Candidate Privacy Notice (Israel)

Effective February 22, 2021

Scope and Overview

Operative (namely, SintecMedia Ltd. d/b/a Operative, SintecMedia, NYC, Inc. d/b/a Operative, or any of their direct or indirect affiliates and subsidiaries with which you will be engaging during the recruitment, application and interview process, in each instance, “Operative,” “we,” “us,” “our,” or the “Company”) is committed to protecting the privacy and security of your personal data. Personal data means any information about an identifiable individual collected in connection with the recruitment process. This Candidate Privacy Notice (this “Privacy Notice”) describes: 1) how Operative and related entities collect and process personal data about you during the recruitment, application and interview process, and 2) the handling of personal data obtained about internal and external job applicants, including applicants by referral, those who apply through third party agencies, recruiters and external career sites (including but not limited to LinkedIn and other job boards) as well as prospective candidates who apply directly through Operative’s online careers page and recruitment process. Please read this document carefully to understand how Operative uses and protects the information you provide.

This Privacy Notice describes the categories of personal data that we collect, how we use your personal data, how we secure your personal data, when we may disclose your personal data to third parties, and when we may transfer your personal data outside of your home jurisdiction. In addition, this Privacy Notice also describes your rights regarding the personal data that we hold about you including how you can access, correct, and request erasure of your personal data.

We will only process your personal data in accordance with this Privacy Notice unless otherwise required under applicable law, including by applicable regulatory bodies. We take steps to ensure that the personal data that we collect about you is adequate, relevant, not excessive, and processed for the limited purposes set forth herein.

Collection of Personal Data

We will collect your personal data from you directly and potentially from other sources. We may collect personal data directly from you as a job applicant, or may receive personal data from third parties in connection with potential employment. Personal data excludes anonymous or de-identified data that is not associated with a particular individual. We may collect, store, and process the following categories of personal data, including other information you may choose to voluntarily submit to us or information that is publically available to or in connection with your application (e.g. information contained in a cover letter, or information disclosed in an interview).

  1. Identifiers

Identifiers we may collect includes:

    • personal contact details such as name, title, telephone numbers, and personal email addresses.
  1. Professional and Employment Related Information

Professional and employment related information we may collect includes:

    • work history and other relevant experience including information contained in a resume, CV, cover letter or job application.
    • information collected during phone screenings and other interviews.
    • details regarding the type of employment sought, desired salary, job preferences, and other information related to compensation and benefits.
    • to the maximum extent permitted by law, reference information and information received from background checks, and where applicable, including information provided by third parties.
    • information related to previous applications to Operative or previous employment history with Operative in accordance with our data retention policy.
  1. Educational Information

Educational information we may collect includes:

    • as applicable and if relevant to the subject position, information pertaining to educational details, including qualifications, certifications, transcripts, degrees, skills and any other information provided in support of job applications.
  1. Data Collected from other Sources

The categories of data we may collect indirectly about you from other sources may include:

    • information about your performance or conduct from referencecs and former employers.
    • publicly available information from websites or social media, including information that you choose to voluntarily submit to us in connection with your application (e.g. when applying through LinkedIn or other job boards).

Use of Personal data

We limit our collection and use of your personal data, and only process your personal data for specific, necessary reasons. We may, for example, use your personal data to:

  1. identify and verify a job application, including assessing skills, qualifications, and interests for the purpose of determining suitability for the position for which you have applied.
  2. retain records related to our recruitment processes, for only as long as appropriate under the circumstances.
  3. communicate with you about the recruitment process and your application.
  4. create and submit reports as required by applicable laws or regulations.
  5. comply with our legal, regulatory, contractual or other corporate governance requirements.
  6. analyze and improve our application and recruitment process.
  7. prevent fraud.
  8. to ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution.

In addition to using your personal data for the position for which you have applied, with your consent we may retain and use your personal data to inform you about and to consider you for other positions that may be appropriate for you.

