This Applicant Privacy Notice (“Privacy Notice”) describes how Tego Inc., and its affiliates (collectively “Tego”, “us” or “we”) process your personal information when you join our Community, search or apply for a job and submit personal information to us via our portal, websites or other recruitment mediums, whether online or offline (the “Services“). We are the controllers of your personal information for the purposes of applicable data protection laws.

Personal Information We Collect

To process your application, we ask you to provide the personal information about yourself, for example when you apply for a particular job vacancy through our website/portal or, in case that you already are a Tego employee, during your employment relationship. All information is provided on a voluntary basis, and you determine the extent of information you provide to Tego.

Please bear in mind that some information may be necessary to complete an evaluation of your application and if it is not provided, our ability to consider you as a candidate may be limited.

(i)   Personal information

We may collect the following personal information about you:

• Personal details and contact information including email address, telephone number(s), and photograph;
• Professional and educational information related to your occupation, such as your current or previous employers, your job title, or other information about the organization with which you are affiliated. You may also provide your CV/resume and information about your qualifications or your education, such as your degrees, fields of study, the institutions you’ve attended, languages, professional memberships, certifications, details on performance management ratings and compensation;
• Career preferences (e.g., short-term and long-term goals, willingness to relocate, date available to relocate and location preferences);
• Personal information derived from your participation in our recruitment process, such as, for example, those obtained during interviews, or the emails we exchange with you regarding your application.
• Audio and visual information, such as your voice and likeness as captured in photographs, video or audio recordings if you participate in a phone or video interview, or if you visit our office.
• Any other personal information that you voluntarily choose to provide to us.

(ii)  Sensitive personal information

We may also collect special categories of personal information about you (also known as “special categories of personal information”) where we have a legal obligation to do so, or the information is relevant to your future working environment at Tego, or for the future provision of employment benefits, or with your explicit consent such as:

• Government-issued identification number (such as a social security number);
• Demographic information, which may include information about protected classifications, such as your age, gender, race, disabilities, sexual orientation, marital status, or veteran status;
• Health information (for example, to accommodate any disability you may have or dietary restrictions);
• Information relating to a person’s political opinions or religious beliefs or trade union membership;
• Information about an individual’s criminal offences or convictions, as well as any other information deemed sensitive under applicable data protection laws. Where permitted by law and to the extent applicable, Tego may also need to carry out background and/or criminal checks to determine your suitability for an open position or opportunity at Tego.

We do not require you to provide us with sensitive personal information unless it is necessary for the purposes of carrying out our regulatory obligations (e..g., for equal opportunity monitoring), or unless you have provided your explicit consent. Except to the extent required by law, the provision of this information will be entirely voluntary. Tego is committed to a true inclusive and diverse workforce. By providing us with your equal opportunity data, you allow us to better understand our employee profile in terms of equal opportunities data and the action we need to take to attract, promote and retain a diverse workforce regardless of age, disability, gender, race, religious or philosophical beliefs and sexual orientation.

(iii) Personal information we collect automatically from you

We may automatically collect certain information from you about your visit to our websites using “cookies” and other similar tracking technologies. For further information about the cookies we use on the website through which you submit your application, please read our Cookie Notice (this will be to our cookie document).

Sources of Personal Information

We may collect your personal information directly from you or indirectly from third parties who are lawfully entitled to share your information with us such as:

• Employment agencies, background/employment check or identity verification service providers;
• Recruitment agencies (for example, when a recruitment agency identifies you as a potential candidate);
• Publicly available information about you from sites such as LinkedIn or your current employer’s website. You may also choose to provide us with access to certain personal information stored by third parties (for example, LinkedIn, Twitter, Google or Facebook). By authorizing Tego to have access to this information, you agree that we may collect, store and use this information in accordance with this Privacy Notice;
• By reference or word of mouth (for example, through a referral from a current or former employee). For referrals, the person who is referring you will be responsible for obtaining your consent to provide us with your personal information.

