Comeet Privacy Policy
We at Pipl, Inc. (“Pipl“, “we”, “us”, “our”) use Comeet (“Comeet”, “them”, “they”), a recruiting and applicant tracking platform (the “Platform”), to recruit for open employment positions.
This Privacy Notice (the “Notice“) describes the ways that Pipl, using Comeet’s Platform, handles your personal data. It also describes the rights and options available to you with respect to your information. For Pipl’s general privacy policy, you can visit https://pipl.com/privacy-policy.
Please note that this Notice covers Pipl’s privacy practices related to your personal data during the candidate selection process and while interacting with the Platform. If this Notice conflicts with Comeet’s privacy notice, then this Notice will apply.
DATA CONTROLLER AND DATA PROCESSOR
Pipl is the data controller of the personal data on the Comeet Platform. We determine the purposes and means of processing your data. Our address is 510 S. Clearwater Loop, Suite 100 Post Falls, Idaho 83854. We can be reached by email at privacy@pipl.com.
Comeet is the data processor of your personal data on the Platform, processing the data on behalf of Pipl. Comeet’s address is 109 South 5th Street, Brooklyn, New York, United States. They can be reached by email at support@comeet.co.
PERSONAL DATA PROCESSED
We collect information about you relating to your candidacy for positions at Pipl. You are not legally required to provide us your information.
We collect the following information about you as a candidate for positions at Pipl: contact information, address, Curriculum Vitae (resumé) information (including information such as skills, work experience, education), notes submitted with the application, URL of your LinkedIn and other online profiles, the position for which you have been or are being considered, the source who submitted your candidacy (e.g., recruiting agency, referral), email correspondences between you and us and between us and other sources (such as recruiting agency and referrals) about your candidacy, information from references, events in the lifecycle of your candidacy, your responses to questionnaires sent to you by us, information about your candidacy and employment options (such as availability to be hired and salary expectations), evaluations of your candidacy, internal discussions within Pipl about your candidacy, materials you or other parties (such as evaluators or background check providers) submitted in relation to your candidacy. If you submit your candidacy by email, or online, then you are the main source of the personal data. In that case, you do not have a legal duty to provide the information, and providing it, is subject to your desire. However, the information is necessary for Pipl to consider your candidacy for the position. Your personal data on Comeet can also originate from other sources, such as LinkedIn profile, recruitment agencies and headhunters and referrals. For more information about the source from which your personal data originates, contact us, in accordance with this Notice.
Comeet, as a processor for Pipl, also collects analytical information about your use of the Platform and your recruitment process.
When you use the Platform, Comeet will collect statistical and analytics information about your use of the Platform, and de-identified information about your candidacy, including: IP address from which you accessed the Platform, time and date of access, type of browser used, language use, links clicked, actions taken while using the Platform, de-identified information about your skills, education and experience, your salary expectations, and your recruitment process (“Analytical Information“).
HOW YOUR PERSONAL DATA IS USED
Pipl will use your personal data to evaluate and consider you as a candidate for positions, in accordance with our processes and policies for evaluating employment candidates. We will also use this information to contact you about job openings and your candidacy. The legal basis under EU law for processing your personal data for this purpose is for our legitimate purpose in evaluating candidates for positions.
WHO WILL PROCESS YOUR DATA
Comeet will not share your information with third-party recipients, except as listed at http://help.comeet.co/en/articles/3132004-comeet-sub-processors, or if you give your explicit consent. Your personal data will be handled by Comeet’s service providers helping them operate the Platform. These companies are authorized to use your personal information only as necessary to provide these services to us and Comeet. These companies are not authorized to use your personal information for their own promotional purposes. We do not sell your personal information to third parties. Comeet will share your general recruitment status with third parties who submitted your candidacy to Pipl.
SUBMISSIONS BY THIRD-PARTIES
If your details are submitted to Pipl by a third-party (such as an employee of Pipl or a recruiting agency), Pipl can give the third-party access to your name, photo and general recruitment status.
INDIRECT REFERRALS
If you apply to a job opening using a unique referral link that was provided to you by an employee of Pipl, we may share your general recruitment status, without identifying you by name, with the person that provided you the referral link. The purpose of sharing the above information is to operate incentive programs (i.e. employee referral bonus programs) of Pipl and to provide feedback to third-parties who submit candidates to us regarding their submission. The legal basis under EU law for processing your personal data in this manner is Pipl’s legitimate purpose in running its recruitment program.
