from disclosing such information. If we decline your request, we will tell you why, subject to legal restrictions. You can submit a request by email to [email protected] or our postal address provided below. Where necessary, we may request specific information from you to help us confirm your identity prior to processing your request.

If you would like to submit a complaint about our use of your personal data or our response to your requests regarding your personal data, you may contact us at [email protected]. If you have unresolved concerns, you also have the right to lodge a complaint with a supervisory authority in the Member State where you reside or work, or where the alleged infringement of the GDPR took place.


How to contact us

Pax8’s EU Data Protection Officer can be contacted via e-mail or regular mail at:

Pax8, Inc.
Attn: Data Protection Officer
Two the Distillery
2 Avon Street
Bristol BS2 0GR
Phone: 0800 335 7298
Email: [email protected]

Pax8 can also be contacted via e-mail or regular mail sent to our headquarters located in the United States at:

Attn: Chief Privacy Officer
5500 S. Quebec Street Suite 350
Greenwood, Village, CO, USA 80111
Phone: 1-855-884-PAX8 (7298)
Email: [email protected]

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