Candidate Privacy Statement
Manychat, Inc., together with all its affiliates and subsidiaries (hereinafter referred to as “we”, “us”, and the “Company”) is committed to protecting your personal data and respecting your privacy. The Company is committed to collecting and further processing your personal data pursuant to the applicable data protection regulations in the countries where the Company operates.
Table of Contents
1. What is this statement for?
This privacy statement explains the reasons we process your personal data, how we collect and handle your data, how we ensure its protection, how it is used, and the rights you have concerning your personal data. This statement applies to all individuals applying for roles with us and describes how we process your personal information as part of the recruitment process for our Affiliates.
In addition, California residents can consult Exhibit A which outlines additional rights and provisions.
We act as the “data controller” with respect to the information described in this Statement, and our contact information is provided at the end of this Statement.
2. To whom is this statement applicable?
This statement applies to job applicants, including those who submit CVs, cover letters, and other relevant personal data as part of the recruitment process, whether for a current position or in response to an open call. It also extends to candidates who are directly contacted by the Company for potential opportunities. For information about how we process personal information outside of such relationships, please see our Website Privacy Policy.
For purposes of the CCPA, this Statement supplements the Website Privacy Policy.
3. What personal data are we processing, for what purpose, legal basis, and period?
As part of the recruitment process, we will process various types of personal data. The legal basis mentioned in the below table is alternative and can vary based on the jurisdiction where we operate, considering the particularities of the local legislation. For California residents, we have identified the categories of Personal Information collected in Exhibit A attached at the end of this Statement.
| Purpose | Legal Basis | Categories of Data | Retention Period |
|---|---|---|---|
| Recruitment Process | Performance of a contract, legitimate interest | Name, contact information, CV, cover letter, job preferences, qualifications, professional background | For non-advancing candidates: during the recruitment process and after the end of the process in accordance with applicable laws. |
| Background Checks | Consent, legal obligations, legitimate interest | Employment history, references, criminal record checks (if applicable) or data you made publicly accessible (e.g. your LinkedIn profile) | For non-advancing candidates: during the recruitment process and for a period not exceeding the maximum statutory period required by law. |
| Interview Process | Performance of a contract, legitimate interest | Interview feedback, test results, communications during the interview | For non-advancing candidates: during the recruitment process and for a period not exceeding the maximum statutory period required by law. |
| Legal and Regulatory Compliance | Legal obligation | Identification details, nationality, work eligibility documents (e.g., visa, work permits) | For non-advancing candidates: during the recruitment process and for a period not exceeding the maximum statutory period required by law. |
| Diversity and Equal Opportunities | Consent or legitimate interest | Gender, nationality, ethnicity (optional for diversity purposes) | For non-advancing candidates: during the recruitment process and for a period not exceeding the maximum statutory period required by law. |
| Internal Analytical Purposes | Legitimate interest | Anonymized data regarding applications, selection process outcomes, and demographic information | Anonymized data can be kept indefinitely for internal statistical purposes. |
The personal data will be used only for the recruitment process and for determining your suitability for a role. We may also use your data for internal administrative purposes related to the recruitment process.
4. Where are we obtaining your personal data from?
We primarily collect your personal data directly from you through your application, CV, and other documents provided during the recruitment process. In some cases, we may collect personal data from:
- Referees: Information such as your previous employment details and performance, if applicable.
- Public Sources: For example, LinkedIn or other professional networks, where we may collect your public profile details, including work history, qualifications, and skills.
- Third Parties: We may also collect information from third parties, including your former employers, credit reference agencies, background check providers, or publicly available resources (such as social media networks).
If you fail to provide personal data when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), or to enter a contract with you, we may not be able to process your application further.
5. How will we use your data?
We will use the personal data collected about you to:
- Assess your skills, qualifications, and suitability for the role.
- Carry out background checks, reference checks, or criminal record checks where applicable and in accordance with the law.
- Communicate with you about your application and the recruitment process.
- Comply with legal, regulatory, or contractual obligations.
