Effective July 25, 2023
This Privacy Notice describes Axonius, Inc. and its affiliated companies (collectively, “Axonius”, “we”, “our” or “us”) privacy practices regarding job candidates or applicants who apply or are recruited for a job with us (“Candidate”).
Axonius is a remote-first global company, with offices in the US, the UK, and Israel. While this Notice is intended to describe the broadest range of our privacy practices globally, those practices may vary based on the local legal requirements. This Notice does not create or form part of any contract for employment or otherwise.
We collect Personal Data directly from a Candidate (such as when a Candidate submits the job application or during the recruitment process - including interviews), indirectly from a Candidate (such as when a Candidate interacts with our website), or via third parties or sources (such as job boards and professional networking websites, Candidate’s named references, other Axonius personnel, background check providers, employment agencies and recruiters, publicly accessible sources, and our service providers). We may combine the Personal Data that the Candidate provides us with Personal Data provided via third parties and sources.
The provision of Personal Data is mostly necessary for us to consider the application (such as evidence of qualifications or work history), and we will not be able to process the application successfully if the related Personal Data is not provided. The provision of some more sensitive Personal Data is voluntary (e.g., information about ethnicity, health conditions, religious beliefs, sexual orientation, and Personal Data provided through interview recordings) and will not have an impact on our consideration of the job application.
Personal Data | (Business) Purposes of the processing | Legal basis |
---|---|---|
Identity and contact Data, including full name, gender, date of birth, nationality, contact details (e.g., telephone number, e-mail address and home address) and copies of documentation proving Candidate’s identity and right to work (e.g., passport, visa, ID card, or driving license) (Identifiers; Protected characteristics under California or US laws). Electronic identification Data, including user, log in and usage information with the tools we use for recruiting purposes, IP address, device/browser characteristics (Identifiers; Internet or other network activity Information). Professional or employment Information, including information from the job application or recruiters, interviews, recruiting exercises, resume or CV, cover letter, employment and professional history, military and reserves status, previously held directorships (if any), references, education details, professional qualifications (such as licenses, permits, certifications), desired position and compensation, location preferences, and willingness to relocate (Professional or employment information and related Inferences; Education Information). Interview recordings, including any Personal Data shared during interviews, as well as your voice and imagery as captured in the recording (Audio, electronic, visual, or similar Information). Sensitive Personal Data (SPD): - Background check information, such as information necessary to complete background, credit, drug/alcohol, and/or other checks, only where permitted by law, and information received during these checks; - Information provided in connection with accommodation requests, regarding potential disabilities or other health conditions, racial or ethnic origin, religious or philosophical beliefs, and/or sexual orientation; - Nationality and immigration status and other information such as residency and work permit status, state identification card, and passport number, that would allow us to verify the employment eligibility; - Health, travel, or medical examination information, where permitted by law, in order to prevent the spread of infectious disease, such as COVID-19. |
Recruitment management, which includes all the steps necessary to decide whether to enter into a contract with the Candidate, such as:
|
To take steps at the request of the Candidate prior to a contract; Legal obligation; Consent where appropriate. |
Recruitment administration, such as:
|
Legitimate interest; Consent where appropriate. |
|
Future communications, such as:
|
Legitimate interest; Consent where appropriate. |
|
Internal employee training, such as:
|
Legitimate interest; Consent where appropriate. |
|
Compliance, safety, and fraud prevention, such as:
|
Legal obligation; Legitimate interest; Consent where appropriate. |
|
Assessing and fulfilling accommodation requests and ensuring equal opportunities during the recruiting process (SPD). |
Legal obligation; Exercising Candidate’s rights; Consent where appropriate. |
|
Compliance with employment, social security, and social protection law (SPD). |
Legal obligation; Exercising Axonius or Candidate’s rights. |
|
Compliance with public health, health and safety, and disability discrimination laws, including protecting the health and safety of our personnel and visitors to our premises and complying with legal obligations, government guidelines, and public health advice to prevent the spread of infectious disease (SPD). |
Legal obligation; Public interest in the area of public health; Consent where appropriate. |
|
To resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties (SPD). |
Legitimate interest; Exercise or defense of a legal claim; Consent where appropriate. |
|
For any other lawful purpose or additional purpose that Candidate consents to. |
Legal obligation; Consent where appropriate. |
If the Candidate is located in a territory governed by privacy laws under which “Consent” is the only or most appropriate legal basis for the processing of Personal Data as described herein, the application for a job at Axonius will be deemed to constitute consent to the processing of Personal Data for all purposes detailed in this Privacy Notice.
