Candidate Privacy Policy

Objective

The policy explains what we do with Personal Information we collect during and after the recruitment process through the Careers portal on the Vitrana websites (“Site”) or by any other means.

Scope

The policy applies to individuals who apply for employment (whether fulltime or on contract basis), internship or
assignment with Vitrana, including those individuals who attend a Vitrana recruitment event.

Definition

“Associate” means any current, past and prospective employees, individual contractors or other members of personnel of Vitrana.
“Vitrana” means
1. Vitrana Inc. with a registered address at 2650 US Highway 130, Ste I, Cranbury, NJ, 08512
2. Virtuous Transactional Analytics Pvt. Ltd. with a registered address at Graphix 2, Block A – 13, Industrial Area, Sector 62, Noida, Uttar Pradesh – 201309, India
3. And its global affiliates and subsidiaries
“Personal Information” is defined under applicable law but may include any information or combination of information, in any form or medium that can identify an External Individual. Examples include name, email address, physical address, phone number, date of birth, age, home address, personal preferences, behavioral information, government issued IDs, IP address, hardware identifiers, etc.
“Sensitive Personal Information” means Personal Information, which if lost, compromised, or disclosed
without authorization, could result in substantial harm, embarrassment, inconvenience, or unfairness to an individual. Examples of Sensitive Personal Information in various jurisdictions may include social security numbers, driver’s license numbers, passwords, passports, tax IDs, financial account and credit card numbers, health information (including Protected Health Information (PHI), biometric identifiers, racial or ethnic origin, and information about political opinions, religious beliefs, trade union membership, criminal history, sexual orientation or blood group , as well as any other information deemed sensitive under applicable data protection laws.
“Process/Processed/Processing” means any operation or set of operations which is performed on Personal Information or on sets of Personal Information, whether or not by automated means, such as collecting, recording, storing, deleting, viewing, accessing, amending, using or disclosing the Personal Information.
Note, where we have used words such as “include,” “including,” “for example,” or “such as” in this Notice, these are meant to be examples and not exhaustive lists

How we collect and use your personal information

We may collect following general types of information about you.

Personal Information – During the recruitment process, we collect information from you in connection with your application. Information we collect includes

Name, address, telephone number, email address and other contact information
Information you submit in resumes/CV’s/letters, including but not limited to employment history, academic qualifications, professional qualifications and skills;
Whether or not you were previously employed by Vitrana, including employee ID
Other relevant information, such as employment preferences, willingness to relocate, current salary, desired salary,
Awards or professional memberships, professional and other work-related licenses, permits and certifications;
Information generated by interviewers and recruiters, based on their interactions with you, e.g., via a recruitment
or Campus hiring event, or basic Internet searches;
Information provided by third-party recruiters, staffing companies or executive search agencies, where applicable;
Recommendations provided on your behalf by others;
Documentation required under immigration laws;
Personal Information submitted or generated as a result of psychological, technical or behavioral assessments
Undertaken (including the involvement of remote video proctoring); you will receive more information about the
Nature of such assessments before your participation in any of them;
Personal Information submitted or generated as a result live video interview s; you will receive more information
About the nature of such interview s before your participation in them.
Your Public LinkedIn profile, if you choose to import your profile to get personalized job recommendations;
Username and password (if available on the Site)

Should you be successful for a role, we would then ask you to provide information about third parties, such as references or contacts that you provide to us. You are responsible for ensuring that you have permission to submit any such information and that such individuals are aw are that their information will be available to Vitrana or its clients for the purposes of taking up references.

Sensitive Personal Information

We do not require you to provide any Sensitive Personal Information during the recruitment process. Nonetheless, should you be successful for a role, we where permitted by applicable law – may then ask you to provide some Sensitive Personal Information and/or identification numbers to enable us to comply with legal requirements at a national level (e.g., in relation to equal opportunities legislation). In addition, you may also be subject to a background check, where justified by the particular role you are applying to and subject to the applicable laws of the country you are located in. The content of background check information varies by country to comply with local requirements, but may include information gathered from publicly available sources, your former employers or colleagues, schools you have attended, credit reporting agencies, and criminal records databases. You will receive more information about the nature of such a background check before it begins. Otherwise, we ask that you avoid submitting information which may qualify as sensitive information under applicable law, except w here such information is legally required.

Aggregated Information

This is information that is aggregated and therefore not uniquely personal to you, but which refers to selected population or geographic characteristics, age, gender, occupation, preferences, and interests in accordance with applicable laws.