If you have seriously abused your rights to use the Platform, or violated any applicable law, we will share your information with competent authorities and with third parties (such as legal counsels and advisors), for the purpose of handling the violation or breach. The legal basis under EU law for processing your data for this purpose is our legitimate interests in defending and enforcing against violations and breaches that are harmful to our business. We will share your Information if we are legally required.
If we are required to disclose your information by a judicial, governmental or regulatory authority, the legal basis under EU law for processing your data for this purpose is our legitimate interests in complying with mandatory legal requirements imposed on us.
We will share your Information with third-party in any event of change in Pipl’s structure. If the operation of the Platform is organized within a different framework, or through another legal structure or entity (such as due to a merger or acquisition), we will share your information only as required to enable the structural change in the operation of the Platform. The legal basis under EU law for processing your data for this purpose is our legitimate interests in our business continuity.
DATA RETENTION
Pipl will retain your data for an initial period during the candidate selection process. The initial retention period is a period of time after the latest of: (1) Pipl adding your data to Comeet, and (2) the last activity Pipl performs regarding your candidacy on Comeet. If you become employed by Pipl, your data will be retained as part of your employee file. If you are not selected by Pipl for employment, Pipl will retain your data only for as long as is necessary to satisfy any obligations contained within the Notice. In general, Pipl will keep your data for the initial retention period and we will then pseudonymize it. Once pseudonymized, your data will be restored if you subsequently apply or are applied to another position. You can consent to Pipl keeping your data for a longer retention period in order to contact you about positions in the future.
If you provide consent to retain your data for a longer period, the legal basis for retaining your data beyond the initial retention period is your consent. If you’ve given your consent, you can withdraw it at any time by contacting us. Note that in any event, a backup copy of your data will be kept by Comeet for a period of up to one year following data removal or pseudonymization, for purposes such as disaster recovery.
DATA SECURITY
We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use or disclosure of your personal information. While we seek to protect your information to ensure that it is kept confidential, we cannot guarantee the security of any information. You should be aware that there is always some risk involved in transmitting information over the internet and there is also some risk that others could find a way to thwart our security systems. As a result, while we strive to protect your personal information, we cannot ensure or warrant the security and privacy of your personal information or other content you transmit using the Services or Websites, and you do so at your own risk. Thus, we encourage you to exercise discretion regarding the personal information you choose to disclose.
INTERNATIONAL DATA TRANSFERS
Comeet, on behalf of Pipl, transfers your personal data from within the European Union to locations outside the European Union. Comeet is located in the United States and is involved in processing your data there. International data transfers to Comeet are safeguarded with EU Commission certified standard data protection contract clauses. The safeguards for international data transfers to Comeet’s sub-processors are set out in Comeet’s list of sub-processors in http://help.comeet.co/en/articles/3132004-comeet-sub-processors.
YOUR EU RIGHTS
If you are in the EU, you may ask us to receive a copy of your personal information that is stored on the Platform, to update, correct or delete your information. You are also entitled to obtain from us your information in a structured, commonly used and machine-readable format, and have the right to transmit those data to another data controller. If you wish to exercise any of these rights, contact Pipl through the channels listed below.
You have the right to opt-out of Comeet processing your data for Comeet’s legitimate interests, unless they demonstrate that they have compelling legitimate interests which override your rights and freedoms. To exercise this right, contact them at support@comeet.co.
Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. If you are in the EU, then according to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority, in particular in the Member State of your residence, place of work or place of alleged infringement of the GDPR.
To exercise your right to access, delete, rectification or object to processing as described above you may submit a request to us via the following methods:
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Calling us at (877) 616-1115 (phone requests typically require additional steps and take longer to process);
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Initiate a request for disclosure/deletion using the following link (identity verification required); or
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Email: privacy@pipl.com
Reasonable access to your personal data will be provided at no cost. If access cannot be provided within a reasonable time frame, Pipl will provide you with a date when the information will be provided. If for some reason access is denied, Pipl will provide an explanation as to why access has been denied.
For questions or complaints about the processing of your personal data, you can email Pipl’s privacy team at privacy@pipl.com.
MINORS
Pipl does not accept information from candidates under the age of 16. Any inquiries from parents concerning the use of children’s information on the Platform should be addressed to Pipl directly and should not be made through the Platform.
CHANGES TO THIS PRIVACY NOTICE
From time to time, we may change this Notice. If we do so, we will make efforts to proactively notify you of such changes. In any event, the latest version of the Notice will always be accessible at https://pipl.com/comeet-privacy-policy.
Last Updated: September 13, 2023