Job Applicant Privacy Notice

As part of any recruitment process, ContentFly Inc., doing business as Moonvalley AI, and its affiliated groups (“the Company,” “we,” or “us”), 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).

We use an online application system to assist with the Company’s recruitment process. This system processes personal information as a data processor on our behalf. If you apply for a job via a job site or similar online service provider (“Partner”), note that the Partner may retain your personal data and collect information from us regarding the progress of your application. Any use by the Partner of your data will be governed by the Partner’s Privacy Notice.

When you apply for a job directly with us, this Privacy Notice governs our processing of your personal information alongside any other relevant Privacy Notices.

Your Personal Information

Information We collect from You

We collect and process some or all of the following types of information from you:

Information that you provide when you apply for a role. This includes information provided through an online job site, 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.
Whether or not you have a disability for which the Company needs to make reasonable adjustments 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 Partner provides us with the facility to link the data you 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 your personal data from a third party who recommends you as a candidate for a specific job opening or for our business more generally.

Uses Made of Your Information

Lawful basis for processing

We rely on legitimate interest as the lawful basis on which we collect and use your personal data. The Company’s legitimate interest is the recruitment of staff for our business. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate's suitability for employment, and decide whom to offer a job. We may also need to process data from job applicants to respond to and defend against legal claims.

Purposes of processing

We use information held about you in the following ways:

To consider your application in respect of a role for which you have applied.
To consider your application in respect of other roles.
To communicate with you in respect of the recruitment process.
To enhance any information that we receive from you with information obtained from third-party data providers.
To find appropriate candidates to fill the Company’s job openings.
The Company may process special categories of data, such as information about ethnic origin, sexual orientation, or religion or belief, to monitor recruitment statistics. We may also collect information about whether or not applicants are disabled to make reasonable adjustments for candidates who require accommodation. We process such information to carry out our obligations and exercise specific rights in relation to employment.
To help our service providers (processors and data providers) and Partners (such as the job sites through which you may have applied) improve their services.

Automated decision making/profiling

We may use our Partner’s technology 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. Any decision as to whom we will engage to fill the job opening will be made by our staff.

Disclosure of Your Information

As set out above, we pass your information to our third-party service providers, who use it only in accordance with our instructions and as otherwise required by law.
Where you have applied to a job opening through another service provider, the service provider shall be the data controller of this data and shall therefore be responsible for complying with all applicable law in respect of the use of that data following its transfer by us.

How We store your Personal Data

Security

We take the security of your data seriously. We have 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. Employees are subject to a duty of confidentiality.

Your information may be shared internally for the purposes of the recruitment exercise. 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 will not share your data with third parties unless your application for employment is successful and we make you an offer of employment. At that stage, we may share your data with former employers to obtain references and with background check providers.

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 Personal Data

The data that we collect from you and process using our Partners’ Services may be transferred to, and stored at, a destination outside the UK, European Economic Area (EEA), Canada, or the US. It may also be processed by staff operating in these or other countries who work for us or one of our suppliers. Such staff may be engaged in the fulfillment of your application, the processing of your payment details, or the provision of support services. By submitting your personal data, you agree to this transfer, storing, or processing.

Your data may be accessible to:

Third-party Partner staff in the US.
Service providers hosting data on servers in the US or other jurisdictions.

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

How long We keep your Personal Data

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. If you agree, we may hold your data on file for an additional 6 months for future employment opportunities. At the end of that period, or once you withdraw your consent, your data is deleted or destroyed.

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.

Your rights

As a data subject, you have several rights. You can:

Access and obtain a copy of your data on request.
Require us to change incorrect or incomplete data.
Require us to delete or stop processing your data where it is no longer necessary.
Object to the processing of your data where we rely on legitimate interests as the legal basis for processing.

If you would like to exercise any of these rights, please contact us using the details below.

If you believe that the Company has 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.
US: Applicable state privacy authority.

United States (US)

State-Specific Privacy Rights

Residents of certain states have specific rights under applicable laws:

California (CCPA/CPRA): You 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.
Not be discriminated against for exercising your privacy rights.

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

To exercise your rights, contact us using the information in our Contact section.

Canada

Consent and Withdrawal

You may withdraw your consent for the collection, use, or disclosure of your personal information at any time by contacting us. Withdrawing consent may affect our ability to consider you for a position.

Cross-Border Transfers

Your personal information may be transferred outside of Canada for processing. In such cases, we ensure the same level of protection under Canadian privacy laws.

United Kingdom (UK)

Legal Basis for Processing

Under UK GDPR, we rely on:

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

Data Protection Officer (DPO)

For questions related to UK GDPR compliance, contact our DPO at dpo@moonvalley.ai

Retention Periods

Unsuccessful applicants: Retained for 12 months, extendable to 18 months with consent.
Successful applicants: Data transferred to HR files and retained for the duration of employment.

What if you do not provide Personal Data?

You are under no statutory or contractual obligation to provide data to the Company 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.

Contact

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

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