Conga Applicant Privacy Statement

 

  1. Personal data we use
  2. How we use your personal data and the basis on which we use it
  3. Your rights over your personal data
  4. Automated decisions about you
  5. Data sharing
  6. Data security and storage
  7. International data transfer
  8. Contact us and​ ​changes to the Privacy Statement


Privacy is important to Conga. 

We are providing this Privacy Notice (“Notice”) to help you understand what personal data we collect, why we collect it, and what we do with it. Personal information (“Personal Information”) or personal data means information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, and online identifier or to one or more factors specific to his/her physical, physiological, genetic, mental, economic, cultural, or social identity. 

We strongly encourage you to read this Notice carefully and contact [email protected] if you have any questions about our privacy practices or your Personal Information choices. 

This privacy statement describes the handling of personal data obtained about internal and external job applicants, including through the Conga online recruitment system and careers page (the "recruitment system") directly by job applicants as well as by third party agencies and recruiters on behalf of candidates. Personal data is information, or a combination of pieces of information, that could reasonably allow you to be identified. 

This privacy statement applies to Apttus Corporation and its worldwide affiliates and subsidiaries including AppExtremes, LLC dba Conga, Conga EMEA Ltd., Conga APAC Pty Ltd., Apttus EMEA Ltd., Apttus Software Private Limited, Conga Software Limited, Conga Software Private Limited, Apttus Switzerland LLC, Apttus Australia Pty Ltd., and Octiv, Inc., (collectively “Conga”) and describes Conga’s policies and procedures regarding the collection, use, and processing of personal data about you, how we use and protect this information, and your rights in relation to this information. To transfer data from the European Economic Area (“EEA”) to other countries, such as the United States, we comply with legal frameworks that establish an equivalent level of protection with EU law.

Standard contract clauses. The European Commission has approved the use of standard contract clauses as a means of ensuring adequate protection when transferring data outside of the EEA. By incorporating standard contract clauses into a contract established between the parties transferring data, personal data is considered protected when transferred outside the EEA or the UK to countries which are not covered by an adequacy decision. We rely on these model contract clauses for data transfers.

This notice is not intended and shall not be read to create any express or implied promise or contract for employment, for any benefit, or for specific treatment in specific situations. Nothing in this notice should be construed to interfere with Conga’s ability to process employee data for purposes of complying with our legal obligations, or for investigating alleged misconduct or violations of company policy or law, subject to compliance with local legal requirements.

Conga's processing of personal data is in all cases subject to the requirements of applicable local law, internal policy, and where applicable or appropriate, any consultation requirements with worker representatives. To the extent this notice conflicts with local law in your jurisdictions, local law controls.

 

1. PERSONAL DATA WE USE

We will collect your personal data from you directly and potentially from other sources. 

1.1         Data we collect directly from you

The categories of data that we collect directly from you include:

  1. personal (e.g. name, date of birth) and contact details (e.g. phone number, email address, postal address or mobile number)
  2. username and password for the online recruitment system
  3. information contained in your resume or CV, and other documents related to the application or recruitment process (e.g. cover letter, transcripts, certifications)
  4. educational details (e.g. educational history, qualifications, certifications, skills) and job history (e.g. previous employment, roles, performance history)
  5. data for diversity monitoring, where the collection of such data is allowed by law
  6. (e.g. race, ethnicity, gender, veteran status and/or disabilities)
  7. information about family and dependents (e.g. for relocation purposes) 
  8. information about any health issues or disabilities (e.g. your disability status, any requests for accommodation in the application or interview process)
  9. citizenship or immigration information (e.g. for visa purposes, right to work information) 
  10. debarment, suspension or related information as it relates to an award for a contract from a US federal agency
  11. on-premise location monitoring for security purposes (e.g. video surveillance when attending our premises for an interview)
  12. other information you may choose to voluntarily submit to us in connection with your application (e.g. information contained in a cover letter, information disclosed in an interview or information you volunteer regarding your criminal records history, compensation history, family history or personal situation)

We also collect information about you using cookies and similar technologies when you use the recruitment system and browse our website.

1.2         Data we collect from other sources:

 We may collect the following data about you from other sources: 

  1. background check data, potentially including your criminal records history (where allowed by law), employment history, educational history and/or compensation history, from employment screening agencies, publicly available registers or databases, former employers and/or educational institutions (as allowed by local laws)
  2. publicly available information from websites or social media, including information that you choose to voluntarily submit to us in connection with your application (e.g. when applying through LinkedIn)
  3. information about you from Conga employees who interview you and who may provide feedback about you 
  4. information about your performance or conduct from references, other Conga employees, clients or service providers, or former employers you work with and/or or with whom you may have worked in the past who may provide feedback about you

2. HOW WE USE YOUR PERSONAL DATA AND THE BASIS ON WHICH WE USE IT

We limit our use of your personal data. We aim to only collect and use your personal data for specific, necessary reasons and aim to explain our use of your personal data. For example, we use your personal data to: 