Purposes for which Personal Information is used

We use your personal information for the following purposes:

• To evaluate your application and make hiring decisions;
• Communicate with you and to inform you about the recruitment and/or your application(s) or any other required communications;  
• Comply with applicable legal and regulatory requirements and in order for us to establish, exercise or defend a legal claim;
• Employment and corporate management (for example, establish a basic employment record if you are hired);
• To carry out aggregated reports / analysis regarding candidates’ activity data (e.g. career site traffic, candidate funnel, source of hire, recruiting campaign success);
• Only where you are a resident of the United States: To send you communications via SMS, specifically:

(i)     1-1 SMS communications in connection with your application to a particular job vacancy; and/or

(ii)    subject to your express consent, SMS campaign communications about employment opportunities, job affairs and application updates.

You will be able to opt out and/or revoke your consent for receiving the abovementioned communications following the instructions given in your profile.

If you are offered and accept employment with Tego, the information collected during the application and recruitment process will become part of your employment record.

Automated Processing and Profiling

Subject to your express consent (which you voluntarily provide when joining our Talent Community or when giving the appropriate consent during the application process), we conduct ‘profiling’ to evaluate your suitability for particular job opportunities. This involves using a matching algorithm that is able to evaluate your employment profile and predict your eligibility for a particular job opportunity. We carry out this automated processing for the purposes of:

• helping recruiters match candidates’ profiles to job opportunities by suggesting candidates for consideration for a specific job opportunity; and
• sending personalized job recommendations to you based on your profile and/or preferences or other information that may be of interest for you such as Tego news, webinars and events.

Please note that based on this profiling, you may not be considered for certain job opportunities unless you have applied for them directly.

We do not make hiring decisions based solely on automated decision-making processes and/or profiling. Your personal information will be subjected to human-made decisions as the ultimate hiring decision will be made by the recruiters or hiring manager.

The Legal Bases for Processing Your Personal Information

Certain jurisdictions require Tego to have a legal basis for processing your personal information. Where applicable law requires us to justify our processing activities, our legal basis for collecting and using your personal information as described in this Privacy Notice will depend on the personal information concerned and the specific context in which we collect it.

• Consent. In general, we will normally collect personal information from you where we have your consent to do so and where we need your personal information to process your application. By accessing our website/portal, joining our Talent Community or applying for one of our job positions, you provide your consent to Tego to collect and further process the personal information described above for the purposes described in this Privacy Notice. You may withdraw your consent at any time by sending us an email to TegoPrivacy@TegoInc.com.
• Legitimate interests. In Tego’s legitimate interests, namely the recruitment, selection, evaluation and appointment of new employees and the management and administration of the recruitment and the HR process to the extent our legitimate interests are not overridden by your fundamental rights and freedoms.
• Legal obligations. Compliance with Tego’s legal obligations where employment law or other laws require the processing of your personal information (for example to the extent the law requires the monitoring equality of opportunity and diversity).
• Vital interests. We may also need your personal information to protect your vital interests (for example, health and safety reasons if you attend an interview at our site)

If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please send an email to TegoPrivacy@Tego.com.

Who We Share Your Personal Information With

Tego will only share your personal information with third parties under the following circumstances:

• Tego group entities. We may share your personal information with other group entities located in jurisdictions around the world for evaluating your profile and consideration for any recruitment opportunities at a group level.
• Service providers We may specifically share your personal information with third party service providers that perform specific services on our behalf (for example, recruitment and outsourcing staffing providers and analytics providers). Such third parties may vary depending on your country and will change from time to time but may include Phenom People, Inc., Cornerstone OnDemand Inc., and their respective third-party providers.
• Tego employees. If you are already a Tego employee, please note that some sections on your profile are public and, therefore, visible to all Tego employees (specifically, your name, title, photograph, skills, interest areas, work experience and education). However, such sections are editable and you will be able to choose which information about you is shown in your profile. Please note that the career goals, relocations and profile status “open to new opportunities” sections will not be public and, therefore, not visible to all Tego employees (only to Tego’s Talent Team).
• Other third parties. Tego may share your personal information with any competent law enforcement body, regulator, government agency, court or third party where we believe the disclosure is necessary under applicable law or in the good-faith belief that such action is necessary to exercise, establish or defend our legal rights or to protect your vital interests or those of another person. We may also share your personal information with others with your consent or at your direction (e.g. a referee or professional association).

