FREIGHTOS CANDIDATE PRIVACY POLICY

Job applicant privacy is something we take very, very seriously.

Last update: November 2020

This Privacy Policy is for Job Applicants (“Privacy Policy”) is between Freightos Limited of 2nd Floor, 625 King’s Road, North Point, Hong Kong, its subsidiaries and affiliates (“Freightos”), and you (“The Candidate”).

Freightos is the company recruiting for the job vacancy you have applied for. The controller of your personal information is the Freightos entity with whom you are applying for a vacancy.

If you have applied for a position in the EU and submit your personal information to Freightos, the controller of your personal information for the purposes of the General Data Protection Regulation (“GDPR”)  data is Web Cargo, S.L.U, Av. Diagonal 211, 10th floor, 08018 Barcelona, Spain.

We respect your privacy and are committed to protect the personal information that you share with us. When you apply for a job with us, or any of our affiliates or subsidiaries, we need your personal information to consider whether you are a good fit for relevant positions and to further contact you if the recruitment process continues. This Privacy Policy describes how we collect and use your personal information when you apply for a job opening at Freightos.

Freightos operates in different countries, some of which have laws related to the collection, use, transfer and disclosure of the personal information, or any information allowed by applicable law, of individuals, including our employees. We take these obligations very seriously and are giving you this Privacy Policy to provide transparency about what we do with personal information and why. Each affiliated company and/or subsidiary shall operate in accordance with local privacy legislation.

Information We Collect

Personal information means any information that (alone or in combination with other information) can be used, directly or indirectly, to identify an individual, including, but not limited to, a first and last name, email address, a home, postal or other physical address, other contact information, title, birth date, gender, occupation, industry, personal interests, CV and other information you provide as part of a job application. In addition to the preliminary information you send us as part of the application, we may collect more information about you in personal interviews or through further communications to the extent applicable. We will only request information from you which is reasonably necessary for the identification and evaluation of potential candidates for open positions.

Information We Receive from Third Parties

Instead of directly submitting your job application or personal information to us, we also provide you with the ability to send such information using tools offered by third parties such as LinkedIn (when you decide to provide your CV by linking to your profile), through our ATS (Application Tracking System) when you submit your application on our career website, or any other job portal or referral program. We may also receive information from third parties, such as your family members, previous employers, friends or placement companies, who may send us your personal information on your behalf, or from other third parties who process your personal information on our behalf. Any information we receive from such third parties in the context of your job application is subject to this Privacy Policy and we will be the controller with respect to such information as allowed by applicable law (however without derogating from their liability for the information that they hold). In this case, you may receive an email with the Privacy Policy attached.

However, please note that by using such third party tools you may be required to review and consent to the privacy statements of such third parties and their use of your information will be subject to such privacy statements and Freightos will have no liability for any privacy breaches of third parties as listed above.

Legal Basis for Processing your personal information

If you are an individual in the EU or your data is treated under GDPR regulations, our legal basis for our collecting and processing of your personal information is as follows:

  • Your unequivocal consent, which you can withdraw at any time. Please note that if you withdraw your consent we may not be able to process your application;
  • The necessity for hiring decisions, i.e. to take steps to assess your suitability for the vacancy prior to entering into an employment contract;
  • The necessity for the compliance by Freightos with applicable laws, regulations and its legal obligations under EU or EU Member state or other applicable law in relation to employment and social security; and
  • The necessity for the purposes of the legitimate interests pursued by Freightos, in particular its economic, commercial and financial interests, business continuity, security and confidentiality of customer information and products, security of digital and physical infrastructure.

 

How Freightos uses your personal information

Freightos will use your personal information for the following purposes:

  • Recruitment, selection, evaluation and appointment of job candidates (temporary or permanent) for the job you have applied for and for subsequent job opportunities.
  • General HR administration and management (in case you become a Freightos employee).
  • Carrying out satisfaction surveys (for example, to manage and improve the recruitment process).
  • Application analysis such as verification of your employment reference(s) that you have provided, background checks and related assessments.
  • Compliance with corporate governance and legal requirements (for example, to monitor diversity requirements) − communicate with you and to inform you of current status of your application and future opportunities (unless you have told us that you do not want us to keep your information for such purposes).

You understand, however, that our collection, use and/or processing of your personal information does not in any event constitute an offer of employment or a guarantee of successful selection for any positions made available with Freightos or any of its sister companies, group companies, subsidiaries, affiliates or partners.

Information Sharing and Disclosure

Because Freightos is a global company, your personal information may be shared with our other subsidiaries or affiliates around the world, such as:

  • Webcargo SL
  • Freightos India Private limited
  • Freightos information Technology (Shanghai) Co. Ltd. Freightos Inc.
  • Freightos Ltd.
  • Freightos Software Development and Data Services Ltd.