- For internal analytical purposes: We may aggregate and anonymize your personal data to analyze recruitment trends, improve the efficiency of our recruitment process, and monitor diversity and inclusion efforts. The anonymized data will be used for internal analysis, and no personally identifiable information will be retained in this context.
6. Will we use your sensitive data?
We may collect and process sensitive data such as:
- Disability status: For the purpose of providing reasonable adjustments during the recruitment process (e.g., special accommodations for interviews or tests).
- Nationality or ethnicity: For compliance with immigration laws or for diversity purposes.
We will only use this data where permitted by law and with your consent where required, if permitted by the applicable legislation.
7. Automated decision-making
You will not be subject to decisions based solely on automated processing that would have a legal or similarly significant effect on you during the recruitment process.
8. Data sharing
Your personal data may be shared with third parties, including:
- Our recruitment team and hiring managers: To assess your suitability for the role.
- Background check providers: For reference checks or verification of qualifications.
- External service providers: For technical support in managing the recruitment process (e.g., recruitment platforms or applicant tracking systems).
- Legal authorities or other public bodies: As required by law, such as verifying work permits or immigration status.
All third-party service providers are, where required by law, bound by confidentiality agreements and data protection agreements and are required to process your personal data in line with our data protection policies.
The personal data you entrust to our company may be transferred outside the country of your residence, including third countries. Where required by law, any transfer will be made subject to an adequate contract laying down the conditions of the transfer in accordance with the applicable privacy laws or in accordance with legal provisions. Your personal information will be transferred to the United States of America to Manychat, Inc.
9. Data security
We have implemented appropriate security measures to protect your personal data from unauthorized access, alteration, disclosure, or destruction. These measures include technical and organizational safeguards, such as encryption and restricted access. If you suspect any breach of your data security, please contact us immediately.
10. Data retention
Your data will be deleted after the end of the recruitment process, in accordance with applicable laws, if you are not selected for the role. If you are selected for a role, we will retain your data for the duration of your employment and subsequently for any statutory period required by law. If we will not advance with your application, we may retain your data, with your consent, for up to 1 year to potentially consider you for future openings, unless you request otherwise.
After the expiration of these retention periods, your personal data will be securely deleted or anonymized for internal analysis in accordance with applicable law. The anonymized data may be retained indefinitely for purposes such as recruitment process improvement or monitoring diversity and inclusion, but it will no longer be identifiable to you.
For California residents, we are required by law to maintain records of requests submitted under the California Consumer Privacy Act and how we responded to such requests for at least 24 months. We only use this information for recordkeeping purposes.
11. Your data subject rights
California residents have additional rights set out in Exhibit A below. Under applicable data protection laws, you have several rights regarding your personal data depending on your jurisdiction or the jurisdiction in which you are applying, including the right to:
- Right to Access and Information: You have the right to request access to your personal data held by the employer, as well as information about how your data is processed and any relevant aspects of this processing, including types of data, purposes of processing and third parties to whom the data is shared.
- Right to confirmation of the existence of the processing.
- Right to Rectification: You have the right to request the correction of inaccurate or incomplete personal data held by the employer.
- Right to Erasure: You have the right to request the deletion of your personal data, subject to certain legal and contractual limitations, including the necessity to comply with applicable employment and legal obligations.
- Right to Restriction of Processing: You have the right to request a restriction on the processing of your personal data under certain circumstances, such as if the data is inaccurate or the processing is unlawful.
- Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and, where feasible, to transmit that data to another controller.
- Right to Object: You have the right to object to the processing of your personal data, particularly where the processing is based on legitimate interests, direct marketing, or profiling.
- Right Not to Be Subject to Automated Decision-Making: You have the right not to be subject to decisions based solely on automated processing, including profiling, which have legal or similarly significant effects.
- Right to refuse the consent for the processing of your personal data or to revoke such given consent.
- Right to lodge a complaint to the competent national supervisory authority.
To exercise these rights, please contact us at privacy@manychat.com. We will handle your request in line with applicable data protection laws and aim to respond within a reasonable timeframe and in accordance with the limits set by the law.
12. Contact for data protection inquiries
If you have any questions about this statement or how we process your personal data, please contact us at privacy@manychat.com.
