Job Applicant Privacy Notice

Updated: 11/26/2024

As part of any recruitment process, ContentFly Inc., doing business as Moonvalley AI, and its affiliated groups (“the Company,” “we,” “us”, or “our”), collect, store, and process personal data relating to job applicants. We are committed to being transparent about how we collect and use that data and to meeting our data protection obligations under applicable privacy laws in the United Kingdom (UK), Canada, and the United States (US).

When This Notice Applies

When you apply for a job with us, either directly using our online application system or through a job site or similar online application partner, this Privacy Notice governs how we process your personal information. By applying for a job with us or otherwise providing us with your personal information, you consent to the collection, use and disclosure of your personal information as set out in this Privacy Notice.

However, please note that if you do use a third-party job site or similar online application partner to apply for a position with us, we are not responsible for how these third parties handle your personal information, and any handling of your information by these partners will be governed by their respective privacy policies. We encourage you to review the privacy policies of any third-party websites you use to apply for positions with us prior to submitting an application through them.

How We Collect and Use Your Personal Information

We collect and process some or all of the following types of information to manage the recruitment process, assess and confirm suitability for employment, and decide whom to offer a job.

More specifically, we use information held about you for the following purposes:

To consider your application in respect of a role for which you have applied.
To consider your application in respect of other roles to fill the Company’s job openings.
To communicate with you in respect of the recruitment process.
To monitor recruitment statistics.
To carry out our obligations and exercise specific rights in relation to employment.

To respond to and defend against legal claims.

Information We Collect From You

We collect the following types of personal information directly from you:

Information that you provide when you apply for a role. This includes information provided through an online job site or other third-party application partner, via email, in person at interviews, and/or by any other method.

In particular, we process personal details such as name, email address, address, telephone number, qualifications, experience, information relating to your employment history, and skills you provide to us. If you conduct your interview using the Video Interview feature, this includes video recordings.

Where such information is volunteered directly by the candidate, we may collect special categories of data, such as information about ethnic origin, sexual orientation, or religion or belief. This information is only used to monitor recruitment statistics, and candidates are never required to provide it.
Information regarding whether or not you have a disability for which the Company needs to make reasonable adjustments or provide accommodations during the recruitment process.
If you contact us, we may keep a record of that correspondence.
A record of your progress through any hiring process that we may conduct.

Information We Collect from Other Sources

Our online application partners provide us with the facility to link any information you or they provide to us with other publicly available information about you that you have published on the Internet, including sources such as LinkedIn and other social media profiles.
We may receive information about you from a third party who recommends you as a candidate for a specific job opening or for our business more generally.
We may also collect information about you from the employment references that you provide to us.

Automated decision-making/profiling

We may use technology provided by our partners and service providers to select appropriate candidates for us to consider based on criteria expressly identified by us or typical in relation to the role for which you have applied. However, we do not rely on fully automated tools to make hiring decisions; any final decision as to whom we will engage to fill the job opening will be made by our staff.

How We Share Your Information

Service providers. We use third-party service providers to help us manage and administer the recruitment process. These service providers process your information only on our behalf to provide us with services. This includes the service provider that hosts our online application system.

When we share your information to our third-party service providers, we ensure that they only use it in accordance with our instructions or as otherwise required by law.

Third-party application partners. If you apply for a job with us via a job site or similar online application partner, we may share limited personal information with them regarding the progress of your application. As set out above, we are not responsible for how these third parties handle such information after we share it with them.

Employment references and background checks. We will not share your data with any other third parties unless your application for employment is successful and we make you an offer of employment. At that stage, we may share your personal information with (a) former employers to obtain references and (b) with additional service providers, such as background check providers.

Our Privacy Practices

Security

We take the security of your data seriously. We have internal policies and administrative, technical, and physical 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. Employees are subject to a duty of confidentiality.

Your information will only be accessed by staff members that strictly require access for the purposes of recruitment. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy, and IT staff if access to the data is necessary for their role.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Where We Store Your Information

Your personal information may be transferred to, and stored at, a destination outside the UK, European Economic Area (EEA), Canada (including outside of your province), or the US. It may also be processed by our staff operating in these or other countries who work for us or by our suppliers, third-party service providers, and Partners for the purposes of fulfilling your application, processing of your payment details, or providing support services. We use appropriate safeguards to ensure that your personal information is protected no matter where it is used or stored.

