Effective date: August 9th, 2024

Prequel, Inc. (referred to as "Prequel", "Company", "us", "our", or "we") is committed to protecting the privacy rights of individuals applying for jobs and positions (referred to as "you") at Prequel, its subsidiaries and its affiliates, and complying with relevant data protection laws. This Applicant and Candidate Privacy Policy (referred to as the "Policy") outlines the purpose and methods of collecting, storing, utilizing, and managing information and data, including personal data, that you provide or we gather during the application and recruitment processes. This Policy also provides guidance on accessing and updating personal information and/or data, as well as making choices regarding the usage of personal information and/or data shared with Prequel.

This Policy covers the information you share with us and/or which may be acquired or produced by Prequel, its subsidiaries and its affiliates during the application or recruitment process including:

• Your name, address, email address, telephone number and other contact information;
• Your resume or CV, cover letter, previous and/or relevant work experience or other experience, education, or other information you provide to us in support of an application and/or the application and recruitment process;
• Information from interviews, if any;
• Details of the type of employment you are or may be looking for, current and/or desired salary and other terms relating to compensation and benefits packages, willingness to relocate, or other job preferences;
• Details of how you heard about the position you are applying for;
• Any sensitive and/or demographic information processed during the application or recruitment process such as gender, information about your citizenship and/or nationality, medical or health information and/or your racial or ethnic origin;
• Reference information and/or information received from background checks (where applicable), including information provided by third parties;
• Information relating to any previous applications you may have made to Prequel and/or any previous employment history with Prequel;
• Your information from publicly available sources, including online, that we believe is relevant to your application or a potential future application (e.g. your LinkedIn profile, referrals, recruitment agencies/ search firms, if any); and/or
• Information related to any assessment you may take as part of the interview screening process.

3.1. Any personal data you provide to Prequel will be used to process your application for the specific position you have applied for. In accordance with applicable law, your personal data may be retained and used to process your application for other open positions within Prequel and its affiliates which may be suitable, unless you object to such processing in which case your personal data will be deleted.

3.2. The processing of your personal data is based on your consent or, in certain cases, the performance of a contract with you (e.g., article 6(1)(a) and 6(1)(b) of the GDPR). We need your personal data in order to conduct the recruitment process, and we will not be able to consider you for a job offer when you do not provide us with your personal data. Any processing of personal data from other sources is based on our legitimate interest (e.g., Article 6(f) of the GDPR).

3.3. Your information will be used by Prequel for the purposes of carrying out its application and recruitment process which includes:

• Assessing your skills, qualifications and interests against our career opportunities;
• Verifying your information and carrying out reference checks and/or conducting background checks (where applicable) if you are offered a job;
• Communications with you about the recruitment process and/or your application(s), including, in appropriate cases, informing you of other potential career opportunities at Prequel;
• Creating and/or submitting reports as required under any local laws and/or regulations, where applicable;
• Where requested by you, assisting you with obtaining an immigration visa or work permit where required;
• Making improvements to Prequel’s application and/or recruitment process including improving diversity in recruitment practices;
• Complying with applicable laws, regulations, legal processes or enforceable governmental requests; and/or
• Proactively conducting research about your educational and professional background and skills and contacting you if we think you would be suitable for a role with us.

3.4. We will also use your information to protect the rights and property of Prequel, our users, applicants, candidates, employees or the public as required or permitted by law.

3.5. If you are offered and accept employment with Prequel, the information collected during the application and recruitment process will become part of your employment record.

3.6. When we retain your personal data for other open positions, we do this based on our legitimate interest and in order to give you the possibility to work with us in the future, even though we are currently unable to offer you a position. We will delete your personal data as soon as it becomes clear that an offer of employment will not be made to you or is not accepted by you unless we believe that you might be suitable for other future open positions and you have not objected to this, or unless we need to retain your personal data for the preparation, filing or defence of legal claims. If we retain your personal data for other open positions, we will store your personal data for this purpose for no longer than necessary to fulfil the purposes for which it is processed.

4.1. Your information may be shared with our affiliates or subsidiaries in the US and in other jurisdictions, in relation to the purposes described above. If you have been referred for a job at Prequel by a current Prequel employee, with your consent, we may inform that employee about the progress of your application and let the Prequel employee know the outcome of the process. In some cases, if it is identified that you have attended the same university/school or shared the same previous employer during the same period as a current Prequel employee we may consult with that employee for feedback on you.

