About this Policy
This Applicant Privacy Policy (the “Policy”) describes how Cybera Global, Inc. (“Cybera,” “we,” “us,” and/or “our”) handles personal information we collect from job applicants (“applicants”) in connection with our application and recruitment process. As used in this Policy, “personal information” means any information relating to an identified or identifiable individual. This Policy does not form part of any contract of employment or other contract to provide services. We may update this Policy at any time.
Information We Collect
We collect personal information that you provide to us in connection with your application through our careers page or application portal, including: your name, email address, telephone number, mailing address, and other contact information; your resume or CV, cover letter, work history, education history, skills, licenses, certifications, and memberships; work authorization status; references and referral source information; employment preferences such as willingness to relocate, desired salary, and current compensation; and anyother information you elect to provide in support of your application.
If you do not provide sufficient information, we may be unable to consider you for employment.
Please avoid submitting the following categories of sensitive information unless such information is legally required or specifically requested: information on race, religion, ethnicity, nationality or national origin, age, gender identity, sex life or practices or sexual orientation, marital status, medical or health information (including disability status), genetic or biometric information, political or philosophical beliefs, political party or trade union membership, criminal records, and veteran status. Not withstanding the foregoing, we may separately request voluntary self-identification information (such as race, gender, veteran status, and disability status) for equal employment opportunity monitoring and compliance purposes as required by applicable law. Any such self-identification data is collected separately from your application, is kept confidential, and is not used in making hiring decisions.
If the personal information you provide contains details of the categories referenced in the preceding paragraph, or your job evaluations or educational records, you expressly consent to our processing of such details for the purposes of your job application.
Any information you submit as part of your application must be true, complete, and not misleading.
It is your responsibility to ensure that information you submit does not violate any third party’s rights.
If you provide us with personal information of a reference or any other individual as part of your application, it is your responsibility to obtain consent from that individual prior to providing the information to us.
Use of Information and Legal Basis
We collect and process your personal information on the following legal bases:
a) Because this information is necessary to take steps at your request prior to entering into an employment relationship
(GDPR Art. 6(1)(b));
b) Because we have a legitimate interest in evaluating candidates and managing our recruitment process (GDPR Art. 6(1)(f));
c) To comply with a legal obligation to which we are subject (GDPR Art. 6(1)(c));
d) Where you have given your consent (GDPR Art. 6(1)(a)), which you may withdraw at any time; or
e) For the processing of sensitive personal information, where necessary for compliance with employment and social security law (GDPR Art. 9(2)(b)), for the assessment of your working capacity (GDPR Art. 9(2)(h)), or with your explicit consent (GDPR Art. 9(2)(a)).
We use your personal information for our recruitment, management, and planning purposes, as permitted by applicable law, including:
- To process your application;
- To assess your capabilities and qualifications for a job;
- To conduct reference checks;
- To respond to your inquiries and communicate with you about your application, and to send you information regarding changes to our terms and policies;
- To comply with or monitor compliance with any applicable law or regulation;
- To conduct background checks if we offer you a position; and
- To preserve our other legitimate interests, for example, for our administrative purposes, aggregate management reporting, internal training, and as generally required to conduct our business.
The information about you will be added to our candidate database. If you do not wish us to do this, please contact us at privacy@cybera.io.
If we hire you, personal information we collect in connection with your application may be incorporated into our human resources system and may be used to manage the new-hire process; any such information may become part of your employee file and may be used for other employment-related purposes.
We may also use the information as we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities; (d) to protect our legal rights and operations or the rights, privacy, safety or property of us, you, or others; and (e) to allow us to pursue available remedies or limit the damages that we may sustain.
Disclosure of Personal Information
We may share personal information with affiliates and/or partners that are involved in evaluating candidates for a given position. We will make the information available to personnel with a business need to know the information, including personnel in the recruiting, human resources, and information technology departments, and in the department responsible for the position for which you are applying.
We may share personal information with third-party service providers who provide services such as hosting and operating our application portal, recruiting assistance, background check processing, and similar services.
We also may share personal information as we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities; (d) to protect our legal rights and operations or the rights, privacy, safety or property of us, you, or others; and (e) to allow us to pursue available remedies or limit the damages that we may sustain.
