US Recruiting Privacy Policy

Effective Date: May 26, 2022

1. What Personal Information Do We Collect?

We collect and maintain personal information in respect of those individuals who seek to be employed by us, such as those applying for employment via the Greenhouse applicant tracking tool. This may, depending on the role and jurisdiction, include personal information contained in:

• resumes and/or applications;
• references and interview notes;
• information required for travel to and from an interview;
• photographs and video;
• letters of offer and acceptance of employment; and
• background screening information.

In addition to the examples listed above, personal information also includes information such as name, home address, telephone, personal email address, date of birth, employee identification number and marital status, and any other information necessary to Paige’s business purposes, which is voluntarily disclosed in the course of an individual’s application for employment with Paige.

As a general rule, Paige collects personal information directly from you. In most circumstances where the personal information that we collect about you is held by a third party, such as in the case of a reference or background check, we will obtain your permission before we seek out this information from such sources.

From time to time, we may utilize the services of third parties (including other members of the Paige Family) in our business and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us and that their practices align with this privacy policy.

Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.

In the U.S., certain states require that we make specific disclosures regarding our collection and use of personal information. For additional information, that may apply based on your location, please see the State Specific Addenda below.

2. How Do We Use Personal Information?

The personal information described above is used and disclosed for our business purpose of recruiting qualified candidates for employment. Such uses include:

• determining eligibility for initial employment, including the verification of references and qualifications;
• assessing qualifications for a particular job or task;
• arranging travel for an in-person interview;
• complying with applicable labor or employment statutes;
• ensuring the security of company-held information;
• such other purposes as are reasonably required by Paige in connection with your application for employment; and
• for any additional purposes that we advise you of and for which we have a legal basis, which may for instance be your consent when such consent is required by law.

We may use your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

3. Monitoring

In the course of conducting our business, we may monitor activities on our systems for security purposes.  For example, some of our locations are equipped with surveillance cameras in public areas and our websites are monitored for suspicious activity. Where in use, surveillance cameras and website monitoring are there for the protection of employees and third parties and to protect against theft, vandalism and damage to Paige’s goods and property. Generally, recorded images are routinely destroyed and not shared with third parties unless there is suspicion of a crime, in which case they may be turned over to law enforcement or other authority.

This section is not meant to suggest that all applicants will in fact be monitored or their actions subject to constant surveillance. It is meant to bring to your attention the fact that such monitoring may occur and may result in the collection of personal information.

4. When Do We Disclose Your Personal Information?

We may share your personal information with our employees, contractors, consultants, and other parties (including other members of the Paige Family, technology providers for communication tools, such as Microsoft O365 and Greenhouse, who require such information to assist us with evaluating your qualifications for employment, including: parties that provide products or services to us or on our behalf. In some instances, such parties may also provide certain information technology and data processing services to us so that we may communicate with you, coordinate scheduling for interviews, arrange travel or similarly conduct recruiting activities. We may share personal information with such parties both in and outside of your home jurisdiction, and as result, your personal information may be collected, used, processed, stored, or disclosed in the United States of America, Canada, India, and in some cases, other countries.

When we share personal information with such parties, we typically require that they only use or disclose such personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy.

In addition, personal information may be disclosed or transferred to another party (including to another member of the Paige Family outside of your home jurisdiction) in the event of a change in ownership of, or a grant of a security interest in, all or a part of Paige through, for example, an asset or share sale, or some other form of business combination, merger or joint venture.

Further, your personal information may be disclosed:

• as permitted or required by applicable law or regulatory requirements. In such a case, we will endeavor to not disclose more personal information than is required under the circumstances;
• to comply with valid legal processes such as search warrants, subpoenas or court orders;
• as part of Paige’s regular reporting activities to other members of the Paige Family (including outside of your home jurisdiction);
• to protect the rights and interests of Paige;
• during emergency situations or where necessary to protect the safety of a person or group of persons;
• where the personal information is publicly available; or
• with your consent where such consent is required by law.

We do not sell personal information subject to this privacy policy to third parties.

5. Consent

Applicants submitting personal information for the purposes of pursuing employment are doing so voluntarily, and may withdraw their candidacy at any time.  The personal information submitted may need to be retained for a short time (< 1 year) for official records, but will not be retained beyond that time or for any other purpose.

All communications with respect to such withdrawal or variation of consent should be in writing and addressed to [email protected].

6. How is Your Personal Information Protected?

Paige endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question, and maintains an ISO 27001 certification. These safeguards are designed to protect your personal information from loss and unauthorized access, copying, use, modification or disclosure.

Despite these safeguards, no method of transmission over the Internet or data storage is fully secure. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

7. How Long is Your Personal Information Retained?

Except as otherwise permitted or required by applicable law or regulatory requirements, Paige endeavors to retain your personal information only for as long as it believes is necessary to fulfill the purposes for which the personal information was collected (including, for the purpose of meeting any legal, accounting or other reporting requirements or obligations).

8. Updating Your Personal Information

It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of your application for employment, please keep us informed of such changes.

In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

9. Access to Your Personal Information and Deletion of Your Personal Information

You may request access to, and rectification, or deletion of personal information that we hold about you.  This right and Paige’s obligations to comply, vary based on the applicable regulations.  Each request will be evaluated individually against the legal requirements.

To make such a request, please contact our Privacy Officer using the contact information set out below.  Please note that any such communication must be in writing.  In your request, please make clear what specific personal information you would like to have accessed, rectified, or deleted.

When requesting access to, or rectification or deletion of your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, rectify, or delete, as well as to search for and provide you with the personal information that we hold about you. If you require assistance in preparing your request, please contact our Privacy Officer.

Your right to access, rectify, or delete the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse your request. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

In the event that we cannot provide you with access to, or rectification or deletion of your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

We will not discriminate against you for exercising any of your rights described in this Privacy Policy.

10. Inquiries or Concerns

If you have any questions about this Privacy Policy or concerns about how we manage your personal information, please contact our Privacy Officer in writing. We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you.

11. Privacy Officer

Paige has appointed a privacy officer to oversee compliance with privacy policies. The Privacy Officer can be reached via email at [email protected].

12. Revisions to the Privacy Policy

Paige may from time to time make changes to this Privacy Policy to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. Any changes to this Privacy Policy will be effective from the date it is posted, which is reflected on the website displaying this policy. This Privacy Policy was last reviewed or updated as of the Effective Date set forth above.