Applicant Privacy Notice

Effective date: 7 July 2023

Last Updated: 1 April 2024

1. Purpose and Scope of Notice

Keywords Studios Group (“Keywords”, “we”, “us” or “our”) knows that you care about how your Personal Data is used and shared, and we take your privacy seriously. When we reference Personal Data, we mean any information which Keywords has or obtains or which an individual provides to us from which that individual can be directly or indirectly personally identified or as that term (or similar term) is defined under applicable law.

Accordingly, we have implemented this Applicant Privacy Notice to explain how your Personal Data will be handled by Keywords where:

• You participate in a Keywords recruitment initiative; 
• You voluntarily submit your CV/resume to a representative of Keywords on an ad hoc basis; 
• You apply for an advertised job with Keywords in; and/or
• a recruiter provides your CV/resume to Keywords and we arrange a job interview with you.

Overall, your Personal Data will be under the responsibility of Keywords and the specific data controller of your Personal Data is the member of Keywords to whom your Personal Data is sent. For more information about Keywords, including a full list of entities in Keywords, please refer to Keywords’ contact page (www.keywordsstudios.com/contact). These entities within Keywords have put in place procedures to ensure that your Personal Data is protected, as can be seen in further detail in our general Privacy Notice that is available on our website: https://www.keywordsstudios.com.

Depending on your place of residence, additional information or rights may be available to you ‎under locally applicable law. ‎If you are a California resident, please also refer to the California Addendum to this Applicant Privacy Notice. If you are a resident of Canada, please also refer to the Canada Addendum to this Applicant Privacy Notice.‎ In the event that ‎there is a conflict between this Applicant Privacy Notice and a local addendum, ‎the provisions of the local addendum will prevail to the extent required to ensure compliance with applicable data protection laws.‎

This Applicant Privacy Notice applies to any and all job applications submitted, and recruitment initiatives coordinated by Keywords. If you have any questions or concerns about this Applicant Privacy Notice, please contact us at [javascript protected email address].

IMPORTANT: When you provide your CV to a recruiter who subsequently sends it to us, we encourage you to read the relevant recruiter's data protection notice to understand how your Personal Data is processed by the recruiter (as a separate and independent controller to us).

2. Application of this Notice

This Applicant Privacy Notice applies to the way we collect and process your Personal Data from the time you provide Personal Data in an application up to the point at which you commence employment with us (if at all). Once you commence employment, the way we process your Personal Data will be governed by our Employee Privacy Notice (which will be made available to you when you commence your employment with Keywords).

3. What Personal Data We Process

As part of the recruitment and job application process, and to the extent permitted by applicable law, we collect the Personal Data that you submit to us, which may include:

• Personal details such as your name, gender, residential address, email address, contact telephone numbers, nationality, marital status, country of birth or previous criminal convictions (where permitted by applicable law);
• Details about your previous employment such as your length of service and your role; 
• Details about your qualifications such as your skills, education, the languages you speak (including your proficiency), your eligibility to work in a particular country (e.g., your citizenship or visa details), your experience in the job you apply for and other industries; 
• Details about your preferences such as positions you may be interested in, information about when you may be available to interview and/or start work for Keywords (i.e. your current notice period) or work on ongoing basis (e.g. full or part time or on weekends), whether you are open to relocation or working remotely, whether you are willing to travel for work and whether you have your own transport; 
• Details you may provide to us in response to our queries or questions at interview stage (including information about you which we generate throughout the interview and/or recruitment process); and
• Details about you which we gather from publicly available sources such as the internet and your social media accounts where such searches are relevant to the job you have applied for within Keywords.

If you apply for a position through LinkedIn, we may use the information you have previously provided to LinkedIn to populate your application. We will ask you to authorise LinkedIn to share your Personal Data with us for this purpose.