When your personal information is transferred to a jurisdiction outside of your region, it may be subject to the law of that foreign jurisdiction, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction.

If you would like further information, please contact us (see ‘Contact’ below).

How Long We Keep Your Information

We only retain your information for as long as necessary to fulfill the purposes for which we collected it.

More specifically, if your application for employment is unsuccessful, the Company will hold your data on file for 12 months after the end of the relevant recruitment process. We may hold your data on file for an additional 6 months for future employment opportunities, unless you ask us not to do so. At the end of that period, or once you withdraw your consent, your data is deleted or destroyed. Please see ‘Your Privacy Rights and Choices’ below for more information on withdrawing consent.

If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your Human Resources file and retained during your employment in accordance with applicable law.

Your Privacy Rights and Choices

Accessing and Correcting Your Personal Information

If you believe that the personal information we maintain about you is not accurate or up-to-date, you can make a request to correct it by writing to us using the contact information set out below under ‘Contact Us.’ You may also request access to and request to obtain a copy of the personal information that we maintain about you by writing to us.

We may need to verify your identity or obtain more information before responding to your request. In some cases, our legal obligations will prevent us from granting a request for access to or correction or personal information. We will inform you in writing of the reasons for any such decision.

Withdrawing Your Consent

You are under no legal obligation to provide us with your personal information during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.

If you wish to withdraw your consent to the Company maintaining your information for longer than 12 months in the event of an unsuccessful application, please contact us in writing using the contact information set out below under ‘Contact Us.’

Depending on where you live, you may withdraw your consent for the collection, use, or disclosure of your personal information at any time by contacting us directly. However, withdrawing consent will affect our ability to process your application or consider you for a position.

Additional Information for Specific Regions

Depending on where you live, you may be able to exercise additional privacy rights, as set out below. To exercise these rights, contact us using the information set out below under ‘Contact Us.’

United States (US)

US residents of certain states have specific additional rights under applicable laws.

California residents have the right to:

Know what personal data we collect, use, share, or sell.
Request the deletion of your personal information.
Opt-out of the sale or sharing of personal data.

Similar rights may apply under state laws in Colorado, Virginia, Connecticut, and Utah.

European Economic Area (EEA) and United Kingdom (UK)

Under the GDPR and UK GDPR, we rely on the following legal bases for processing:

Legitimate Interests: Recruitment and candidate evaluation.
Consent: For processing special category data such as diversity monitoring.
Contractual Necessity: For pre-employment checks and onboarding.

If you are located in the UK or EEA, you have additional rights under the General Data Protection Regulation (GDPR) or UK GDPR:

Deletion and restriction: You may request deletion of, or restrictions on the processing of, your personal information where it is no longer necessary, subject to certain exceptions.
Objection: You may object to the processing of your data where we rely on legitimate interests as the legal basis for processing.
Data portability: You may request a copy of your personal information in a structured, commonly used, and machine-readable format.
Data Protection Officer: While we may not be required to appoint a Data Protection Officer, you can contact us with any data protection inquiries at privacy@moonvalley.com or dpo@moonvalley.com.
Complaints: You have the right to lodge a complaint with your local data protection authority if you believe we have violated applicable data protection laws.

Quebec

If you are located in Quebec, you may exercise the following additional rights:

Deletion and restriction: Request deletion of, or restrictions on the processing of, your personal information where it is no longer necessary, subject to certain exceptions.
Data portability: You may request a copy of your personal information in a structured, commonly used, and machine-readable format.

Updates to this Notice

We may update this Privacy Notice from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any significant changes by updating the date at the top of this Privacy Policy and, if required, through additional notifications (e.g., via email).

Contact Us

All questions, comments and requests regarding this Privacy Notice should be addressed to privacy@moonvalley.ai.

Please reach out to us directly if you have any concerns regarding our handling of your information and we will do our best to resolve them. However, if you believe that that we have not complied with your data protection rights, you can complain to the relevant regulatory authority:

UK: Information Commissioner’s Office (ICO).
Canada: Office of the Privacy Commissioner of Canada or equivalent provincial regulators in Alberta, Quebec, or British Columbia (as applicable).
US: Applicable state privacy authority.

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