We may transfer information in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
Cybera operates globally, which means your personal information may be stored and processed outside of the country or region where it was originally collected, including in the United States. When we transfer personal information internationally, we implement appropriate safeguards as described in the “Transfers of Personal Information” section below. We take reasonable steps to ensure that any third parties to whom we disclose personal information are bound by confidentiality and data protection obligations consistent with this Policy.
Data Retention
We keep your personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained. Unless otherwise required by applicable law, the following retention periods apply: (a) for applicants inthe United States, we generally retain applicant personal information for a period of twenty-four (24) months following the conclusion of the application process; (b) for applicants in the European Union (“EU”), European Economic Area (“EEA”), and the United Kingdom (“UK”), applicant data is deleted four (4) months after formal reject in, or eighteen (18) months after formal rejection if the applicant has consented to longer retention. The criteria used to determine our retention periods include (i) for as long as we have an ongoing relationship with you; (ii) as required by a legal obligation to which we are subject (including applicable record retention requirements under employment laws); or (iii) as advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).If you accept a position with Cybera, we will retain your applicant data in accordance with the data retention practices set forth in our personnel privacy policy.
Data Subject Rights
Depending on your location and applicable law, you may have the following rights with respect to your personal information. To exercise any of these rights, please contact us at privacy@cybera.io. We will respond to your request without undue delay and in any event within one month of receipt (or such longer period as permitted by applicable law).
Right of access: You may have the right to obtain confirmation as to whether your personal information is being processed and, where that is the case, to request access to and a copy of your personal information.
Right to rectification: You may have the right to obtain the rectification of inaccurate personal information concerning you.
Right to erasure (right to be forgotten): You may have the right to request that we erase your personal information. In some jurisdictions, this right may be limited to data that is unnecessary, excessive, or unlawfully processed.
Right to restriction of processing: You may have the right to request that we restrict the processing of your personal information in certain circumstances.
Right to data portability: You may have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit that information to another controller without hindrance.
Right to object: Under certain circumstances, you may have the right to object to the processing of your personal information on grounds relating to your particular situation. We will cease processing unless we demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.
Right to withdraw consent: Where we rely on your consent for any processing activities, you have the right to withdraw your consent at any time. Such withdrawal will not affect the lawfulness of processing carried out prior to the withdrawal.
Right to lodge a complaint: You have the right to lodge a complaint with the competent data protection authority in your jurisdiction. For contact details of your local data protection authority inthe EEA, please see https://edpb.europa.eu/about-edpb/about-edpb/members_en. If you are located in the UK, please see https://ico.org.uk/make-a-complaint/data-protection-complaints/.
We may request proof of identification to verify your request. We may deny or restrict fulfillment of your request in some cases, such as when your access to data places another individual’s privacy rights at risk or the continued processing of your data is necessary to comply with a legal obligation. If so, we will notify you of the reason(s) for this denial.
Transfers of Personal Information
Due to the global nature of our business, your personal information may be transferred to, stored in, or processed in countries other than the country in which it was collected, including the United States. These countries may have data protection laws that differ from those in your jurisdiction.
With regard to transfers of applicant personal information from the EU/EEA and the UK to the United States, Cybera Global, Inc. complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”) and the UK Extension to the EU-U.S. Data Privacy Framework (“UK Extension to the EU-U.S. DPF”), as set forth by the U.S. Department of Commerce. Cybera Global, Inc. has certified to the U.S. Department of Commerce that it adheres to the Data Privacy Framework Principles (“DPF Principles”) with regard to the processing of applicant personal information received from the EU/EEA in reliance on the EU-U.S. DPF and from the UK (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. To learn more about the Data Privacy Framework program, please visit https://www.dataprivacyframework.gov/s/.
If Cybera Global, Inc. withdraws from the DPF, the DPF is invalidated, or personal information otherwise cannot be lawfully transferred based on the DPF, or for transfers to countries other than the United States, Cybera will rely on appropriate European Commission-approved or UK Government-approved Standard Contractual Clauses, or otherwise transfer personal information in accordance with applicable data protection laws. You are entitled to obtain a copy of these agreements by contacting us using the information provided in the “Contact Us” section below.
