Digital Turbine Global Recruitment Privacy Notice
About this Notice
We, at Digital Turbine put great efforts in making sure that we secure personal information related to you and use it properly. This notice explains our privacy practices and how we handle personal information related to you when you apply for a job with Digital Turbine. Specifically, this notice will provide details about:
- what personal information needs to be submitted by job applicants (“Candidates”)
- what we do with that information and how we process it, and,
- the rights that you as a Candidate have in connection with the personal information and job application materials that you submit during the process.
Personal information means any information relating to an identified or identifiable natural person, and as defined in data protection or privacy laws that are applicable to our processing of personal information related to you.
- Purposes for Collecting and Processing Personal information related to you
We collect personal information related to you for recruiting purposes – so that we could assess your candidacy and suitability for a job with Digital Turbine, whether it is the position that you applied for, or other vacant positions, to be in contact with you during the recruitment process and to prepare to offer you an employment contract if we decide to hire you.
We also use personal information related to you for Digital Turbine’s human resources’ management in general –
- to maintain Digital Turbine’s HR record keeping;
- to comply with diversity, inclusion and other legal requirements and to protect Digital Turbine’s legal rights;
- to combine personal information related to you with information such as criminal background checks (where permitted by law) that Digital Turbine receives from third party service providers;
- to manage recruitment, other HR-related activities and personnel generally, for example, to conduct data analytics studies to review and understand better personnel retention and attrition rates;
- to manage business operations and governance, for example: auditing, HR development and handling frauds and other violations of the law;
- to comply with legal and other mandatory requirements, including to obey orders and subpoenas, to and to comply with supervision and enforcement actions;
- to support any corporate structure change, including mergers, acquisition and other corporate transactions; and,
- to monitor your use of any information and communication systems that we make available to you during your recruitment process and for cyber security purposes; and,
- when Digital Turbine believes in good-faith that using personal information related to you is necessary to protect the life, health, safety or other vital interest of Digital Turbine or any other person.
- Personal Information That We Collect
When you apply for a job at Digital Turbine, we will ask you to provide certain personal information that will help us evaluate your qualifications and candidacy and to stay in touch with you during the application and recruitment process. The Information we collect includes but is not limited to:
- Personal data connected to the identification of a Candidate such as: first name, surname, title, date of birth, place of birth;
- Contact information such as: address (street, zip code, country), phone number, email address;
- Eligibility information such as: resume/CV, cover letter, employment history (employers, job titles, length of employment) and educational background and training, linguistic capabilities, job skills, personal interests;
- Verification and background information and documents such as: diplomas, certificates, national IDs, driver’s license, passport, social security, birth certificate;
- Reference materials and documents such as: job references and letters of recommendation, job salary/payment history, military records, titles and licenses, immigration visa status, security clearance, background checks including criminal history (where permitted by law);
- Social media information such as your LinkedIn Profile;
- Information that you provide us about your work and personality traits such as answers during an interview, or answers to essay questions, or information about your salary expectations and work preferences;
- When you visit our ‘Careers’ page on our website, or view job positions, or click on the Apply button for specific positions, we and our third party service providers collect information such as the IP address of your device, which provides your device location, and other non-identifiable information that is used for analytical purposes, such as the type of browser, browser language, type of operating system, domain name of Internet service provider, web pages visited, times and dates of visits and the content you access on and/or through the Site.
- Sensitive Information
Sensitive information, such as health, genetic, biometric, sexual orientation and government issued IDs are sensitive and we will process such data only if we need to and are allowed to, and for specific purposes, for example: leaves of absence, social security and obligations under social protection laws, to ensure meaningful equal opportunity, to protect your and others’ vital interests, in disciplinary and legal proceedings, for work-related medical diagnosis and safety, for work-related statistics and otherwise to comply with the law.
If permitted by law, we will also process information about criminal records as part of background checks.
- How we Collect personal information related to you
- If you use our online application system to apply for a job with Digital Turbine, our HR platform service provider will collect personal information related to you on our behalf. We use a third-party service provider that handles our job recruitment process (see further information in the Sharing Personal Information section below)
- We also collect personal information related to you when you apply for a job position through our website.
- Legal Basis for Processing Personal information related to you
We will only process personal data related to you where legally permitted or where you have provided consent. Sometimes more than one legal basis applies depending on the processing activity. We will process personal information related to you on the following legal grounds:
- for a legitimate interest of Digital Turbine as it is necessary for us to fulfill our hiring and employment needs, for us to evaluate the qualifications and backgrounds of Candidates, and to communicate with you throughout the recruitment process.
- If consent is required, we will condition our processing of personal information related to you, with receiving appropriate consent from you. When we process personal information related to you based on your consent, you can withdraw consent at any time with future effect (although this may have an effect on our ability to consider your job application). Withdrawing consent will not affect the lawfulness of any processing we conducted prior to the withdrawal and will have no effect on mandatory processing of your information under applicable law.Processing personal information related to you is necessary for our compliance with legal obligations such as complying with immigration and employment laws and regulations.
- Your Choice
Applying for a job and submitting your job candidacy materials is voluntary and at any time, if you have already applied for a job and would like to withdraw your job candidacy, you can contact us and request that we stop considering your application and that we delete your profile and any materials we collected.
