The John Gore Organization, Inc. and Our group of companies (collectively, “We”, “Our” or “Us”) respects the privacy of Our job applicants. This Applicant Privacy Notice (“Notice”) describes the privacy practices that apply to Our collection, use, and disclosure of personal information from You (“You” or “Your”) for employment, scholarship, and/or internship opportunities with Us when You submit personal information and other information to Us via any of Our application portals, websites, or other recruitment channels, whether online or off-line (collectively, the “Sites”), as well as how We use and share that information. We appreciate Your interest and take care to process and use Your information responsibly.

If You have any questions about this Notice, please contact Us at hrprivacy@johngore.com.

PART I: What information We collect, how We collect it, and how We use it

1. Information We collect from You. To review any inquiries or applications, We ask You to provide personal information about yourself. All information is provided on a voluntary basis, and You determine the extent of information You provide to Us. Please note that some information may be necessary to complete an evaluation of Your application.

   For purposes of this Notice, “personal information” means any information which relates to an identified or identifiable, living individual that directly or indirectly references one or more factors specific to their physical, physiological, mental, economic, cultural, or social identity. Personal information excludes anonymous data.

   As further described below, We collect personal information from You in connection with Your job application with Our recruitment process,

   1. Personal identifiers, such as Your name, preferred name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, date of birth, and other similar identifiers.

   2. Personal Records, such as Your signature, Social Security number, address, telephone number, education, employment or employment history.

   3. Protected characteristics, such as minority, veteran and disability status, through voluntary self-disclosure. Such information will only be collected as permitted by applicable law and will not be used to make hiring decisions.

   4. Internet or other similar network activity information, such as Your IP address, log-in information or information regarding Your interaction with a website, application or advertisement.

   5. Geolocation Data, such as IP addresses from which We can determine Your general location.

   6. Sensory data, such as audio and visual information, for example if You use video interviewing as part of the application process. If You visit Our facilities, Your entry and exit may be monitored by CCTV.

   7. Professional or employment-related information, such as Your work history, references, information about skills and abilities, accomplishments and awards, training and development information, performance evaluation information, and employment termination information.

   8. Education information, such as Your education history, education records (such as grades, transcripts and class lists), and other information included in Your resume or cover letter.

   9. Inferences drawn from other personal information, such as a profile reflecting Your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.

   10. Other: Job interview notes, responses to screening questions, assessment results, and any other information You provide in connection with the recruitment process. We also collect legal and contractual information, such as information necessary to respond to law enforcement and governmental agency requests, comply with legal and contractual obligations, exercise legal and contractual rights, and initiate or respond to, or establish, exercise and defend, legal and contractual rights claims.

2. How We collect Your Information. We may collect this information in a variety of ways, including from application forms, CVs or résumés, identity documents, third parties (such as for references or background checks, or from recruiters), other websites on the Internet (subject to such third party’s privacy policies), or through interviews or other forms of assessment. We may also combine personal information collected from other sources with the personal information that You provide to Us. For example, We may collect information from: (a) recruiters; (b) prior employers (e.g., for references); (c) professional references You provide to us; (d) educational institutions; (e) pre-employment screening services; (f) credentialing and licensing organizations; (g) publicly available sources such as Your social media profile (e.g., LinkedIn, Twitter and Facebook); and (h) the sources as directed by You. By authorizing Us to have access to this information, You agree that We may collect, store, and use this information in accordance with this Notice.

   If We ask You to provide any other personal information not described above, then the personal information We will ask You to provide, and the reasons why We ask You to provide it, will be made clear to You at the point We collect it. If We ask You to provide personal information that We consider to be mandatory for Us to administer Your relationship with Us, We will inform You of such at the time of collection. In addition, We will also inform You of the consequences for not providing Us with the mandatory personal information.

3. How We use Your information. We use the categories of personal information listed above for the following purposes:

   1. Process and manage Your application: We use Your personal information to process Your job application, establish a job applicant profile for the recruitment process, assess Your qualifications for a specific role with us, schedule and conduct interviews, communicate with You, and carry out background and reference checks (see the following bullet point for additional information). We may collect audio and visual information of job applicants through photographs used for identification purposes. With Your consent, We may record video of You in connection with the application process, for example through a third-party screening service. Additionally, if You are offered a position with us, We may use Your personal information in the employee on-boarding process and the personal information collected during the job application and recruitment process may become part of Your employment record.