Data Sharing

  1. Service Providers

While we do not sell or market your personal data, we may share your personal data with third parties in limited situations, including with third parties under the following circumstances:

  • to our employees, contractors, designated agents, or third-party service providers who require such information to assist us with administering the recruitment process.
  • to obtain employment verification and background checks.
  • for data storage or hosting.

We require all of our third-party service providers, by written contract, to implement appropriate security measures to protect your personal data consistent with our policies and any data security obligations applicable to Operative. We do not permit our third-party service providers to process your personal data for their own purposes, and only permit them to process your personal data for specified purposes in accordance with our instructions. These third-party service providers may be located outside of the country in which you live or the country where the position for which you applied is located.

  1. Legal Obligations

We may disclose your personal data where required by law. For example, we may disclose your personal data in connection with search warrants, subpoenas, or court orders. When we disclose your personal data to comply with a lawful obligation or legal process, to the extent permitted by applicable law, we will take reasonable steps to ensure that we only disclose the minimum personal data necessary for the specific purpose and circumstances.

  1. Operative Companies

We may also disclose your personal data where permitted or required by applicable law:

  • to other members of our group of companies (including outside of your home jurisdiction) for the purposes set out in this Privacy Notice, as necessary to administer the application and recruitment process and as part of our regular reporting activities to other members and principals of our group of companies.
  • if a business transfer or change in ownership occurs and/or is contemplated and the disclosure is necessary to evaluate or complete the transaction. In these circumstances, we will limit data sharing to what is absolutely necessary, and we will anonymize the data where possible

Cross-Border Data Transfers

Because we operate as part of a global business, we may transfer, store, or process your personal data in a country different from where you reside, including as applicable, in the United States and Israel.

Data Security

We have implemented appropriate physical, technical, and organizational security measures designed to secure your personal data against accidental loss and unauthorized access, use, alteration, or disclosure. In addition, we limit access to personal data to those employees, agents, contractors, and other third parties that have a legitimate business need for such access. To learn more about measures Operative takes to safeguard your personal data, please see Operative’s Information Security Policy, available here.

Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, accounting, or reporting requirements, or as necessary to resolve disputes. To determine the appropriate retention period for personal data, we consider our statutory obligations, the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means.

Under some circumstances we may anonymize your personal data so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

If you are offered and accept employment with Operative, the personal data we collected during the application and recruitment process will become part of your employment record, and we may use it in connection with your employment consistent with our employee personal data policies. If you do not become an employee, or, once you are no longer an employee of Operative, we will retain and securely destroy your personal data in accordance with our document retention policies and applicable laws and regulations.

Your Rights

Your personal data belongs to you. As such, you may exercise the following rights in relation to your personal data to the maximum extent permitted under applicable law:

  1. The right to be informed

This Privacy Notice provides transparency on how Operative processes and handles your personal data. If you have any questions, please do not hesitate to contact us.

  1. The right of access

You are allowed anytime to access your personal data so that you are aware of and can verify the accuracy of the personal data and lawfulness of the processing.

  1. The right to rectification

You are entitled to have personal data rectified if it is inaccurate or incomplete.

  1. The right to erasure

You can request the deletion or removal of your personal data where there is no compelling reason for its continued processing.

  1. The right to restrict processing

You have the right to suppress processing of personal data.

  1. The right to objection

You have the right to object to processing based on legitimate interests.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal data that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal data that we hold about you, or we may have destroyed, erased, or made your personal data anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal data, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

If you would like to exercise any of your individual privacy rights, please complete the request form available here.

Changes to this Privacy Policy

We reserve the right to update this Privacy Notice at any time and we will provide you with a new Privacy Notice or post the same at when we make any updates.

Contact Us

Should you have any questions regarding this Privacy Notice or our privacy practices, please contact us at:

Alyssa Greenspan
Data Protection Officer

If you would like to exercise any of your individual privacy rights, please complete the request form available here.