Exhibit A
California Privacy Addendum
CCPA Notice at Collection. We collect and process personal information as described in Section 3 of this Notice. The relevant CCPA categories for this information are indicated below. We may provide a separate notice at collection if we collect additional information or intend to use information for additional purposes. This Notice relates to personal information we may collect and process in the course of our relationship with you. For information about how we process personal information of individuals who do not have such a relationship with us, please see our Website Privacy Policy. This Notice supplements the Website Privacy Policy.
| Purpose | Categories of Data |
|---|---|
| Recruitment Process | Name, contact information, CV, cover letter, job preferences, qualifications, professional background CCPA Categories: Identifiers; Categories Described in the Customer Records Statute; Professional or Employment-related Information; Education Information |
| Background Checks | Employment history, references, criminal record checks (if applicable) CCPA Categories: Identifiers; Categories Described in the Customer Records Statute; Professional or Employment-related Information; Education Information; Sensitive Personal Information |
| Interview Process | Interview feedback, test results, communications during the interview CCPA Categories: Identifiers; Categories Described in the Customer Records Statute; Professional or Employment-related Information; Education Information; Sensitive Personal Information; Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information |
| Legal and Regulatory Compliance | Identification details, nationality, work eligibility documents (e.g., visa, work permits) CCPA Categories: Identifiers; Categories Described in the Customer Records Statute; Professional or Employment-related Information; Sensitive Personal Information |
| Diversity and Equal Opportunities | Gender, nationality, ethnicity (optional for diversity purposes) CCPA Categories: Identifiers; Categories Described in the Customer Records Statute; Professional or Employment-related Information; Sensitive Personal Information |
| Internal Analytical Purposes | Anonymized data regarding applications, selection process outcomes, and demographic information CCPA Categories: |
| Sensitive Information | Social security number, identification card (e.g., driver’s license, state ID card, passport), data revealing racial or ethnic origin CCPA Categories: Identifiers; Categories Described in the Customer Records Statute; Sensitive Personal Information |
Data Practices During the Last 12 Months
- Personal Information Collected: We have collected the categories of personal information listed below during the preceding 12 months:
- Identifiers
- Categories Described in the Customer Records Statute
- Characteristics of Protected Classifications
- Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information
- Professional or Employment-related Information
- Education Information
- Sensitive Personal Information
- Categories of Sources: We have collected the personal information identified in this Notice from you and through third parties, including background check providers and third-party references and websites.
- Business and Commercial Purposes for Collecting: We have collected the categories of personal information listed above for the following purposes:
- Recruitment Process
- Background Checks
- Interview Process
- Legal and Regulatory Compliance
- Diversity and Equal Opportunities
- Internal Analytical Purposes
- Personal Information Disclosed for a Business Purpose: We have disclosed for a business purpose the categories of personal information listed below during the preceding 12 months. We have disclosed each category of personal information to the following categories of third parties: (1) subsidiaries and affiliates; (2) advisors (e.g., accountants, attorneys); and (3) service providers (e.g., data storage, administration, technical support).
- Identifiers
- Categories Described in the Customer Records Statute
- Characteristics of Protected Classifications
- Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information
- Professional or Employment-related Information
- Education Information
- Sensitive Personal Information
- Business and Commercial Purposes for Disclosing: We have disclosed to the identified categories of third parties the categories of personal information listed above for the following purposes:
- Recruitment Process
- Background Checks
- Interview Process
- Legal and Regulatory Compliance
- Diversity and Equal Opportunities
- Internal Analytical Purposes
No Financial Incentives. We do not offer financial incentives or any price or service difference in exchange for the retention or sale of your personal information.
Notice of Right to Opt-out of Sale/Sharing. As a California resident, you have the right to direct us to stop selling or sharing your personal information to third parties and to refrain from doing so in the future. For purposes of the CCPA in the context of our employment or contractual relationship with you, we do not sell or share personal information as defined under applicable law.
Limited Use of Sensitive Personal Information. We only use or disclose sensitive personal information for purposes permitted by the CCPA and to which the right to limit does not apply.