The categories of Personal Information listed above have been collected, processed and disclosed within the last 12 months.
Personal Data does not include aggregated or de-identified information that is maintained in a form that is not reasonably capable of being associated with or linked to the Candidate.
We, our service providers and contractors maintain, store and process Personal Data in the US, the UK, the EEA, and Israel as well as other locations as reasonably necessary for the purposes of processing listed above, or as may be required by law.
While privacy laws may vary between jurisdictions, Axonius, its service providers and contractors are committed to handling the transfer of Personal Data in accordance with any appropriate lawful mechanisms and contractual terms, including (where appropriate) standard contractual clauses or similar mechanism adopted by the EU or the UK, to ensure an adequate level of protection.
We retain Personal Data for as long as we deem reasonably necessary to fulfill the purposes of processing listed above, taking into account the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure, and applicable legal and regulatory requirements.
We implement systems, applications, and procedures to safeguard Personal Data, to minimize the risks of theft, damage, loss, or unauthorized access or use of information. These measures provide robust, industry-standard security. To learn more about our cybersecurity program, please visit https://www.axonius.com/security.
In order to pursue the purposes of processing listed above, we may disclose Personal Data in the following ways:
Axonius affiliated companies; Change of control: We may disclose Personal Data internally within our group. In addition, should Axonius or any of its affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, or will be considered or found eligible for a governmental grant and/or a potential investment, Personal Data may be shared with the parties involved in such an event.
Service providers and contractors: We may, upon the execution of a written contract, engage selected service providers, to perform services on our behalf, or contractors, to provide complementary services that help us manage the recruiting process and operate our business and, limited to this purpose, grant them access to Personal Data as necessary. Such service providers and contractors may include or be related to job boards, recruiters, interviewing and testing services, pre employment screening, interview travel booking and expense reimbursement (where applicable), relocation (where applicable), recruitment analytics and software providers, and our business, immigration, legal, financial and compliance advisors.
Government or law enforcement authorities: We may disclose Personal Data to government or law enforcement authorities if (a) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process, or governmental request; (b) to enforce our agreements, policies, and terms of service; (c) the disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (d) such disclosure is required to protect our legitimate business interests, including the security or integrity of our assets, personnel, and rights.
Additional disclosures: We may disclose Personal Data in additional manners, pursuant to the Candidate request or consent, if we are legally obligated to do so, or if we have successfully anonymized such Personal Data.
We do not sell Candidate Personal Information, or share it with third parties for cross-context behavioral advertising purposes.
To the extent available in the appropriate jurisdiction, Candidates may have rights concerning their Personal Data. To exercise these privacy rights – please submit a data subject Request via our dedicated page or contact us by e-mail at privacy@axonius.com.
When Candidates ask us to exercise any of their privacy rights, we may require additional information, including certain Personal Data, in order to authenticate and process the request. Such additional information may be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request).
US Data Protection Rights
Depending on the US state of residence and applicable laws, Candidates may have the right to:
European Economic Area (EEA) and United Kingdom (UK) Data Protection Rights
Subject to applicable laws, Candidates may have the right to:
Updates and Amendments: We may update and amend this Privacy Notice from time to time by posting an updated version on our website. The amended version will be effective as of the date it is published.
Questions, comments or concerns: For any questions, concerns or complaint regarding our Privacy Notice, or our privacy practices, please contact us at:
- privacy@axonius.com
- via post at: 41 Madison Ave Floor 37, New York, NY 10010, USA, to the attention of the Legal Team
- via post at: 16 Great Queen Street, Covent Garden, London, United Kingdom, WC2B 5AH, to the attention of the Legal Team
- via post at: 32 Menachem Begin Street, The Circular Tower, Floor 23 Tel Aviv, Israel 6701101, to the attention of the Legal Team.
Representation for Candidates in the EU: We value Candidate’s privacy and rights in the EU and have therefore appointed Prighter Group with its local partners as our privacy representative and point of contact. Prighter gives an easy way to exercise privacy-related rights (e.g. requests to access or erase personal data). To contact us via our representative, Prighter, or make use of your data subject rights, please visit the following website.
Data Protection Officer: Axonius has appointed PrivacyTeam in person of Avishai Ostrin as our Data Protection Officer (DPO), for monitoring and advising on Axonius ongoing privacy compliance and serving as a point of contact on privacy matters for Candidates and supervisory authorities.