   2. Conduct reference and background checks (as permitted by applicable law): We use personal information We collect to conduct reference checks and to evaluate Your qualifications and experience. We may also conduct background checks (as authorized by You and permitted by applicable law).

   3. Provide immigration support: If applicable and as permitted by applicable law, We may collect Your personal information to assist with immigration support, such as applying for visas or work permits.

   4. Analyze and improve our recruitment process and tools: For example, We analyze trends in our applicant pool, and use personal information to understand and improve our recruitment process and tools (including improving diversity and inclusion). If You use our online job application process, We collect personal information in this category, such as Your interactions with our “Careers” page and our online application process. We collect IP address location information to better understand how candidates use our careers page and online application process.

   5. Record-keeping: We keep records of Your personal information as required by law and in accordance with our record retention policies.

   6. Meeting legal requirements and enforcing legal terms: We collect and process Your personal information for purposes of: fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property or safety of You, Us or another party; enforcing any agreements with You; responding to claims; and resolving disputes. Additionally, We may use information about protected characteristics to analyze and monitor the diversity of our job applicants in accordance with applicable laws.

   If We need to process Your personal information for an incompatible purpose not discussed in this Notice, We will provide notice to You and, if required by law, seek Your consent. We may process Your personal information without Your knowledge or consent only where required by applicable law. Lastly, We do not subject You to automated decision-making.

PART II: How We Share Your Information

We may share Your personal information as necessary for the purposes described in this Notice, including internally with our personnel involved in the hiring process. For example, We share Your personal information with the following parties:

1. Affiliates. We may share Your personal information with our affiliates.

2. Service Providers. We use service providers, including Workday, to operate, host and facilitate our hiring and recruitment process. These include hosting, technology and communication providers; security and fraud prevention consultants; analytics providers; background and reference check screening services; and hiring process management tools.

3. Government authorities and law enforcement. In certain situations, We may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

4. Business transfers. Your personal information may be transferred to a third party if We undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).

5. Professional advisor. We may share Your personal information with our professional advisors.

6. With Your consent. We may disclose Your personal information for any purpose with Your consent.

7. Referrals. Upon request, to Our employee who referred You to inform them about the limited, general status of the referral.

8. Other. We may also share Your personal information with third parties in conjunction with any of the activities set forth under “Meeting legal requirements and enforcing legal terms” in the “Use of Personal Information” section above.

Please note that We do not sell (as defined in applicable data protection and privacy laws) Your personal information (and will not sell it without providing any required notices and/or opt-in/opt-out rights).

PART III: International transfers of information for Canadian Residents

Personal information may be transferred, stored, and processed by Us and Our service providers, partners, and affiliates outside of Your home jurisdiction (such as the United States or Canada) and in some cases, potentially other countries for the purposes described in this Notice. These countries may have data protection and privacy laws that are different than the laws of Your home country. We only transfer personal information to another country in accordance with applicable data protection and privacy laws, provided there are legally adequate protections in place for the personal information.

PART IV: Security and confidentiality

Except as otherwise stated in this Notice or as required for legal or regulatory purposes, We treat Your personal information as confidential. We maintain (and requires its services providers and agents to maintain, appropriate organizational and technical measures designed to protect the security and confidentiality of Your personal information. For example, We employ physical access controls, encryption, Internet firewalls, intrusion detection, and network monitoring depending on the nature of the data and the scope of processing. Our staff who may have access to personal information are required to keep that information confidential.

However, no security procedures or protocols are ever guaranteed to be 100% secure so We encourage You to take care when disclosing personal information online and to use readily available tools, such as Internet firewalls, anti-virus and anti-spyware software, and similar technologies to protect yourself online. If You have reason to believe that Your interaction with Us is no longer secure (for example, if You feel that the security of Your personal information has been compromised), please immediately notify Us in accordance with the “How to Contact Us” section below.