It is necessary for us to process your Personal Data in order to assess your job application and/or include you in a recruitment initiative. Ultimately, it may also be necessary for us to process your Personal Data in order to take steps to offer and enter into a contract of employment with you. In the event that you do not wish to provide us with your Personal Data for the purposes outlined in this Applicant Privacy Notice, we will not be able to assess your job application and/or include you in a recruitment initiative and/or offer you a contract of employment.

Please note that should you include information you think is relevant to your job application or the recruitment initiative, including cover letters, references from your previous employers and other documents that are likely to contain your Personal Data, we will hold and process any such Personal Data in accordance with the terms of this Applicant Privacy Notice. 

4. Why we process your Personal Data 

If you are from a region that requires a legal basis for processing personal data (such as the European Union or the UK), our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it but we will only process your Personal Data if we have a lawful basis for doing so. In such circumstances, the table below details how Keywords will use your Personal Data for our commercial or business purposes (“Purposes”) and the context for which we use your Personal Data (“Legal Basis”). 

Where required by applicable law, we will only use your Personal Data for the purposes for which we collect it (as outlined in this section), unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you as and when required by applicable data privacy laws and we will explain the legal basis that allows us to do so. 

5. Disclosure of Personal Data

We may disclose some or all of your Personal Data to the following parties: 

• Internal business units such as Human Resources, IT, Finance/Payroll, Keywords managers, system administrators and support staff who have advertised a vacancy within their unit or who will interview you;
• Your previous employers where you have provided them as a reference;
• Recruitment agencies; 
• Members and shareholders of Keywords; 
• Outsourced service providers who assist Keywords with recruitment initiatives and campaigns such as Workable;
• Other third-party service providers, such as organisations software  and
• Professional advisors such as legal advisors, consultants and accountants. 

6. Transfer of your Personal Data

We may transfer your Personal Data outside the European Economic Area ("EEA") to other members of Keywords and to other entities (“Recipients”). Certain Recipients (our third-party service providers and other companies within Keywords’ group) who process your Personal Data on our behalf may transfer your Personal Data outside the EEA to a country that does not provide an adequate level of protection to your Personal Data. Where such transfers occur, it is our policy that: a) they do not occur without our prior written authority; and b) that an appropriate safeguard such as the Standard Contractual Clause Contracts or othertransfer mechanisms approved by the European Commission and supervisory authorities (such as the Data Protection Commission) is put in place to protect your Personal Data. 

7. Retention of your Personal Data 

Keywords endeavours to ensure that Personal Data will be deleted or anonymized as soon as the ‎purposes of collection are achieved unless we have legitimate reasons to retain such information in accordance ‎with our retention schedules.‎

Where you are a successful job applicant, the Personal Data generated by us and provided by you over the course of the job application/recruitment process will be retained by us for the purpose of your contract of employment. Such Personal Data will be retained in accordance with our Employee Privacy Notice (which will be available to you when you commence employment). 

Where you are an unsuccessful job applicant and unless otherwise agreed, we will retain your Personal Data for a period of up to 12 months after you attend an interview or submit a job application for the purposes of both contacting you in relation to future vacancies within Keywords which we think may be of interest to you and for the purpose of defending potential employment equality claims which you may bring against us. 

Please note that in certain circumstances, we may hold your data for a longer period, for example, if we are processing an ongoing claim or believe in good faith that the law or a relevant regulator may reasonably in our view expect or require us to preserve your Personal Data. 

8. Security of Data

Keywords is committed to protecting the security of the Personal Data you share with us. Keywords uses a variety of technical and organisational methods to secure your Personal Data in accordance with applicable laws.

9. Your Rights and How to Exercise Them

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at [javascript protected email address]. 

• Access:  You may at any time request a copy of your Personal Data from Keywords. 
• Rectification, Erasure & Restriction:  If you believe that any Personal Data we are holding about you is incorrect or incomplete, you the right to correct any inaccuracies in, and in certain circumstances, to request erasure, or restriction on the use, of your Personal Data, and to object to certain uses of your Personal Data, in each case subject to the restrictions set out in applicable data privacy laws. 
• Withdrawal of Consent:  If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right has the right to change your mind and withdraw consent to future processing of Personal Data. 
• Portability:  You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
• Objection:  Where Keywords is relying on a legitimate interest, in order to use and disclose Personal Data, you may to object to such use or disclosure of your Personal Data, and we will cease to use and process the Personal Data for that purpose, unless we can show there are compelling legitimate reasons for processing to continue or we need to use the Personal Data for the purposes of legal claims. 
• Right to File Complaint:  You have the right to lodge a complaint about Keywords’ practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.