  1. create and manage the recruitment system and job applications
  2. assess and evaluate your skills, qualifications and interests against the position applied for and/or other positions within the Conga group of companies
  3. communicate with you in relation to your application and the recruitment process 
  4. if you are selected for employment, your personal data may be used for the purpose of entering into an employment relationship, including sending you correspondence or general information related to the employment relationship.
  5. verify your information, including through reference checks and, where applicable, background checks 
  6. send you information about the new hire and employee experience at Conga prior to your first day
  7. with your consent, send you information about other positions with the Conga group of companies which may be of interest to you 
  8. operate, evaluate and improve the recruitment system, our application tracking and recruitment activities (this includes analysing our job applicant base, our hiring practices or trends, identifying qualifications or skills shortages, and using information to match candidates and potential opportunities)
  9. detect, prevent and respond to fraud or potentially illegal activities (such as intellectual property infringement), misuse of the recruitment system, this Candidate Privacy Statement or other Conga policies
  10. perform audits, assessments, maintenance and testing or troubleshooting
  11. activities related to the recruitment system and our recruitment processes
  12. comply with legal obligations to which we are subject and cooperate with regulators and law enforcement bodies
  13. respond to your enquiries and requests

We must have a legal basis to process your personal data. In most cases the legal basis will be one or more of the following: 

  1. to comply with our contractual obligations to you or to take steps to enter into a contract with you 
  2. to comply with our legal obligations
  3. to meet our legitimate interests, for example to conduct our recruitment processes efficiently and fairly or to manage applicants effectively. When we process personal data to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy or other fundamentals rights and freedoms are not overridden by our legitimate interest to comply with our legal obligations, for example obtaining proof of your right to work status to enable us to meet relevant obligations.

When we are required by local law to collect certain personal data about you, your failure to provide this data may prevent or delay the fulfillment of our legal obligations and may impact our ability to employ you. If we ask for your consent to process your personal data, you may withdraw your consent at any time by contacting us using the details at the end of this privacy statement. 

3. YOUR RIGHTS OVER YOUR PERSONAL DATA 

You have certain rights regarding your personal data, subject to local laws. These include the following rights to:

  • access your personal data
  • fix any errors your personal data
  • erase or delete your personal data
  • restrict our use of your personal data
  • object to our use of your personal data
  • receive your personal data in a usable electronic format and transmit it to a third party (right to data portability)
  • lodge a complaint with your local data protection authority or regulatory body.

If you would like to exercise such rights, please contact us at [email protected]

We encourage you to contact us to update or correct your information if it changes or if the personal data we hold about you is inaccurate. 

4.  AUTOMATED DECISIONS ABOUT YOU

We do not generally make recruiting or hiring decisions based solely on automated decision-making or profiling (as defined within the EU General Data Protection Regulation). In the event that we choose to rely solely on automated decision-making that could have a significant impact on you or profiling, we will apply the appropriate safeguards as may be required by local law.

5. DATA SHARING

While we do not sell or market your personal data, we may share your personal data with third parties, including with:

  • Conga group companies. We may share your personal data with other companies that fall within the Conga group, for example for recruitment purposes, human resource management and internal reporting.
  • Service providers and business partners. ​We may share your personal data with our service providers and business partners that perform business operations for us. For example, we may partner with other companies to host the recruitment system and analyze data to improve performance or engage third parties to audit our systems, products or practices.
  • Law enforcement agency, court, regulator, tax authority, government authority or other third party. We may share your personal data with these parties if necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, your rights or the rights of any third party.
     

6. DATA SECURITY

The organisation takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.

We will keep your personal data until the position you are applying for has been filled, after which we will retain your personal data for a period of time that enables us to:

  • Maintain business records for analysis, understanding market trends and/or audit purposes
  • Comply with record retention requirements as required by local law or other relevant legal or regulatory requirements
  • Defend, establish, exercise or bring any existing or potential legal claims
  • Ensure fraud detection and prevention 
  • Respond to any queries or complaints you may have
  • With your consent, suggest other roles that may be of interest to you

We will delete your personal data when it is no longer required for these purposes. If there is any personal data that we are unable, for technical reasons, to delete entirely from our systems, we will ensure that appropriate measures are taken to prevent any further processing or use of the personal data.

7. INTERNATIONAL DATA TRANSFER

Because we operate as part of a global business, we may transfer, store, or process your personal data in a country different from where you reside. If you reside in the European Economic Area, while we may transfer, store, or process your personal data in a country that is not regarded as ensuring an “adequate” level of protection for personal data, we have put in place appropriate safeguards (such as Standard Contractual clauses​) to ensure that your personal data is adequately protected. 

8. CONTACT US AND CHANGES TO THE PRIVACY NOTICE

If you have questions or concerns regarding the way in which your personal data has been used or about this privacy notice, please contact the [email protected]  

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the data protection authority in the country where you reside. If you reside in a country that is a member of the European Union, you may find the contact details for your appropriate data protection authority on the following website.   

We may modify or update this privacy statement from time to time. If we make a material change this privacy statement, we will notify you of the change.