Please direct any inquiries or complaints regarding our compliance with the DPF Principles to the contact information listed in the “Contact Us” section below. Under certain conditions specified by the DPF Principles, you may also be able to invoke binding arbitration to resolve your complaint. Cybera Global, Inc. is subject to the investigatory and enforcement powers of the United States Federal Trade Commission. If Cybera Global, Inc. shares personal information with a third-party service provider that processes the data solely on our behalf, then Cybera Global, Inc. will be liable for that third party’s processing of personal information in violation of the DPF Principles, unless Cybera Global, Inc. can prove that it is not responsible for the event giving rise to the damage.
Security
We use reasonable organizational, technical and administrative measures to protect personal information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contact Us” section below.
In the event of a data breach involving your personal information, we will notify you and the relevant supervisory authorities in accordance with applicable law.
Links to Third Party Websites
Our application portal or careers page may contain links to other websites. This Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which our portal links. The inclusion of a link does not imply endorsement of the linked site or service by us. We encourage you to read the legal notices posted on those sites, including their privacy policies.
International Use
Our application portal is operated from the United States. If you are located outside the United States, please be aware that information you provide to us will be transferred to and processed in the United States, which may have different data protection laws than your country of residence. By submitting your application, you acknowledge this transfer.
Our application portal is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to local law or regulation.
California Applicant Privacy Rights
If you are a California resident, please also review our California Applicant Privacy Notice below for more information about the categories of personal information we collect and disclose, as well as how to exercise your rights under California law.
State Privacy Laws
In addition to the California-specific rights described above, residents of other states with applicable consumer privacy laws (including, without limitation, Virginia, Colorado, Connecticut, Texas, Oregon, Montana, Tennessee, Indiana, Iowa, Delaware, New Jersey, New Hampshire, Kentucky, Nebraska, Maryland, and Minnesota) may have similar rights with respect to their personal information, including the right to access, correct, delete, and obtain a copy of their personal information, as well as the right to opt out of certain processing activities. If you are a resident of a state with an applicable privacy law and wish to exercise your rights, please contact us using the information provided in the "Contact Us" section below. We will process your request in accordance with applicable law.
Automated Decision-Making
We do not use solely automated decision-making, including profiling, to make hiring decisions that produce legal or similarly significant effects. We may use automated tools or technologies to assist in the screening, assessment, or evaluation of job applications. These tools may be used to filter applications based on qualifications, experience, or other job-related criteria, but no solely automated decision will be made regarding your application without human review. If you have questions or concerns about the use of automated tools in connection with your application, or if you wish to request an alternative selection process or accommodation where required by applicable law, please contact us using the information provided in the "Contact Us" section below.
About Children
Our application portal is not intended for individuals under the age of 18 (or such other minimum age as may be required by applicable law in your jurisdiction).
Changes to this Policy
We reserve the right to amend this Policy at any time in order to address future developments or changes in industry or legal trends. We will post the revised Policy on our careers page or otherwise make it available to applicants.
You can determine when the Policy was last revised by referring to the “Last Updated” date at the top of this Policy.
Any changes will become effective upon the posting of the revised Policy. By continuing to use our application portal following such changes, you acknowledge and accept the updated terms of this Policy.
If you do not agree with the terms of this Policy, in whole or part, you can choose not to continue to use our application portal.
Contact us
If you have questions or requests, please feel free to contact us at privacy@cybera.io or by mail at:
Cybera Global, Inc.
122 Grand Street.
New York, NY 10013
If you are not satisfied with our response to your inquiry or concern, you may also have the right to lodge a complaint with the applicable regulatory authority, including your state attorney general, the Federal Trade Commission (FTC), or, for applicants in the EU/EEA, your local data protection authority (see https://edpb.europa.eu/about-edpb/about-edpb/members_en), or, for applicants in the UK, the Information Commissioner’s Office (see https://ico.org.uk/make-a-complaint/data-protection-complaints/).
California Applicant Privacy Notice
Cybera Global, Inc. and its subsidiaries and affiliates (collectively, “Cybera,” “we,” “us,” or “our”) respect your privacy. This California Applicant Privacy Notice (“Notice”) applies to Personal Information that we collect as a Business during the application or recruitment process from California residents (collectively, “you” or “applicant”).
For the purposes of this Notice, “Personal Information” and other capitalized terms not otherwise defined in this Notice have the meanings provided in the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”).
Personal Information does not include information that is: (a) publicly available, as defined by the CCPA; (b) deidentified or aggregated; or (c) otherwise excluded from the scope of the CCPA.