Please note that not all the rights are absolute and there will be certain circumstances in which we are unable to fulfil the above rights. In all cases, we will provide you with a prompt response and a full explanation of our decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

The above rights do not apply to residents of California or Canada, whose rights are detailed in the local addendums. 

10. Changes to this Applicant Privacy Notice 

We may need to change this Applicant Privacy Notice from time to time to reflect changes in technology, law, business operations or any other reason we determine is necessary or appropriate, but we will alert you to any material changes by placing a notice on the Website, by sending you an email and/or by some other means. 

11. Contact Information

If you have any questions or queries about this Applicant Privacy Notice, the ways in which we collect and use your personal data or your choices and rights regarding such collection and use, please contact us at: 

• Email: [javascript protected email address]; or
• Address: South County Business Park, Leopardstown, Dublin 18, D18 T9P8, Ireland. 

California Addendum

This California Addendum and Notice at Collection (“CA Applicant Notice”) provides specific information for residents of California who apply to work with Keywords. This CA Applicant Notice is intended to satisfy our notice requirements under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (Cal Civ. Code § 1798.100 et seq.) (“CCPA”) and explain how your Personal Data will be handled by Keywords. Personal Data, as used in this CA Notice, also includes “personal information,” as that term is defined under applicable state privacy laws.

1. Scope

This CA Applicant Notice applies to applicants and other candidates for employment who are California residents and who apply to a position with Keywords. This CA Applicant Notice does not address or apply to our collection of Personal Data that is not subject to the CCPA. 

For purposes of this CA Applicant Notice, Personal Data does not include the following:

• Publicly Available Information. Information that is lawfully made available from government records, or information we have a reasonable basis to believe is lawfully made available to the general public by you or by widely distributed media or by a person to whom you have disclosed the information and not restricted it to a specific audience. 
• Protected Health Information. Information governed by the Health Insurance Portability and Accountability Act (“HIPAA”).
• Deidentified or Aggregated Information. Information that is deidentified or aggregated.
• Information Covered by the Fair Credit Reporting Act (“FCRA”). Information provided or issued by consumer reporting agencies that are subject to the FCRA (e.g., information contained in background check reports we obtain as part of our applicant screening process).

2. What Personal Data do We Process?

As more fully described in the What Personal Data We Process section of the Applicant Privacy Notice above, we collect (and have collected within the last twelve (12) months) the following categories of Personal Data:

• Identifiers. Such as real name, alias, job title, address, unique personal identifier, online identifier, email address, date of birth, social security number, driver’s license number, and other government identifiers. 
• Characteristics of Protected Classifications. Such as age (40 years or older), race, ancestry, national origin, citizenship, physical or mental disability, sex, veteran or military status, and other characteristics of protected classifications under California or federal law.
• Internet or Other Electric Network Activity Information. Such as information about applicants’ interaction with our portals, website, applications, or advertisements, including, but not limited to, browsing history, clickstream data, and search history.
• Audio, Electric, Visual, or Similar Information. Such as information collected via call recordings, recorded meetings, videos, photographs, and video footage to secure our offices and premises.
• Employment-Related Information. Such as previous positions held, skills and experience, job duties, certifications, and licenses.
• Education Information. Such as education records, including grades, transcripts, student disciplinary records, or any other related information you chose to provide.
• Sensitive Personal Information. Such as your social security number, driver’s license number, race or ethnic origin, medical condition, and physical or mental disability.
• Inferences and Preferences. Such as inferences and preferences reflecting an Applicant’s preferences, characteristics, attitudes, behaviours, and abilities.

