Privacy Policy

This privacy notice (the “Notice”) describes the ways that Masterschool Ltd. and its affiliates (collectively, “Company”, “we”, “us”, “our”), collects and uses your Personal Data as a candidate (“you” or “candidate”). We work with data processors to whom we have instructed to collect, store and process Personal Data on our behalf for the purposes of facilitating, assessing and operating your candidacy and recruitment process at the Company, for example, Comeet, as a recruiting and applicant tracking platform (“Platform”) in order to handle your personal data as a candidate. It also describes the rights and options available to you with respect to your personal data.

We may have an additional privacy notice(s) explaining our own specific privacy practices related to your personal data (“Company Notice”).

If you have any questions related to your personal data, please contact us at [email protected].

1. PERSONAL DATA PROCESSED
   We receive Personal Data about you as a candidate for positions at the Company, such as: contact information, address, Curriculum Vitae (resumé) information (including information such as skills, work experience, education), notes or any other document submitted with the application, URL of your LinkedIn and other online profiles, the position for which you have been or are being considered, the source who submitted your candidacy (e.g., recruiting agency, referral), email correspondences between you, the Company and between the Company and other sources (such as recruiting agency and referrals) about your candidacy, information from references, events in the lifecycle of your candidacy, your responses to questionnaires sent to you by us, information about your candidacy and employment options (such as availability to be hired and salary expectations), evaluations of your candidacy, internal discussions within the Company about your candidacy, materials you or other parties (such as evaluators or background check providers) submitted in relation to your candidacy (collectively, “Personal Data”). If you submit your candidacy by email, or online, then you are the main source of the Personal Data. Your personal data can also originate from other sources, such as LinkedIn profile, recruitment agencies, headhunters and referrals.
2. HOW YOUR PERSONAL DATA IS USED. LEGAL BASIS.
   We will use your personal data in accordance with our Company Notice (if any is made available to you), including to evaluate and consider you as a candidate for positions, in accordance with its processes and policies for evaluating employment candidates, to contact you for your candidacy status and interviews, to schedule meetings and interviews, amongst others.The lawful bases we rely on for processing personal information are (if applicable to us under privacy law):
   1. You gave us your consent to the processing of your personal data (for one or more specific purposes);
   2. Processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
   3. Processing is necessary for the purposes of our legitimate interests; and/or
   4. Processing is necessary for compliance with a legal obligation to which we are subject.If you have questions about these uses, please contact us.
3. WHO WILL PROCESS YOUR DATA
   1. We may share your Personal Data with our service providers and vendors who assist us to collect, process and store your personal data as further described in our Company Notice, including, Comeet (who provides us with the Platform) in the context of your candidacy. These companies are authorized to use your personal data as necessary to provide these services or as otherwise authorized by us.
   2. Personal Data may be shared with, or transferred to, our affiliated corporate group entities (entities controlled by, under common control with, or controlling us, directly or indirectly).
   3. We may share your general recruitment status with third parties who submitted your candidacy to us.
   4. If your details are submitted to the Company by a third-party (such as an employee of the Company or a recruiting agency), the Company can give the third-party access to your name, photo and some of the general recruitment status.
   5. If you apply to a job opening using a unique referral link that was provided to you by an employee of the Company to which you are applying, the Company may share some of your general recruitment status, without identifying you by name, with the person that provided you the referral link.
   6. The purpose of sharing the above information is to operate incentive programs (i.e. employee referral bonus programs) of the Company and to provide feedback to third-parties who submit candidates to the Company regarding their submission.
   7. If we are required to disclose your Personal Data by a judicial, governmental and/or regulatory authority to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order.
   8. If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your Personal Data to such third party (whether actual or potential) in connection with the foregoing events.
   9. In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Data in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company.
4. SECURITY AND DATA RETENTION
   1. Retention. We will retain your Personal Data for as long as we need it to assess you as a candidate or as long as we have a valid legal basis (should any such legal basis apply to the processing of your Personal Data). In accordance with our internal data retention policies and practices, we can decide whether to keep your personal data, delete it or pseudonymize/anonymize it.
   2. Security. We implement industry standard measures to reduce the risks of damage, loss, unauthorized access, or use, of your Personal Data. Despite these measures, Company cannot provide absolute information security or eliminate all risks associated with Personal Data, and security breaches may happen. If there are any questions about our security practices, please contact us.
5. INTERNATIONAL DATA TRANSFERS
   We host your personal data in connection with our use of the Platform either in the US, in the country where we are located, or in countries deemed as providing an adequate level of data protection.
6. YOUR RIGHTS
   Your rights may vary, depending on the applicable law. These rights may not be available in certain jurisdictions and/or may be subject to certain derogations or limitations. You may have the following rights:
   1. To ask us to receive a copy of your Personal Data that is stored on our servers, including the Platform;
   2. to update, correct and/or delete your Personal Data;
   3. to request the restriction of processing concerning your Personal Data or to object the processing of your Personal Data;
   4. to request to obtain a copy of your Personal Data in a structured, commonly used and machine-readable format;
   5. If we rely on consent, please note that you have the right to withdraw consent at any time; and/or
   6. to lodge a complaint with a supervisory authority.If you wish to exercise any of these rights, please contact us. If you choose to exercise any of your rights, we will handle these requests in accordance with applicable law but please note that exercise of some of those rights may have some consequences in your application as a candidate.In the context of the Platform we do not use any automated decision-making related to your Personal Data.
7. MINORS
   We do not intend to collect personal data of children. If you have reason to suspect that personal data pertaining to children under the age of 16 is collected, you are kindly requested to immediately report it to us. If you have questions regarding children’s personal data contact us.
   
8. CHANGES TO THIS PRIVACY NOTICE
   From time to time, we may change or update this Notice. If we do so, we will make efforts to notify you of such changes by any means.
9. CONTACT US
   You may send requests, responses, questions and complaints by contacting us using the information provided below.

   Masterschool Ltd.
   Address: 651 North Broad Street, Suite 206, Middletown, Delaware, New Castle, United States, 19709
   Email: [email protected]