All such entities are governed by this Privacy Policy or are bound by the appropriate confidentiality and data transfer agreements as allowed by applicable law.

We may send your personal information to other companies or people under any of the following circumstances:

  • We need to send the information to companies who work on our behalf to provide services directly related to the job application process, such as external assessment institutions located in your jurisdiction, recruiting system providers located in the US (such as Comeet, our Application tracking System), IT service providers, providing hosting service (such as AWS and Google Cloud). We will only provide those companies the information they need to assist us in the job application process, and they are prohibited from using that information for any other purpose;
  • In the event of sale or transfer of all or substantially all of our or any of our affiliate’s shares or assets, in cases of mergers or in case of negotiations with respect to the foregoing;
  • If required to do so by law, or in urgent circumstances, to protect personal safety, the public or our website.

Freightos may also disclose your personal information to regulatory authorities (including tax authorities), government agencies, law enforcement authorities, parties (including our legal or other advisors) in legal proceedings involving Freightos, third parties with whom we may collaborate or engage in acquisition transactions, or where otherwise required by applicable law. Freightos may also share anonymous or aggregate information with third parties.

Other than as described above, any other transfer of your personal information to third parties will be subject to your consent.

 

For the above purposes, personal information may be transferred to recipients in countries around the world (which may be located outside the EU/EEA, European Economic Area) which in some cases may have a lower level of protection than that within the EU/EEA. If you are a resident of the EU/EEA, when transferring personal information to countries outside the EU/EEA, to jurisdictions that did not receive an adequacy decision by the European Commission, we use standard contractual clauses approved by the European Commission to ensure a sufficient level of protection for your personal information. If you are not a resident of the EU/EEA, we may transfer your information to such non EU/EEA countries without any additional measures and you agree to such transfers based on this Policy.

Data Retention

We will keep your personal information for as long as necessary in connection with the purposes described in this Privacy Policy and in accordance with applicable law. If you want to learn more please reach out to [email protected]

We hereby inform you that for candidates treated under GDPR regulations,  unless you request otherwise, exercise your right to erasure or join our team,  data will be kept for a maximum term of three years for any possible future recruitment processes. Once such a term has ended, your data will be deleted or, alternatively pseudonymised.

Data Subject Rights

Under applicable EU regulation, and some other countries, you may have some or all of the following rights in respect of your personal information:

  • To obtain a copy of your personal information together with information about how and on what basis that personal information is processed;
  • To rectify inaccurate personal information;
  • Where you have provided your personal information to us with your consent, to ask us for a copy of this data in a structured, machine-readable format and to ask us to share (port) this data to another data controller;
  • To erase your personal information in limited circumstances where (a) you believe that it is no longer necessary for us to hold your personal information; (b) we are processing your personal information on the basis of legitimate interests and you object to such processing, and we cannot demonstrate an overriding legitimate ground for the processing; (c) where you have provided your personal information to us with your consent and you wish to withdraw your consent and there is no other ground under which we can process your personal information; and (d) where you believe the personal information we hold about you is being unlawfully processed by us;
  • To restrict processing of your personal information where: (a) the accuracy of the personal information is contested; (b) the processing is unlawful but you object to the erasure of the personal information; (c) we no longer require the personal information for the purposes for which it was collected, but it is required for the establishment, exercise or defense of a legal claim; or (d) where you have objected to us processing your personal information based on our legitimate interests and we are considering your objection;
  • To challenge processing which we have justified on the basis of our legitimate interest;
  • To object to decisions which are based solely on automated processing or profiling.

In addition to the above, you have the right to lodge a complaint with a supervisory authority for data protection.

We will ask you for additional data to confirm your identity and for security purposes, before disclosing data requested to you. We reserve the right to charge a fee where permitted by law. We will decline to process requests that jeopardize the privacy of others, are extremely impractical, or would cause us to take any action that is not permissible under applicable laws. Additionally, as permitted by applicable laws, we will retain where necessary certain personal information for a limited period of time (according to the data retention term) for record-keeping, accounting and fraud prevention purposes.

Right to Object

You can object to any processing of your personal data which has legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms. Requests to exercise your rights shall be addressed to [email protected]

Data Security

We safeguard the security of the data you send us with physical, electronic, and managerial procedures, taking into consideration the state of the art technology, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of processing your personal information. While we strive to protect your personal information, we cannot ensure the security of the information you transmit to us, and so we urge you to take every precaution to protect your personal information when you are on the Internet.

Changes to this Privacy Policy

We may amend this Privacy Policy from time to time. If we make any substantial changes in the way we use your personal information we will make that information available by posting a notice on this site, so please re-visit this site frequently to see any updates or changes to this Privacy Policy.

Privacy Inquiries

We are responsible for the processing of your personal information, and requests to exercise your rights as stated above shall be addressed to [email protected]

To Contact our data protection officer, please use the following contact details: [email protected]