3. Disclosure of Personal Data to Third Parties and Other Recipients

The categories of Personal Data we may have disclosed for a business purpose in the preceding twelve (12) months include: 

• Identifiers; 
• Characteristics of protected classifications;
• Internet or other network activity information; 
• Audio, electronic, visual, or similar information; 
• Employment-related information; 
• Education information
• Inferences; and
• Sensitive personal data.

The categories of third parties and other recipients to whom we may have disclosed Personal Data for a business purpose may include: 

• Affiliates and subsidiaries; 
• Business partners; 
• Vendors and service providers; 
• Data analytics and marketing providers; 
• Government entities (as and when required); and
• Operating systems and platforms.

4. Sources of Personal Data

We generally collect Personal Data from the following categories of sources: 

• Directly or indirectly from you; 
• Recruiters;
• Service providers;
• Social media sites (e.g., LinkedIn).
• Affiliates and subsidiaries; and
• Advertisers and analytics providers.

5. Purposes of Collecting and Disclosing Personal Information. 

As more fully described in the Why We Process Your Personal Data section of the Applicant Privacy Notice above, in general we collect and otherwise process Personal Data for the following business or commercial purposes:

• Recruiting and hiring purposes, including applicant screening, conducting background checks, evaluation of qualifications and eligibility for employment, communicating with applicants, scheduling interviews, making job offers, promoting recruitment events, notifying you of other potential opportunities with Keywords, and to obtain feedback.
• Complying with legal obligations, including supporting our equal opportunity employment practices, for health and safety purposes, and for tax, accounting, and recordkeeping purposes.
• Defending and protecting our rights, including managing and responding to legal disputes and to otherwise establish, defend, or protect our rights or interests, or those of others.

Sensitive Personal Data. We do not collect, use, or disclose sensitive personal data beyond the purposes authorized by the CCPA.

6. Sale and Sharing of Personal Information

The CCPA, define "sale" as disclosing or making available Personal Data to a third-party in exchange for monetary or other valuable consideration, and “sharing” as disclosing or making available Personal Data to a third-party for purposes of cross-contextual behavioural advertising. We do not “sell” or “share” any applicant Personal Data. We also do not sell or share Personal Data about individuals we know are under age sixteen (16).

7. Retention of Your Personal Data

We retain your Personal Data as described above in the Retention of your Personal Data section of the Applicant Privacy Notice above.

8. Your Privacy Rights and Choices

California residents have the following rights regarding their Personal Data, subject to certain exceptions and qualifications under the CCPA.

• Access and Data Portability. You may have the right to request details about the Personal Data we have collected about you, such as whether we have collected Personal Data about you, the categories of sources, the purposes for which we have collected the Personal Data, the categories of recipients and the specific pieces of Personal Data we have collected. You may also have the right to receive a copy of your Personal Data in a readily usable format.
• Correction. You may have the right to request we correct incorrect or inaccurate Personal Data, subject to restrictions regarding the determination of accuracy of the existing Personal Data.
• Deletion. You may have the right to request deletion of your data unless an exception applies. Examples of exceptions include when we need to keep data to continue providing the Service, meet legal obligations, detect fraud, investigate violations of our Terms of Use (which is available on our website: www.keywordsstudios.com) or address security issues.
• Opt-Out of Sale, Sharing, or Targeted Advertising. We do not “sell” or “share” applicant Personal Data or use it for targeted advertising purposes, so there is no need to exercise your right to opt-out.
• Limit Use and Disclosure. We do not engage in uses of sensitive Personal Data that would trigger a right to limit use and disclosure of sensitive personal information under applicable state privacy law.
• Opt-Out of Profiling with Legal or Significant Effects. You may have the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects. However, as stated above, we do not engage in such activities as described under applicable state privacy law, so there is no need to exercise this right.
• Non-Discrimination. We will not discriminate against you in terms of price or service level for exercising any of the rights described in this section.