4.2. Prequel may also use service providers acting on Prequel’s behalf to perform some of the services described above including for the purposes of the verification/ background checks. These service providers may be located outside the country in which you live or in the country where the position you have applied for is located.

4.3. Prequel may sometimes be required to disclose your information to external third parties such as to local labour authorities, courts and tribunals, regulatory bodies and/or law enforcement agencies for the purpose of complying with applicable laws and regulations, or in response to legal process.

4.4. We will also share your personal information with other third parties if we have your consent (for example if you have given us permission to contact your referees), or to detect, prevent or otherwise address fraud, security or technical issues, or to protect against harm to the rights, property or safety of Prequel, our users, applicants, candidates, employees or the public or as otherwise required by law.

4.5. It is your responsibility to obtain consent from referees before providing their personal information to Prequel.

4.6. Prequel operates globally, which means your information may be stored and processed outside of the country or region where it was originally collected including in the United States. In some of these countries, you may have fewer rights in respect of your information than you do in your country of residence. Regardless of where your information is processed, we apply the same protections described in this policy. We also comply with certain legal frameworks relating to the transfer of data, such as the European frameworks described below. The European Commission has determined that certain countries outside the European Economic Area (referred to as the “EEA”) adequately protect personal data. You can review current European Commission adequacy decisions on the Commission website. To transfer data from the EEA to other countries, such as the United States, we comply with legal frameworks that establish an equivalent level of protection with EU law.

4.7. Use of Third-Party Service Providers. Prequel may engage third-party service providers, such as recruitment agencies/search firms and providers of recruiting software and applicant tracking system, with whom Prequel contracts as part of its normal business operations to carry out recruitment-related functions. Prequel diligently selects such service providers and enters into written agreements with them ensuring that such providers

(i) have adopted adequate data protection and security measures to safeguard your personal data;
(ii) only use your data as instructed by Prequel and for no other purposes; and
(iii) store your personal data only within the terms of the agreement.

We use the data processing services of the following companies:


4.8. When sharing information with third parties, we ensure that they assume responsibilities no less than what this Policy outlines. We require these third parties to adhere to the information-sharing practices and standards described herein to uphold the same level of privacy protection.

We keep your personal information for no longer than necessary to fulfil the purposes for which it is processed. The length of time for which we retain personal information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws as set out in our records retention policy and/or data handling standard. Generally, this means we retain your personal information to comply with any retention or statutory limitations. For example, if you are offered and accept a job at Prequel, we retain certain information in your personnel file; if you are not offered or do not accept the job for which you have applied, we will delete your data time, unless you authorize us to retain your information for longer with respect to potential future job opportunities.  Where there are technical limitations that prevent deletion or anonymization, we safeguard personal information and limit active use of it.

6.1. Subject to applicable laws, you may have certain rights related to your personal information as described in more detail below. To exercise any of these rights, please contact us at [email protected]:

• You can access the personal information we store about you, including details of why we are processing it. 
• You have a right to correct personal information about you that is inaccurate, incomplete, or outdated.
• In certain situations, you can ask that we erase your personal information, object to or restrict the use of your personal information, or export your personal information to another controller.
• Where we rely on your consent to process your personal information, you have the right to withdraw consent at any time. This will not affect the lawfulness of processing prior to the withdrawal of your consent. At any time, you can request that we stop using your personal information for recruiting purposes. 
• If you are unsatisfied with our response to your complaint, you have a right to raise questions or complaints with your local data protection authority at any time.

6.2. If you make a request to exercise the rights referenced above, we will require you to provide certain information for identity verification purposes. You may authorize an agent to make a request to us on your behalf and we will verify the identity of your agent or authorized legal representative by either seeking confirmation from you or documents that establish the agent’s authorization to act on your behalf.

We have implemented appropriate technical, physical and organizational measures to protect your personal information from misuse or accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure, acquisition, or access as well as all other forms of unlawful processing. For example, our staff is permitted to access job applicant and/or candidate personal information only to the extent necessary to fulfil the applicable business purpose(s) and to perform their job, subject to confidentiality obligations.