International Transfers of Personal Information

If you are accessing our Services from outside the United States, please be aware that your personal information may be transferred to, held, stored or used across various locations worldwide such as the US, Mexico and India in accordance with applicable law. This means that when we collect your personal information it may be processed in countries that may have data protection laws that are different to the laws of your country. However, Tego will always take reasonable steps to protect your privacy and to provide a level of protection of personal information that is comparable to that of your country of residence which include implementing the European Commission’s Standard Contractual Clauses which may be found at the Commission’s website at https://ec.europa.eu.

Retention

We will retain your personal information for as long as necessary in connection with the purposes described in this Privacy Notice and in accordance with Tego’s Record Retention Schedule or as required by applicable law.

Your Rights

Depending on applicable law, you may have certain rights with respect to your personal information. If you are a Californian resident please refer to below.

• You may have the right to access, correct, update or request deletion of your personal information;
• You can object to the processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information;
• You may have the right not to have a decision made about you that is based solely on automated processing, including profiling if that decision produces legal effects about you or significantly affects you. Tego does not, as part of its recruitment process, make solely automated decisions about candidates.
• Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent; and
• You have the right to complain to a data protection authority about our collection and use of your personal information.

We will facilitate your exercise of the rights that apply to you in accordance with applicable law. To exercise any of your rights relating to your personal information, please contact us through HR Help, or send an email to TegoPrivacy@Tego.com.

Additional Information for California Residents

If you are a resident of the State of California, this section supplements Tego’s Applicant Privacy Notice.

(i)      Categories of Personal Information Collected and Disclosed

Tego has collected and disclosed the following categories of personal information for our business purposes in the preceding twelve-months: 

CATEGORIES	WE COLLECT
A. Identifiers such as name, date of birth, gender, email address, telephone numbers, postal address, online identifiers, social media account and other identifiers.	Yes
C. Characteristics of protected classifications under California or federal law such as race, ethnicity, religious or philosophical beliefs, trade union membership, health data, biometric information, genetic data, disability, veteran status, sexual orientation, personal mail, email and text messages (unless Tego is the intended recipient), government identifiers (e.g., social security number), driver’s license, passport, financial and banking information.	Yes
F. Internet or other electronic network activity information, such as browsing history, interactions with Tego websites, email and text messaging services.	Yes
G. Geolocation data, such as device location and IP location.	Yes
H. Audio, electronic, visual, thermal or similar information, such as your voice and image, video or audio recordings if you participate in a phone or video interview or if you visit our offices.	Yes
I. Professional or employment-related information such as your occupation, current or previous employers, job title, educational history, academic and professional qualifications, resume, job history, hiring references, interview notes and assessments, languages, professional memberships, certifications, performance management ratings, compensation, location preferences and travel preferences.	Yes
K. Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.	Yes

(ii)      Your rights

You have the right to send us a request for the following rights covering the twelve-month period that precedes your request. Please note that these rights are not absolute and in certain cases are subject to limitations as specified in applicable law:

• The right to know what personal information we have collected about you, the categories of sources from which we collected your personal information; the business or commercial purpose for which we collected your personal information for, and the categories of third parties with which we disclose your personal information;
• The right to delete your personal information;
• The right to correct inaccurate personal information about you;
• The right to opt out of the sale or sharing of your personal information;
• The right to limit the processing of your sensitive personal information;
• The right to be free from unlawful discrimination for exercising your rights under applicable laws.

We will facilitate your exercise of the rights that apply to you in accordance with applicable law and, considering the type and sensitivity of the personal information subject to the request, for your protection, we may need to request verify your identity and request additional information from you.To exercise any of your rights relating to your personal Information, please contact send an email to TegoPrivacy@Tego.com.