C2FO Recruitment Privacy Policy

Last Updated Date: January 24, 2024

This Privacy Policy governs the manner in which Pollen, Inc. (“C2FO”) collects, uses, maintains and discloses information collected from team members and applicants (“you” or “your”). C2FO is committed to respecting your privacy and protecting your personal data. This privacy policy also describes the choices available to you regarding the use of Personal Information and how you can access and update this information.

This Privacy Notice only applies to the personal data of job applicants, potential candidates for employment or partnership, and those who participate in our recruiting programs and events.

By submitting your personal data to us, you acknowledge that:

You have read and understood this Privacy Notice and agree to the use of your personal data as set out herein.
Your personal data may be transferred and processed worldwide, including in countries that may not be deemed to provide the same level of data protection as your home country, for the purposes and in the manner specified in this Privacy Notice.
You are not required to provide any requested information to us, but your failure to do so may result in our not being able to continue your candidacy for the job for which you have applied.
All of your representations are true and correct to the best of your knowledge and belief, and you have not knowingly omitted any related information of an adverse nature. Providing any inaccurate information may make you ineligible for employment.
This Privacy Notice does not form part of any contract of employment offered to candidates hired by C2FO.

What Information Does C2FO Collect?

Personal Information or Personal Data refers to any information relating to an identified or identifiable natural person. We collect Personal Information from you in a variety of ways, including, but not limited to, when you apply for a role with us through our online application process. C2FO would collect such information as your name, address, contact information, work and educational history, identity documents and other categories of data that you voluntarily share with us. We also collect data about you which is created by our recruiting personnel in the course of their interactions with you during the recruiting process or through your participation in our interactive assessment tools. If you receive an offer from us, we may then conduct a background check and, to the extent permitted by applicable law, we may also collect data related to criminal offences and proceedings. We also collect similar personal data about you from third parties, such as professional recruiting firms, your references, prior employers, C2FO employees with whom you have interviewed or who recommended you for a position, and, to the extent permitted by applicable law, employment background check providers. We may also collect personal data about you online to the extent that you have chosen to make this information publicly available on professional social media websites. For example, we may find your profile on LinkedIn and contact you about suitable roles.

Sensitive personal data is a subset of personal data that includes ethnicity, health, trade union membership, philosophical beliefs, sexual orientation, and other categories as prescribed by law. We may collect sensitive personal data about a candidate to the extent permitted or required to do so by applicable laws (e.g., U.S. equal opportunity laws) and to support our efforts to create an inclusive and diverse work environment. Under limited circumstances and to the extent permitted by applicable law, we may also collect sensitive personal information relating to health and medical characteristics, to address our public health and workplace safety obligations and to provide reasonable accommodations to facilitate the interview process (in case of disabilities).

How C2FO uses collected information

C2FO collects and uses your Personal Information for legitimate human resources and business management including but not limited to for the following purposes:

To identify and evaluate a candidate for potential employment, as well as for future roles that may become available;
To maintain records in relation to recruiting and hiring;
To ensure compliance with legal requirements, including those relating to public health and workplace safety;
To foster our diversity and inclusion programs and practices;
If you receive an offer from us, to conduct background checks, including, to the extent permitted by applicable law, criminal history checks;
To protect our legal rights to the extent authorized or permitted by law; and
To protect the workplace and communicate with medical professionals, law enforcement, or other public authorities in the event of an emergency or public health event, such as when the health or safety of you or one or more individuals may be endangered.

Additionally, we may also use your personal data for C2FO analytics purposes, including in aggregated/pseudonymized form, to improve our recruitment and hiring process and augment our ability to attract successful candidates.

Legal basis for processing your personal data

Our processing of your personal data for the purposes mentioned above is based in one or several of the following legal grounds:

in part, on our legitimate business interests in evaluating your application to manage our relationship with you, to ensure that we recruit appropriate employees, and to evaluate and maintain the efficacy of our recruiting process more generally; and in operating our business and protecting C2FO and its employees, clients, and third parties. When we rely on this legal ground, C2FO will only process your personal data after assessing the adequacy, proportionality, and legitimacy of the data processing activity;
in part, on our performing contractual and precontractual measures relating to our potential employment relationship with you;
in part, on our complying with applicable law with regard to personal data necessary to satisfy our legal and regulatory obligations, including with regard to public health and workplace safety;
in part, on your consent, if we offer you the opportunity to participate in our optional recruiting programs or if we collect sensitive personal data for legally permitted purposes other than compliance with our legal obligations regarding public health and workplace safety.

Background screening

If you receive an offer from us, we may conduct a background check on you or instruct a third party to do so on our behalf. Background screening will only be done where permitted by the law applicable to the location where the position is located and to the extent necessary and proportionate to the role that you are being offered. A background check will only involve criminal background data to the extent permitted by law. Our legal basis for background screening is our need to perform precontractual measures related to establishing our employment relationship. If a background screening is required, you may be contacted by a third-party background screening service provider to request authorization for the release of your information, and at that time you will be provided with further information about the process and what personal data it might involve.