Behavioral Information

We use “cookies” and similar technologies on the Site. Any information you submit must be true, complete and not misleading. Submitting inaccurate, incomplete or misleading information may make you ineligible for employment. We may collect information about you directly from you or from other sources (w here permissible and in accordance with applicable law):

From you directly or from your use of the Site
From referrers, referees and former employers
From conversations with recruiters and other Vitrana associates or representatives, as well as from internet searches that these individuals may perform, or data that they may obtain from job search or professional networking websites (e.g., LinkedIn, etc.) where you may have made data about yourself publicly available
From third party recruiters, staffing companies or executive search agencies that are contracted by Vitrana;
From background checks, as applicable. Where permitted by law, we may contract with a third party to perform a pre-employment background screening. You will receive more information about the nature of such a background check before it begins

Why we need to collect your personal information

We will process your Personal Information (including, without limitation and where permitted, your Sensitive Personal Information) for our recruitment, management and planning purposes, including:

Assessing your suitability for the role for which you are applying as w ell as future roles that may come available;
Management and administration of your application;
Facilitate communication, responding to your queries;
Verifying eligibility to work;
Perform data analytics, including of our candidate pool, to improve our recruitment process and the Site;
Notifying you about opportunities (if you signed up);
To comply with or monitor compliance with applicable law:

Who will have access to your personal information

In general, access to your Personal Information will be restricted to the relevant people in Vitrana who need it for the purposes set out in this policy (e.g., your potential future managers and direct colleagues, recruitment, HR and IT). We will not sell your Personal Information, but may disclose your Personal Information, as required and in accordance with applicable laws.

International Transfers of your Personal Information

As further detailed above under the section ‘Who will have access to your Personal Information’, due to the global nature of Vitrana’s business, Personal Information may be shared, disclosed and transferred between the various Vitrana Affiliates and third parties where such transfers are required for legitimate business reasons. Such companies may be located outside your country of residence. The level of protection for Personal Information is not the same in all countries. However, we will take reasonable steps and implement measures as described in this policy to keep your Personal Information secure. In addition, we will ensure that any international transfers of your Personal Information will take place in accordance with the requirements of applicable law.

How long we retain your Personal Information

We will retain Personal Information for the period necessary to fulfil the purposes outlined in this policy, unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods are
(i) the duration of the application process,
(ii) as long as we have an ongoing relationship with you,
(iii) as required by a legal obligation to which we are subject; and
(iv) as advisable in light of our legal position (such as in relation to statutes of limitations, litigation or regulatory investigations).

How we protect your Personal Information

Vitrana implements appropriate security measures designed to prevent unlawful or unauthorized Processing of Personal Information and accidental loss of or damage to Personal Information. Vitrana maintains written information security policies and procedures designed to prevent, detect, contain, and correct violations of measures taken to protect the confidentiality, integrity, availability, or security of your Personal Information. Where we contract with third parties to provide services that may enable them to access your Personal Information, we require them by contract to have similar security controls in place.

What are your rights

To the extent these rights are provided to you by applicable law, you may:

Request access to your Personal Information or to correct, update or request deletion of your Personal Information. You can do so by contacting us at the details provided in “Contact Us” section.
Object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information. Again, you can exercise these rights by contacting us
If we have collected and process your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the law fulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Complying with all or part of your request may be denied or limited by Vitrana if it would violate another person’s rights and/or as otherwise permitted by applicable law. Before responding to a request, we reserve the right to verify and authenticate your identity and the information that your request relates to. If an archival copy of your Personal Information is required to be retained by applicable law after receiving a request for deletion or closure of your account, we will follow the statutory term for such a retention.

Changes

We may occasionally update this Privacy Statement. If the changes we make are material, we also may post a notice regarding the changes on our websites. We encourage you to periodically review this Privacy Statement to stay informed about how we are helping to protect the PII we collect. Your continued use of our websites constitutes your agreement to the Privacy Statement and any updates. Subsequent changes in this Privacy Statement will not apply to data that were collected before the change is made.

Contact us

References to “Vitrana,” “we,” “us” and “our” are references to Vitrana Inc. and its affiliates. Please address any questions, comments and requests regarding this Privacy Statement to your local Vitrana affiliate using the contact information below. If you contact us, please note the name of the websites you have visited, as well as how we may contact you. Email: contact@Vitrana.com