1. Information you provide directly through our application portal.
In the preceding twelve months since this Notice was last updated, we have collected Personal Information from the following categories of sources: (a) you (job applicants); (b) referrals and references; (c) affiliates; (d) third-party service providers such as recruiters and recruiting platforms; and (e) publicly available information and databases, including professional networking services.
2. Collection and Disclosure of Personal Information
The chart below provides the categories of Personal Information and Sensitive Personal Information (as defined by the CCPA) we have collected, disclosed for a business purpose, or sold or “shared” (for cross-context behavioral advertising purposes) in the preceding twelve months since this Notice was last updated. The examples provided for each category reflect each category’s statutory definition and may not reflect all of the specific types of Personal Information associated with each category.
Disclosures of Personal Information
In the preceding twelve months since this Notice was last updated, we have disclosed Personal Information to the following categories of third parties:
Affiliates: Our affiliate companies. Personal Information we disclosed: Identifiers; Categories of Personal Information in Cal. Civ. Code Section 1798.80(e); Characteristics of Protected Classifications under California or Federal Law; Geolocation Data; Professional or Employment-Related Information; Inferences Drawn from Personal Information; Sensitive Personal Information (Group Membership); and Sensitive Personal Information (Contents of Communications).
Third-Party Service Providers: Third-party service providers that perform operations on our behalf. Personal Information we disclosed: Identifiers; Categories of Personal Information in Cal. Civ. Code Section 1798.80(e); Characteristics of Protected Classifications under California or Federal Law; Geolocation Data; Professional or Employment-Related Information; Inferences Drawn from Personal Information; Sensitive Personal Information (Group Membership); and Sensitive Personal Information (Contents of Communications).
Third Parties with Consent: Other third parties for whom we have obtained your permission to disclose your Personal Information. Personal Information we disclosed: Identifiers; Categories of Personal Information in Cal. Civ. Code Section 1798.80(e); Characteristics of Protected Classifications under California or Federal Law; and Professional or Employment-Related Information.
Use of Personal Information
We collect, use, or disclose your Personal Information in accordance with the following specific business purposes: (a) recruitment purposes, such as sourcing eligible job applicants, receiving, evaluating, and processing job applications, verifying information and conducting reference checks, communicating about the recruitment process and your application, scheduling interviews, and improving the recruitment process; (b) legal and compliance purposes, such as implementing and monitoring compliance with internal policies and procedures, equal opportunity and anti-discrimination legal regimes, managing discrimination and harassment claims, processing legal claims, investigating or responding to suspected fraud or other illegal activity, pursuing legal rights and remedies, complying with laws and legal processes, and conducting internal investigations and audits; and (c) other business purposes for which we provide specific notice at the time information is collected.
Your California Privacy Rights
If you are a California resident, you may exercise the following rights:
Right to know and access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information collected or disclosed by us; (2) purposes for which categories of Personal Information are collected by us; (3) categories of sources from which we collect Personal Information; (4) categories of third parties to whom we disclosed Personal Information; and (5) specific pieces of Personal Information we have collected about you during the past twelve months.
Right to delete. Subject to certain exceptions, you may submit a verifiable request that we delete Personal Information about you that we have collected from you.
Right to correct. You have the right to correct inaccurate Personal Information that we maintain about you.
Verification. Requests for access to, deletion, or correction of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations.
Right to opt out. In some circumstances, you may opt out of the sale or sharing (for cross-context behavioral advertising purposes) of your Personal Information.
Right to limit use and disclosure of sensitive personal information. In some circumstances, you may limit our use and disclosure of your Sensitive Personal Information. We do not use or disclose your Sensitive Personal Information for purposes other than the limited purposes permitted by the CCPA.
Right of no retaliation. You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.
Submit requests. To exercise your rights under the CCPA, send an email to privacy@cybera.io.
Authorizing an agent. If you are acting as an authorized agent to make a request to know, delete, correct, or opt out on behalf of a California resident, please contact us at privacy@cybera.io and attach a written authorization signed by the resident.
Contact us
If you have any questions, comments, or concerns about this Notice or our processing activities, please email us at privacy@cybera.io or write to us at:
Cybera Global, Inc.
122 Grand Street.
New York, NY 10013
