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Last Updated:  May 31, 2023

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1. Introduction

This Privacy Policy (or “Policy”) tells You how Orveon collects, uses, shares, secures, and eventually deletes, information collected from and about Job Applicants when they apply for a job with us in our career page.

Depending on the position you’re applying for, “Orveon” (“we,” “us,” or “our”) is one of the following enterprises, as indicated in the communication related to the job posting:

·      Orveon Global US LLC

·      Orveon Global Ltd. (UK)

·      Orveon Global Germany GmbH

·      Orveon Global Spain, S.L.

·      Orveon Global Japan, K.K.

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2. Definitions

“Careers Site” means https://orveon.applytojob.com/apply.

“Job Applicant” means a natural person who is applying for an open position with Orveon or one of Orveon’s brands.

“Personal Information” means any information relating to an identified or identifiable individual that is collected via our Careers Site. Personal Information may include a Jop Applicant’s: full name, physical address, email address, or IP address.

Personal Information does not include any aggregate or anonymized data that may have been created from Personal Information but can no longer be used to identify, relate to or could reasonably be linked to a Job Applicant.

“Sensitive Personal Information” means any data about a natural person that reveals a racial or ethnic origin, political opinion, religious belief, philosophical belief or  trade union membership. It also includes a natural person’s genetic and biometric data, and data concerning their health, sex life or sexual orientation.

“You” or “Your” means a Job Applicant.  

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3. Information that We Collect about You

We collect certain Personal Information from You when You apply for a position with us:    

·      Identifiers (i.e., a legal name, nickname, physical home address, internet protocol address, email address, phone number, an online identifier, driver’s license number, etc.)

·      Professional or Employment Information (i.e. where a person currently works, wants to work, or has worked in the past)

·      Other Personal Information you choose to share with us (i.e, Your professional social media profile, Your blog, Your personal website, or portfolio information).

·      Sensitive Information you choose to share with us (i.e., Your relevant health information, race, and potentially Your religious and sexual orientation information)

·      If applicable, we may also collect Your immigration or visa status when necessary.

·      Internet Activity (i.e., browsing history and internet search history, as further described below in the section ‘How do we collect Your Data’)

·      Geolocation Data (i.e. data describing your current or past whereabouts)

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4. Accurate Information

Please note that ensuring that Your resume and the information that You share with regards to Your application is accurate and up-to-date is very important. Inaccurate data may impact the provision of Your candidacy and ultimate employment with us.

5. How do we collect Your Data?

In most cases we collect Your Data directly from You and in connection with the assessment of your application and the provision of Your employment. In certain situations, third-party employment sites, such as Indeed or LinkedIn, may provide this information to us directly.  

6. Why We Collect Your Information?

1. To Evaluate Your Candidacy for Employment with us

We collect and process Your Personal Information and Your Sensitive Personal Information in order to evaluate You for a potential position with us, and if You are hired, to support and provide for Your employment with us. The legal basis for this processing, if You are an EU or UK citizen, is necessity for the performance of a contract with You or taking steps at Your request prior to entering into a contract.

2. To Notify You of Future Positions with Us

If You are not hired for a position, but have asked us to keep Your resume and information on file in the event that another position becomes available, we may use this information to send You communications and job alerts about employment opportunities with us.  You can opt out of receiving these communications at any time by clicking the “opt out” link at the bottom of these emails or by emailing Us directly at privacy@orveonglobal.com.   The legal basis for this processing, if You are an EU or UK citizen, is Your consent to receive notifications and job alerts from Us.

3. In Order to Respond from Requests from You

If You have requested further information or in any other way requested that we contact You, we will use Your Personal Information to respond to such a request. The legal basis for this processing, if You are an EU or UK citizen, is Our legitimate interest to be able to reply to Your requests and questions.

4. For Our Compliance Purposes

We also collect information in order to comply with certain legal rules and regulations that we are subject to. The legal basis for this processing, if You are an EU or UK citizen, is Our legal obligation pursuant to national legislation. We might need Your Information to defend ourselves in legal proceedings, in which case we will rely on Our legitimate interest to use Your Personal Data in these proceedings.

7. Who do We share Collected Personal Information with?

Orveon only shares Your Personal Information and Your Sensitive Personal Information when necessary to members of our internal team and if necessary, our service providers.

The categories of third parties that we need to share your Personal Information with and the Categories of Personal Information that we share with those parties are:

Categories of Third Parties  

Categories of Personal Information Shared with the Third Party

Data Service Providers

We do not share Your Personal Information or Sensitive Information directly with these providers, but they may receive records that may contain Identifiers, Geolocation Data, Professional or Employment Information, Internet Information, and Other Sensitive Information.  

Legal Representatives

Depending on the need, we may need to share Your Identifiers, Professional or Employment Information, Internet Information, and Other Sensitive Information.  

IT Service Providers

Identifiers, Geolocation Data, and Internet Information.

Law Enforcement, Courts, or other related Legal third parties that are not our legal representatives

Depending on the need and related law, we may need to share Your Identifiers, Geolocation Data, Professional or Employment Information, Internet Information, and Other Sensitive Information.  

Auditors

Depending on the need, we may need to share Your Identifiers, Geolocation Data, Professional or Employment Information, Internet Information, and Other Sensitive Information.  

Accounting Representatives

Depending on the need, we may need to share Your Identifiers, Professional or Employment Information, and Other Sensitive Information.  

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8. Why do We share Your Personal Information?