9. Exercising Your Privacy Rights

If you have any questions or queries about this CA Applicant Notice, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please contact us at: 

• Email: [javascript protected email address]; or
• Phone: +1 818 729-8508. 

Canada Addendum

This Canada Addendum (“Canada Applicant Notice”) provides specific information for residents of Canada who apply to work with Keywords. This Canada Applicant Notice is intended to satisfy our notice requirements under the the Personal Information Protection and Electronic Documents Act (Canada), the Act respecting the protection of personal information in the private sector (Québec), the Personal ‎Information Protection Act (Alberta), and the Personal Information Protection Act (British ‎Columbia)‎‎(collectively the “Canadian Privacy Laws”)and explain how your Personal Data will be handled by Keywords. Personal Data, as used in this Canada Applicant Notice, also includes “personal information,” as that term is defined under applicable Canadian Privacy laws.

1. SCOPE

If you are a resident of Canada, this Canada Applicant Notice applies to our handling of your Personal Data, in addition to the provisions of the Applicant Privacy Notice. We will only collect, use, communicate, and otherwise handle or process your Personal Data in compliance with Canadian Privacy Laws each as may be applicable to your situation.

Unless otherwise specified in this Canada Applicant Notice, all capitalized terms shall have the same meaning as that set out in the Applicant Privacy Notice. To the extent that there is a conflict between this Canada Applicant Notice and the Applicant Privacy Notice, the provisions of this Canada Applicant Notice will prevail for residents of Canada only. You may have different rights depending on your province or territory of ‎residence within ‎Canada: please consult the sections below relevant to your ‎province or territory of residence.‎

2. CONSENT

Notwithstanding any information provided in the Applicant Privacy Notice regarding legal basis for processing and unless otherwise allowed by Canadian Privacy Laws applicable in your province or territory of ‎residence, we will only ‎‎collect or use your Personal Data ‎with your consent.‎ You are not obliged to consent to the collection or use of your Personal ‎Data, ‎‎however, please note that if you do not provide your consent‎ for the purposes outlined in the Applicant Privacy Notice and this Canada Applicant Notice then we ‎will not be able to assess your job application, include you in a recruitment initiative or offer you ‎a contract of employment.‎

Your consent can be express or implied, and may be ‎provided verbally, in writing, in-person, electronically ‎or otherwise.‎

You have the right to withdraw your consent to further use, communication or processing of your ‎Personal ‎Data, as further explained below in the Your Privacy Rights‎section of this Canada Applicant Notice.‎

To the extent that you are providing us with the Personal Data of third parties (e.g. family or dependents), you acknowledge and confirm having obtained consent from any such individuals, as may be required by applicable Canadian Privacy Laws.

3. YOUR PRIVACY RIGHTS

Residents of Canada have the following rights regarding your Personal Data that we hold, subject to ‎any conditions or limitations set out in applicable Canadian Privacy Laws:‎

