Employee/Candidate Privacy Policy

1. Introduction

Gigs Wireless, LLC ("we", "us", "our") is committed to protecting your privacy and handling your personal data responsibly in accordance with applicable data privacy laws, including the General Data Protection Regulation (GDPR) and California Privacy Rights Act (CPRA), and telecommunications regulations.

This Candidate Privacy Policy explains how we collect, use, store, and protect your personal data when you apply for a position with us or otherwise engage with our recruitment processes. It applies to all candidates, prospective applicants, and individuals who participate in our hiring activities worldwide.

Please read this notice carefully. By submitting your application or participating in our recruitment process, you acknowledge that you have read and understood this notice.

2. Data Controller

For candidates in the European Economic Area (EEA) applying for a position within Gigs, the data controller for the purposes of this Policy is:

Gigs Wireless, LLC
2261 Market Street #4288
San Francisco, CA 84114
Email: data-request@gigs.com

If you have any questions about this notice or how we handle your personal data, please contact us using the details above.

3. Personal Data We Collect

During the recruitment process, we may collect and process the following categories of personal data:

Information you provide directly

• Identification and contact details: name, email address, phone number, postal address, and any other contact information you provide

• Professional background: CV/resume, cover letter, work history, job titles, previous employers, and dates of employment

• Education and qualifications: academic history, degrees, certifications, professional licenses, and training records

• Work authorization: visa status, right to work documentation, and immigration details where applicable

• Application materials: responses to application questions, assessment results, work samples, portfolio materials, and interview recordings or notes

• Compensation expectations: salary requirements and benefits preferences

• Other information: any additional information you voluntarily provide during the recruitment process

• Cookies and other tracking information: including the collection of IP addresses on our career webpages

Information from other sources

• References provided by your nominated referees

• Information from recruitment agencies or platforms (e.g., LinkedIn, job boards)

• Background check information where legally permitted and relevant to the role

• Publicly available professional information

Special category data

We generally do not request or process special category data (such as racial or ethnic origin, health information, or religious beliefs) unless required by law or with your explicit consent. Where we collect such data for equal opportunity monitoring or to accommodate specific needs during the recruitment process, we will inform you at the point of collection and explain how it will be used.

4. How We Use Your Personal Data

We process your personal data for the following purposes:

• Recruitment administration: managing your application, scheduling interviews, and communicating with you throughout the process

• Assessment and evaluation: evaluating your skills, qualifications, and suitability for the role and our company

• Verification: confirming information you have provided, conducting reference checks, and where applicable, background screening

• Legal compliance: fulfilling our legal obligations, including right to work checks and equal opportunity reporting

• Future opportunities: with your consent, retaining your data to consider you for future roles that may match your profile

• Defending legal claims: establishing, exercising, or defending legal rights

5. Legal Basis for Processing

Under the GDPR, we rely on the following legal bases to process your personal data:

• Legitimate interests: We have a legitimate interest in processing your data to evaluate candidates and make informed hiring decisions. Our interests are balanced against your rights and do not override them.

• Contract: Processing is necessary to take steps at your request prior to entering into an employment contract.

• Legal obligation: Processing is necessary to comply with applicable employment and immigration laws.

• Consent: In limited circumstances, such as retaining your data for future opportunities or processing special category data, we rely on your explicit consent, which you may withdraw at any time.

Other legal bases may apply locally, depending on the jurisdiction.

6. Who We Share Your Data With

We may share your personal data with the following categories of recipients:

• Internal personnel: Hiring managers, interviewers, and other team members involved in the recruitment process

• Service providers: Third-party providers who assist with recruitment, including our applicant tracking system (ATS) provider, background check providers, and assessment platforms

• Recruitment agencies: Where you have been referred by a recruitment agency

• Professional advisors: Legal, accounting, or other professional advisors where necessary

• Regulatory authorities: Government bodies, law enforcement, or regulators where required by law or to comply with legal processes

All service providers are bound by data processing agreements that require them to process your data only on our instructions and to maintain appropriate security measures.

7. International Data Transfers

As Gigs operates across multiple jurisdictions including, but not limited to, the EU, UK, United States, and Brazil, your personal data may be transferred to and processed in countries outside the EEA or the UK.

Where we transfer personal data from the EEA or UK to the United States, we rely on the EU-U.S. Data Privacy Framework (DPF) and its extensions (e.g, the UK Extension or Swiss-U.S. DPF, as applicable), and when necessary, the European Commission's Standard Contractual Clauses (SCCs).

Where we transfer personal data outside of the EEA or UK to countries that have not been recognized as providing an adequate level of data protection, we implement appropriate safeguards to protect your data. These safeguards include the SCCs and, where applicable, the UK International Data Transfer Addendum.

You may request a copy of the relevant data transfer mechanisms by contacting us using the details in Section 2.

8. Data Retention

We use strong safeguards to ensure your data is retained securely and only for legitimate purposes. We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, unless a longer retention period is required by law and in such case, we will retain the data for the legally required period.

• Successful candidates: If you are offered and accept a position with us, your recruitment data will become part of your employee record and will be processed in accordance with our Employee Privacy Notice.

• Unsuccessful candidates: We typically retain your data for 12 months following the conclusion of the recruitment process, unless you request earlier deletion or consent to longer retention for future opportunities.

• Talent pool: With your consent, we may retain your data for up to 24 months to consider you for future roles.

9. Your Rights

Depending on your location, you may have the following rights regarding your personal data:

• Right of access: You can request a copy of the personal data we hold about you.

• Right to rectification: You can request correction of inaccurate or incomplete data.

• Right to erasure: You can request deletion of your personal data in certain circumstances.

• Right to restrict processing: You can request that we limit how we use your data in certain circumstances.

• Right to data portability: You can request to receive your data in a structured, commonly used format.

• Right to object: You can object to processing based on legitimate interests.

• Right to withdraw consent: Where we rely on consent, you can withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us using the details in Section 2. We will respond to your request within one month, or inform you if we require additional time.

10. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include encryption of data in transit, access controls, and regular security assessments of our systems and processes.

Access to candidate data is restricted to personnel who require it for their role in the recruitment process, and all such personnel are bound by confidentiality obligations.

11. Automated Decision-Making

We do not make hiring decisions based solely on automated processing. While we may use technology to assist in taking notes during the interview process or organizing candidate information, all hiring decisions (e.g., reviewing resumes and applications, deciding whether a candidate moves through the interview process, and final hiring decisions) involve human review and evaluation.

12. Complaints

If you have concerns about how we handle your personal data, we encourage you to contact us first so we can address your concerns. You also have the right to lodge a complaint with a data protection supervisory authority. For candidates based in the EU, a list of supervisory authorities is available at: https://edpb.europa.eu/about-edpb/about-edpb/members_en

13. Updates to This Notice

We may update this notice from time to time to reflect changes in our practices or legal requirements. The date at the top of this notice indicates when it was last updated. We encourage you to review this notice periodically.

14. Contact Us

If you have any questions about this notice or wish to exercise your data protection rights, please contact us by contacting us using the details in Section 2. If you have a question about your application, please contact recruiting@gigs.com.