Individual Rights. California residents have the rights described below. However, these rights do not apply in all instances and are subject to certain exceptions as a matter of law.
- Request to Know. As a California resident, you have the right to request: (1) the specific pieces of personal information we have collected about you; (2) the categories of personal information we have collected about you; (3) the categories of sources from which the personal information is collected; (4) the categories of personal information about you that we have sold or shared and the categories of third parties to whom the personal information was sold or shared; (5) the categories of personal information about you that we disclosed for a business purpose and the categories of third parties to whom the personal information was disclosed for a business purpose; (6) the business or commercial purpose for collecting, disclosing, selling, or sharing personal information; and (7) the categories of third parties to whom we disclose personal information. Our response will cover the 12-month period preceding our receipt of a verifiable request unless a longer period is requested by you.
- Request to Delete. As a California resident, you have a right to request the erasure/deletion of certain personal information collected or maintained by us. As described herein, we will delete your personal information from our records and notify any service providers and contractors (as defined under applicable law) to delete your personal information from their records. However, we are not required to honor a deletion request if an exemption applies under the law.
- Right to Correct. As a California resident, you have a right to correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes for which we process the personal information. We will use commercially reasonable efforts to correct the inaccurate personal information as directed by you.
- Right to Limit Use and Disclosure. As a resident of California, you have the right to limit our use and disclosure of your sensitive personal information to that use which is necessary to perform our services and provide our goods as requested by you, or as otherwise permitted by law. We only use or disclose sensitive personal information for purposes permitted by the CCPA and to which the right to limit does not apply.
- Right to Opt-Out. As a resident of California, you have the right to direct us to stop selling or sharing your personal information to third parties and to refrain from doing so in the future. For purposes of the CCPA, we do not sell or share personal information as defined under applicable law.
- Non-Discrimination. You have the right not to receive discriminatory treatment by us due to your exercise of the rights provided by the CCPA. We do not offer financial incentives and price or service differences, and we do not discriminate against consumers, employees, applicants, or independent contractors for exercising their rights under the CCPA.
Submission Process. You may submit a request to exercise one of the above rights via email to privacy@manychat.com. If a request is submitted in an incorrect manner or if it is deficient, we will either (1) treat the request as if it had been submitted via the designated manner, or (2) provide you with specific directions on how to submit the request or remedy any deficiencies, as applicable.
Verification Process. We are required to verify the identities of those who submit requests exercise the above rights. To determine whether the individual making the request is the consumer about whom we have collected information, we will verify your identity by matching the identifying information provided by you in the request to the personal information that we already maintain about you. As a part of this process, you will be required to provide your name, address, and telephone number. We will inform you if we cannot verify your identity.
- If we cannot verify the identity of the person making a request for categories of personal information, we may deny the request. If the request is denied in whole or in part for this reason, we will provide a copy of, or direct you to, our privacy policy.
- If we cannot verify the identity of the person making the request for specific pieces of personal information, we are prohibited from disclosing any specific pieces of personal information to the requestor. However, if denied in whole or in part for this reason, we will evaluate the request as if it is seeking the disclosure of categories of personal information about the consumer.
- If we cannot verify the identity of the person making a request to delete, we may deny the request.
- If there is no reasonable method by which we can verify the identity of the requestor to the degree of certainty required, we will state this in our response and explain why we have no reasonable method by which we can verify the identity of the requestor.
Authorized Agents. Authorized agents may submit requests via the methods identified in this Notice. If you use an authorized agent to submit a request to know or a request to delete, we may require: (1) the authorized agent to provide proof that you gave the agent signed permission to submit the request; (2) you to verify your identity directly with us; and (3) you to directly confirm with us that you provided the authorized agent permission to submit the request. However, we will not require these actions if you have provided the authorized agent with power of attorney pursuant to the California Probate Code.
Excessive Requests. If requests from a consumer are manifestly unfounded or excessive, in particular because of their repetitive character, we may either (1) charge a reasonable fee, or (2) refuse to act on the request and notify the consumer of the reason for refusing the request. If we charge a fee, the amount will be based upon the administrative costs of providing the information or communication or taking the action requested.