• Informed. You have the right to be informed of the Personal Data we collect, use, communicate, or otherwise process about you and how we process it. We inform you through this Canada Applicant Privacy Notice, through information provided to you via policies and procedures and by answering your specific questions and requests when you contact us.   
• Access. You may at any time request a copy of your Personal Data that Keywords may hold.
• Rectification. You have the right to ask us to rectify inaccurate Personal Data about you.
• Erasure. You have the right to ask us to erase Personal Data about you in certain circumstances. For example, you may have the right ask us to erase Personal Data: a) that is obsolete; and / or b) that is not justified by the purpose of the file.
• Portability. If you are a resident of the province of Québec, you can ask for a copy of your Personal Data in a structured, commonly used technological format. You can also request that we transmit the data to another third party you designate, where technically feasible.
• Automated decision making. When we make an automated decision about you (i.e. a decision based exclusively on automated processing of your Personal Data, including profiling), we will only do so when allowed under Canadian Privacy Laws and we will inform you about this.  You will be given the opportunity to submit observations to a person who is in a position to review the decision. We will also, upon request, inform you of the information used to render the decision and of the parameters considered.
• Withdrawal of consent. You have the right to change your mind and withdraw your consent to future processing of Personal Data by writing to us at [javascript protected email address]. This will however not affect the lawfulness of any processing of your Personal Data prior to the time you withdraw your consent, nor does this create an obligation for us to delete your Personal Data if we are otherwise allowed to retain it under applicable Canadian Privacy Laws.
• Right to file a complaint. You have the right to lodge a complaint about Keywords’ practices with respect to your Personal Data with the supervisory authority of your province of residence. If you are a resident of the province of British Columbia, you should contact the Office of the ‎Information & Privacy Commissioner for British Columbia at https://www.oipc.bc.ca/. If you are a ‎resident of the province of Alberta, you should contact the Office of the Information and Privacy ‎Commissioner of Alberta at https://oipc.ab.ca/. If you are a resident of the province of Québec, ‎you should contact the Quebec Commission d’accès à l’information at https://www.cai.gouv.qc.ca/.‎ Residents of any other province or territory should contact the Office of the Privacy Commissioner of Canada at https://www.priv.gc.ca/en/. 
• De-indexation. If you are a resident of the province of Québec, you have the right to request, in certain ‎circumstances, that we cease ‎‎disseminating your Personal Data or to ‎de-‎‎index any hyperlink that allows ‎access ‎to that Personal Data by ‎technological means, if ‎‎such dissemination ‎contravenes ‎applicable law.‎

We will take all reasonable steps to ensure that your request can be addressed within the time periods specified under applicable Canadian Privacy Laws.

Please note that not all rights are absolute and there will be certain circumstances in which we are unable ‎to fulfil the above rights. In all cases, we will provide you with a prompt response and a full explanation of ‎our decision as required by applicable laws.‎

4. RETENTION OF YOUR PERSONAL INFORMATION ‎

Unless otherwise stated in this section, we retain your Personal Data as described above in the Retention of your Personal Data section of the Applicant Privacy Notice above.

Where you are an unsuccessful job applicant and unless otherwise agreed, we will retain your Personal ‎ Data for a period of up to 3 years after you attend an interview or submit a job application for the ‎purposes of both contacting you in relation to future vacancies within Keywords which we think may be of ‎interest to you and for the purpose of defending potential claims which you may bring against us. ‎

We will keep Personal Data used to make a decision affecting you for at least one year after ‎using it to ‎make the decision.‎

5. CROSS BORDER TRANSFERS OF PERSONAL DATA

From time to time, your Personal Data may be transferred outside of your province or country of residence to be used or otherwise processed for the purposes described in the Applicant Privacy Notice and this Canada Applicant Notice.

Certain recipients (our clients, vendors, third party service providers and other companies within Keywords) who process your Personal Data on our behalf may transfer your Personal Data to jurisdictions with data protection laws which do not provide the same level of protection as Canadian Privacy Laws. Applicable laws in those ‎jurisdictions might permit foreign governments, courts, law enforcement or ‎‎‎‎regulatory agencies to ‎access, use or disclose Personal Data in those jurisdictions.‎

Where such transfers occur, it is our policy that:

• They do not occur without our prior written authority;
• We will conduct any necessary data privacy impact assessments prior to such transfers;
• Appropriate safeguards are in place to protect your Personal Data and ensure that the transfer of your Personal Data is in compliance with applicable data protection laws. 
• That an appropriate transfer agreement is put in place to protect your Personal Data. 

Keywords is a party to an Intra-Group Data Transfer Agreement which governs the transfer of Personal Data across all members of the Group in a manner consistent with the requirements of all applicable data protection laws, including Canadian Privacy Laws.

Further information as to the measures taken to safeguard your Personal Data as part of such an international transfer can be obtained by contacting us at [javascript protected email address].

6. Contact

If you have any questions or queries about the Applicant Privacy Notice or this Addendum, the ways in which we collect and use your ‎Personal Data or your choices and rights regarding such collection and use, please contact us at: [javascript protected email address]