How C2FO shares the information we collect

Your personal data may be accessed by recruiters and interviewers working in the country(ies) where the position(s) for which you are applying is(are) based, as well as by recruiters and interviewers working in different countries within the C2FO global organization. Individuals performing administrative functions and IT personnel within C2FO may also have access on a need to know basis to your personal data to the extent necessary perform their jobs. In some countries, you may have fewer rights under local law than you do in your country of residence, but we have put in place legal mechanisms designed to ensure adequate data protection for your personal data when it is processed by C2FO subsidiaries and affiliates within the C2FO global organization and by C2FO’s service providers, including the transfer of your personal data to countries other than the one in which you reside.

Except to the extent necessary to accomplish the C2FO uses and purposes described in this Privacy Notice, we do not disclose your personal data to third parties. We also prohibit our service providers from using your personal data for non-C2FO purposes. We do not otherwise share or sell your personal data to third parties.

We maintain processes designed to help ensure that any processing of personal data by third-party service providers is consistent with this Privacy Notice and protects the confidentiality, availability, and integrity of your personal data in compliance with applicable law. Where required by law, we put in place additional legal mechanisms designed to help ensure adequate data protection for your personal data when transferred to another country.

In addition, we may disclose or transfer your personal data in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business.

Your rights

We take reasonable steps that are designed to keep your personal data accurate, complete, and up-to-date for the purposes for which it is collected and used. We also have implemented measures that are designed to help ensure that our processing of your personal data complies with this Privacy Notice and applicable law.

Subject to applicable law, including exceptions, you have the following rights with regard to the personal data that we collect about you:

right to request information about the personal data that we hold about you, including information about how we use your personal data.
right to request a copy of the personal data that we hold about you;
right to request portability of your data to permit you to provide a copy of your personal data in a structured, commonly used, and machine-readable format and to transmit that personal data to another controller;
right to request that we correct or otherwise amend your personal data if it is not correct or otherwise not complete, timely, and accurate for the purposes for which we are using it;
right to request deletion of your personal data;
right to request that we cease processing or restrict or limit the processing of your personal data;
right to withdraw your consent to our processing of your personal data where the basis of our processing is your consent. This right may not apply if there are other legal justifications to continue processing or we need to retain certain personal data where required or permitted under applicable law
right to not be discriminated against for exercising your individual rights regarding your personal data;
right to seek additional legal remedies regarding our response to your request to exercise your individual data-protection rights, depending upon your jurisdiction, by lodging a complaint with your data-protection authority or initiating a legal proceeding.

If you would like to exercise your data protection rights regarding your personal data, you can do so by the C2FO Chief People Officer at krissy.young@c2fo.com.

Upon receipt of your request to exercise your data protection rights, we will acknowledge receipt within the time period required by applicable law and provide you with information about the next steps in the process and the timing. To help protect your privacy and security, we may take reasonable steps to verify your identity before acting on certain data protection rights, in accordance with applicable law. If you are using an authorized agent to exercise your data protection rights and that agent does not provide a power of attorney with the initial request, we may request further evidence of the agent’s right to act on your behalf, including valid written authorization or contacting you to verify the request.

Please note that applicable laws include exceptions to assertions of data protection rights that may prevent us from providing access to your personal data or otherwise fully complying with your request. If we believe exceptions apply, we will respond to your request to the extent we are able to do so, and we will provide an explanation of the basis for not complying wholly or partially with your request.

Data Retention

If you accept an offer of employment with us, any relevant personal data collected during your pre-employment period will become part of your personnel records and will be retained in accordance with specific country requirements and with the privacy notice applicable to C2FO employees, which will be provided during the on-boarding process.

If we do not employ you, and unless you object by following the process described in the Section “Your Rights” above, we may nevertheless continue to retain and use your personal data for a period of time (which may vary depending on the country) for system administration purposes, to consider you for potential future roles, and to perform research. Thereafter, we retain a minimal amount of your personal data to record your recruiting activity with us.

To the extent that we have collected personal data, including sensitive personal data, for the specific purpose of fulfilling our legal obligations regarding public health or workplace safety, we will retain that data for the duration of those legal obligations. Thereafter, we retain a minimal amount of your personal data to establish our compliance with those obligations.

How we protect your information

We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your Personal Information, username, password, transaction information and data.

Miscellaneous

Cookies

C2FO, our analytics or service providers, and our third-party partners use cookies or similar tracking technologies. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

Log Files

As is true of most web sites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this for purposes of analytics and to improve site functionality.

Governing Language

This Privacy Policy is entered into in the English language. Any translation prepared for any reason shall be a non-binding accommodation of no legal effect, and the English version of this Privacy Policy shall govern. You may request this Privacy Policy in an alternate language. In the event of any conflict between the English version and any translations of this Privacy Policy, the English version shall prevail.

Modifications

C2FO reserves the right to modify this Privacy Policy as required by changes to our business processes or applicable law. We will post any changes to our Privacy Policy.

Contacting us

If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this site, please contact us at:

Pollen, Inc.
2020 W 89 St, Suite 200
Leawood, KS 66206
888.980.9025
support@c2fo.com