Some U.S. state privacy laws, such as the California Consumer Privacy Act (referred to as the “CCPA”), require specific disclosures for state residents.
This Notice is designed to help you understand how Prequel handles your information. In the sections above, we explain:

(1) the types of information Prequel collects and the sources of that information;
(2) how Prequel uses information;
(3) when Prequel may disclose information; and
(4) how Prequel retains information.

Prequel does not sell your personal information. Prequel also does not “share” your personal information as that term is defined in the CCPA.

State laws like the CCPA also provide the right to request information about how Prequel collects, uses, and discloses your information. And they may give you the right to access and correct your information, and to request that Prequel delete that information. Finally, the CCPA provides the right to not be discriminated against for exercising these privacy rights.

If you have questions or concerns related to your rights under CCPA or would like to exercise your rights, you (or your authorized agent) can contact Prequel at [email protected]. We’ll validate your request by verifying your interactions with Prequel, and may require that you provide us with additional information, such as any names, phone numbers or email addresses you have used when communicating with us.

8.1. Types of Information We Collect:

8.1.1. Identifiers and similar information, such as your name, phone number, and address.
8.1.2. Demographic information, such as your age, gender, and language(s) spoken. If you choose, you may also provide additional information, like your racial or ethnic origin, religious or philosophical beliefs, trade union membership, sexual orientation, or gender identity.
8.1.3. Financial information, such as your current and/or desired salary and other terms relating to compensation and benefits packages.
8.1.4. Audio, electronic, visual, and similar information, such as information transmitted in connection with interviews or phone screenings you may have, if any.
8.1.5. Communications data, such as emails that you may send or receive in connection with the application or recruitment process.
8.1.6. Health information, if you choose to provide it, in connection with the application or recruitment process, such as data you may provide in connection with an accommodations request.
8.1.7. Professional, employment, and education information, such as information you provide in connection with the application and recruitment process, as well as information Prequel, may otherwise collect through reference checks, criminal and financial background checks (where applicable) and information from publicly available sources, including online, that may be relevant.
8.1.8. Other information you create or provide, such as the content you create, upload or otherwise provide in connection with the application and recruitment process.

8.2. Purposes for Which Information May Be Used or Disclosed:

8.2.1. Administrative purposes: Prequel uses and may disclose information for purposes related to carrying out its application and recruitment process, including for assessing candidates; verifying information and conducting reference checks and criminal and financial background checks (where applicable); communicating with you; responding to requests for assistance with obtaining an immigration visa or work permit (where required); diversity, equity, inclusion and belonging; and other related activities.
8.2.2. Protecting against security threats, abuse, illegal activity, and violations: Prequel uses and may disclose information to detect, prevent and respond to security incidents, and for protecting against other malicious, deceptive, fraudulent, or illegal activity.
8.2.3. Maintaining our services: Prequel uses the information to ensure our equipment, accounts systems, and services are working as intended, such as tracking outages or troubleshooting bugs and other issues.
8.2.4. Research and development: Prequel uses the information to improve our application and recruitment process, including improving diversity in recruitment practices.
8.2.5. Use of service providers: Prequel shares information with service providers to perform services on our behalf, in compliance with this privacy policy and other appropriate confidentiality and security measures. For example, we may rely on service providers to help perform criminal and financial background checks (where applicable).
8.2.6. Legal reasons: Prequel also uses information to satisfy applicable laws or regulations, and discloses information in response to legal processes or enforceable government requests, including to law enforcement.

8.3. Parties With Whom Information May Be Disclosed:

8.3.1. Other people with whom you choose to share your information, such as the content you create, upload, or otherwise provide in connection with the application and recruitment process.
8.3.2. Third parties with your consent, for example if you have given us permission to contact your references.
8.3.3. Service providers, trusted businesses or persons that process the information on Prequel’s behalf, based on our instructions and in compliance with this privacy policy and any other appropriate confidentiality and security measures.
8.3.4. Law enforcement or other third parties, in response to legal process or enforceable government requests, and as necessary to identify, report on and investigate violations of applicable laws and regulations.

This Policy will not form part of any potential employment contract and we may change it from time to time. We will post any changes to this Policy on this page. Each version of this Policy is identified at the top of the page by its effective date.