PART V: Your privacy rights

1. Certain jurisdictions may provide You with privacy rights under applicable data protection or privacy law regarding Your personal information. In particular, You may have the right to: (a) be informed about Your personal information; (b) access Your personal information; (c) correct any personal information that is inaccurate; (d) have Your personal information erased; (e) restrict or suppress the processing of Your personal information; (f) obtain and reuse Your personal information; (g) object to the processing of Your personal information; (h) object to how Your personal information is used in automated decision making, if applicable; and (i) lodge a complaint with a supervisory authority.
2. These rights may be limited, for example, if fulfilling Your request would reveal personal information about another individual, or if You ask Us to delete personal information which We are required by law to keep or which We need to defend claims against Us.
3. If You are a California resident, please see Our Privacy Notice to California Job Applicants Regarding the Collection of Personal Information for additional disclosures and information about the personal information We have collected about You over the last 12 months and rights You may have regarding Your personal information.
4. If We process Your personal information in reliance upon Your consent, You can contact Us at any time to withdraw Your consent.
5. To exercise any of these rights, please contact Us by using the contact details under the “How to contact Us” heading below.
6. We will respond to such requests in accordance with the requirements of applicable data protection laws. Please note that in order to fulfil Your request, We may need You to provide certain personal information to verify Your identity. Depending upon applicable data protection and privacy law, individuals may also designate an authorized agent to exercise these rights on their behalf.

PART VI: Other information

1. How long We retain Your information. Unless a longer retention period is required by law, We will retain Your personal information for as long as is needed to fulfill the purposes outlined in this Privacy Notice or for as long as We have a legitimate business interest that is not outweighed by Your data protection interests. We may also retain Your information in accordance with applicable law to consider You for other job opportunities unless You have told Us that You do not wish Us to retain Your details for such purposes. When We have no ongoing legitimate business need to process Your personal information, We will either delete or anonymize it or, if this is not possible (e.g., because Your personal information has been stored in backup archives), then We will securely store Your personal information and isolate it from any further processing until deletion is possible. As such, We reserve the right to use such anonymous data for any legitimate business purpose without further notice to You or Your consent.

2. Cookies and Similar Technologies. For information about the cookies and other tracking technologies used by Our Website and how to manage Your settings for these cookies and technologies, please see Our Cookie Notice.

3. How We Treat Do Not Track Signals. Various browsers (i.e., Internet Explorer, Chrome, Firefox, Edge, etc.) allow a “do not track” (DNT) setting, which sends a signal to websites visited by an individual about their browser DNT setting. At this time, there is no general agreement on how companies, like iCIMS, should interpret DNT signals. Therefore, We do not currently commit to respond to DNT signals. We will continue to monitor developments around DNT browser technology and the implementation of a standard.

4. Third-Party Websites and Applications. Our website and services may provide links to or the ability to connect with third-party websites, services, social networks, applications, or social media features such as “Share” or “Like” buttons. Visiting those sites or clicking on those links may allow the third party to collect and use information about You. Further, the personal information You choose to give to these third parties is not covered by this Notice. We encourage You to review the privacy notices and terms of use of such third parties prior to interacting with them or providing them with Your personal information to understand how Your information may be collected and used. We do not control the privacy practices of such third parties, nor do We endorse or make any representations about these third-party websites, services, social networks, or applications.

5. Children. The Website is not directed to or intended to be used by anyone under the age of 18. We do not knowingly collect personal information from anyone under the age of 18. If You are under 18, please do not attempt to fill out Our forms or send any personal information about yourself to Us. If We learn that We have collected personal information from a child under age 18, We will delete that personal information promptly.

6. Changes to this Notice. We will review and update this Notice periodically in response to changing legal, technical, and business developments. When We update this Notice, We will note the date of its most recent revision above. If We make material changes to this Notice, We may take appropriate measures to inform You in a manner that is consistent with the significance of the changes We make. We encourage You to review this Notice frequently to be informed of how We are protecting Your information.

7. Your responsibilities. You are responsible for the information You provide or make available to Us, and You must ensure it is honest, truthful, accurate and not misleading in any way. You must ensure that the information provided does not contain material that is obscene, defamatory, or infringing on any rights of any third party; does not contain malicious code; and is not otherwise legally actionable. Further, if You provide any information concerning any other person, such as individuals You provide as references (“referee”), You are responsible for providing any notices and obtaining any consents necessary for Us to collect and use that information as described in this Notice before You provide the referee’s personal information to Us. To the extent permitted or required by law, We may delete data at any time; accordingly, You should retain Your own copy of any information You submit to Us.

PART VII: How to contact Us.

To ask questions or comment about this Notice and Our privacy practices or if You need to update, change, or remove Your personal information or exercise any other rights,

Via Email: hrprivacy@johngore.com
Via Mail: General Counsel, 1619 Broadway, 9th Floor, New York NY 10019, USA.

Please reference this Applicant Notice in Your communication.