Our deletion of personal information related to you and job application materials will be completed in accordance with our Retention Policy as described below in this notice.
If you were required to provide your consent before submitting your job application materials and personal information, you can withdraw your consent at any time. You can exercise your choice by contacting us at: [email protected].
- Your Obligation
It is important that the personal data that we hold about you during the recruitment process is accurate and current. Please keep us informed if personal data related to you changes.
Cookies are small packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Digital Turbine uses Session Cookies for legitimate purposes, such as facilitation of the use of the Site and its features and tools. Your device removes session cookies when you close your browser session.
We also allow third parties, such as Google analytics and social media websites to place cookies on your device. These are persistent cookies. A persistent cookie has an expiry date. It remains on your device until it is expired or removed.
If you wish to delete cookies or limit the kinds of cookies that can be placed on your device you need to check out the settings in your browser, use the ‘Help’ tab or look for settings like ‘Options’ or ‘Privacy.’ From there, you can delete cookies, block them or control when they can be placed.
- Exercising Your Right of Access and Correction
If you are entitled by law to exercise the rights of access, correction and deletion of inaccurate data (collectively: the right of access), you can contact us at: [email protected] and request to access the personal information that we keep about you.
We will ask you to provide us certain credentials to make sure that you are who you claim to be and will make good-faith efforts to locate your personally identifiable information that you request to access.
In responding to your request, we will apply limitations available under applicable law, for example to protect our trade secrets and confidential information and to protect the privacy of others.
To the extent that you are entitled to a right of access under the applicable law, you can receive a copy of personal information related to you that we hold about you and request the correction, amendment or deletion of personal information related to you if it is inaccurate or if you believe that the processing of personal information related to you is in violation of applicable law.
We will use judgement and due care to redact from the data which we will make available to you, personally identifiable information related to others.
- Your Additional Rights
You may be entitled to additional rights, depending on the relevant law that governs our processing of personal information related to you. These rights include and if they are applicable, they may be subject to certain limitations and restrictions under the relevant law:
- Right to Erasure or Deletion –the right to request that we erase some or all of personal information related to you. We note that, for example, we will not delete any information that the law requires use to maintain, or that is necessary to protect vital interests.
- Right to restriction of processing – the right to request that we restrict or limit the processing of personal information, for example, if our processing is unlawful.
- Right to object –the right to object to our processing of personal information related to you, for, for example to unsubscribe from any distribution lists.
- Right to data portability – the right to receive a copy of personal information related to you in standard usable form and your right to transfer it to others. We note that any personal information related to you that we process based on our legitimate interests or compliance with legal obligations is not eligible for any transmission to another controller.
- Right not to be Subject to a Decision Based Solely on Automated Processing – We may use our service providers’ automated platforms to identify appropriate Candidates and process their personal information. However, our decision whether to hire you or not is made by our HR staff.
Please contact us at: [email protected] if you wish to make a request to exercise your rights or if you have a question about your rights.
If you would like further additional information about your rights in association with personal information related to you or if you believe that we are misusing or have misused your personal information, you contact your local data protection authority and you can also file a complaint with such authority.
- Retention of Your Personal Information
If your application for employment is unsuccessful, Digital Turbine will hold your data on file for six months after the end of the relevant recruitment process.
At the end of that period, your data is deleted or destroyed. 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 as an employee will be provided to you in a separate privacy notice.
However, we will maintain a record with details about your submission of the application with us, such as your name, interview dates and locations, our decision whether to hire you or not and other relevant information to establish exercise and defend legal claims, for internal review, oversight and operation of our HR efforts and if we are required under law to retain your personal information.
Retention periods can vary based on how long the recruitment process lasts and the time period between when you first apply and when a hiring decision is made in connection with your application.
You can let us know that you would like us to save personal information related to you for a longer period of time to take into account for future job postings.
- Sharing Your Personal Information
We will share personal information related to you in the following instances:
- With only the relevant Digital Turbine’s managers and HR teams to facilitate your application and the job recruitment process and for further purposes as described above in this notice.
- With our third-party service providers that handle our job recruiting, hiring, and on-boarding process, or with any additional service provides which help us with the recruiting process.
- With third party service providers that provide legitimate business functions for Digital Turbine, which will include processing personal information related to you. Such third-party service providers are engaged by us for the provision of, among others, data storage, information security and employee background checks.
- With a competent supervisory authority if we believe doing so is in accordance or otherwise required by an applicable law, regulation, judicial or legal process.
- With law enforcement or other authorities (including immigration, health, tax, national security) when it is necessary to protect the interests of our company or individuals.
- With another entity when it is required as part of a merger, acquisition or assignment of part or all of our business with that entity, or any other change of corporate structure.
- Transfer of Personal information related to you Outside Your Territory
As applicable, required, and relevant under laws that apply to our processing of personal information related to you –
- you hereby provide Digital Turbine your express and unambiguous consent to the transfer of personal information related to you to the US and Israel.
- We will use appropriate measures, such as standard contractual clauses between us and the recipient of the information, and where applicable, we will rely to adequacy recognitions by the applicable countries, to lawfully transfer personal information related to you from one territory to another. Contact Us
If you have any questions about this privacy notice or have any concerns about how we handle your personal information, please contact us at: [email protected].