We do not use or disclose Your Personal Information and Your Sensitive Information for any other purpose besides than to perform business services, including evaluating You for a position with us. The business purposes for which we may share Your Data to third parties include:

1. Interviewing You and otherwise evaluating Your Candidacy – We need to share Your Personal Information and Sensitive Personal Information internally to interview You and otherwise evaluate Your candidacy for a position with us.  
2. Auditing – We may share this information with our third-party vendors, partners and service providers, and our own auditors related to an audit of our business.
3. Service Partners – We may share this information our third-party vendors, other partners, and service providers in order to have them perform their services for us, pursuant to a written contract that includes the notified purposes permitted by the CCPA.
4. Security and Legal Issues – We may share this information with law enforcement or other individuals pursuant to a valid subpoena or other legal obligation, our third-party vendors, other partners, and service providers in order to detect, prevent, and investigate security incidents.
5. Employment through an Employer of Record (EOR) – In the event you receive and/or accept offer of employment in a jurisdiction in which we partner with an EOR, please be aware that we will need to share Your Personal Information and Sensitive Personal Information with our EOR partner.

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9.     How do We Secure Your Personal Information?

Orveon maintains a comprehensive Information Security Program that employs commercially available physical and IT securitization tools, including but not limited to:

a.     Commercially available and sufficient firewalls;

b.     Segmented Data Storage;

c.     Encryption;

d.     Multi-factor authentication; and

e.     Policies providing for least privileged access to data across our organization.

Unfortunately, however, there is no way to completely eliminate the risk of a data security incident. If we do suffer one that affects any of Your Personal Information, we will report the same to You as per applicable data breach notification laws.

If You have any questions about the cybersecurity for our Website, You can send an email to privacy@orveonglobal.com.

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10. How long do we store Your Data?

We securely store Your Data as detailed above. We only store and maintain Your Personal Information for as long as is necessary to fulfill the purpose for which it was collected or to satisfy a legal obligation that we may have related to maintaining Your Personal Information. If You sign up to receive our job alerts, but do not have an account with us currently, we will store and maintain Your Personal Information to continue to send You these materials until You opt out of receiving such communications. After the end of Your Personal Data storage period, we securely delete Your Personal Information.

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11. We do not Sell Your Personal Information

Orveon does not under any circumstances sell any Personal Information or Sensitive Personal Information that it has collected from Job Applicants for any reason.

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12. Sale or sharing of the Personal Information and Sensitive Information of Persons under the age of 16

Our website and products are not made for, marketed to, or directed at, children under the age of 16 years of age. We do not sell or share the Personal Information of persons under 16 years of age.

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13. Your Rights under the California Privacy Rights Act (CPRA)

1. You, or Your authorized agent, can request the specific pieces of Personal Information we have collected about You by emailing us at privacy@orveon.com. You can also request that we disclose how we have collected, used and shared Your personal information over the past 12 months, including the categories of personal information we collected and our purposes for doing so. You may also request the categories of the sources of that information, the categories of the third parties with whom we have shared this information with for a business purpose, and our business purpose for doing so.  
2. You have the right to correct inaccurate Personal Information that we have collected or maintain about You. In fact, we ask that You do so as soon as You realize any Personal Information that we have collected is inaccurate as it could impact our provision of the Services.
3. You have the right to opt out of Sale of Your Information, but as noted above, We do not sell Your information.
4. You have a right to be notified when we collect information from You, and we cannot collect new categories of information from You without notifying You first.
5. You have the right to limit our sharing of Your Personal Information.
6. You have the right to not be discriminated against for exercising these rights.
7. You have the right to ask us to delete Your Personal Information. Please note that because our collection of Your Personal Information and Sensitive Personal Information is done in connection with the provision of Your employment, we must maintain certain information related to Your employment pursuant to various regulations. Thus, if You request that we delete Your Personal Information, we may not be able to so right away if subject to those legal requirements. However, as soon as we legally can delete your information we will.

14. Your rights under the (UK) General Data Protection Regulation (GDPR)

As an EU or UK Data Subject, You have the following rights:

1. The Right to Access Your Data - including asking for copies of Your Personal Information and Sensitive Information. We are entitled to charge you a small fee to provide You with the same.
2. The Right to Rectification of Your Data - including the right to ask us to correct any inaccurate data and complete any incomplete data.
3. The Right to Erasure of Your Data - including asking us to delete copies of Your Data. Please note that we may not be able to immediately delete certain portions of Your Data based on legal rules and requirements, however, once those restrictions have expired, we will delete the same.
4. The Right to Restrict Processing of Your Data – including the right to request that we restrict processing of Your Data under certain circumstances. Again, legal requirements and obligations may limit our ability to fully restrict the processing of Your Data.
5. The Right to Object to the Processing of Your Data - including the right to request that we stop processing Your Data under certain circumstances. Again, legal requirements and obligations may limit our ability to fully stop processing of Your Data.
6. The Right to Data Portability - including the right to request that we transfer Your Data to another organization or directly to You, under certain circumstances. Again, legal requirements and obligations may require us to also maintain copies of Your Data even if we transfer it as requested.

If You wish to report a complaint or feel that we have not respected your rights or addressed your concerns in a satisfactory manner, then You may contact Your local Data Protection Authority which may be found here: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

15. How to Exercise Your Rights

If You would like to exercise any of the rights listed above with regards to Your Personal Information, then please contact Us, or have Your registered agent contact Us, at privacy@orveonglobal.com.

If you want to review and request changes to Your Personal Information, You may also email us and we will then provide you with detailed instructions on how to do so.

16. Changes to this Policy

We regularly review and update this Policy as needed. The most recent date that this Policy has been updated, will be reflected above in the “Last Updated” section.

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17. Contact Us

If You have any questions or concerns about this Policy, Your Data that we have, or would like to exercise any of Your data protection rights, please email Us at: privacy@orveonglobal.com.

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