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GAN Integrity Recruitment Privacy Notice

Last updated: September 6, 2024

GAN Integrity is committed to respecting your privacy and protecting your personal data. Personal data broadly is information that directly identifies an individual or that reasonably likely makes an individual identifiable when combined with other information. “GAN Integrity”, “us,” or “we” means the legal entity of GAN Integrity which acts as the data controller of your personal data, and this legal entity depends on the office you are applying to as follows:

  • Denmark and the European Union: GAN Integrity Solutions ApS, CVR no. 28279779
  • United Kingdom: GAN Integrity Solutions Ltd, company no. 13319440
  • United States and rest of world: GAN Integrity, Inc., incorporated in Delaware, USA

This Recruitment Privacy Notice (“Privacy Notice”) describes how we handle and protect your personal data in connection with GAN Integrity’s recruiting processes and programs. In case of a conflict between this Privacy Notice and applicable law, applicable law will govern. This Privacy Notice only applies to our processing of potential job candidates’ personal data for recruitment purposes. Personal data may be processed through our online applicant tracking system, email, and/or through alternative recruitment channels such as professional recruiting firms. This Privacy Notice does not apply to the personal data of our employees, partners, clients, vendors or any other person from whom GAN Integrity collects personal data for other purposes.

By submitting your personal data to us, you acknowledge that:

  • You have read and understood this Privacy Notice and agree to the use of your personal data as set out herein.
  • Your personal data may be transferred and processed in our global offices, including in countries (such as the United States) that may not be deemed to provide the same level of data protection as your home country, for the purposes and in the manner specified in this Privacy Notice. We currently operate offices in the United States, United Kingdom and Denmark.
  • You are not required to provide any requested information to us, but your failure to do so may result in our not being able to continue your candidacy for the job for which you have applied.
  • All of your representations are true and correct to the best of your knowledge and belief, and you have not knowingly omitted any related information of an adverse nature. Providing any inaccurate information may make you ineligible for employment.
  • This Privacy Notice does not form part of any contract of employment.

Personal data we collect

The types of personal data that we request from you and the ways that we process it are determined by the requirements of the country in which the role you apply for is located, and not the country in which you reside. Should you apply to more than one location or should the role to which you apply be available in more than one country, the types of personal data we request from you and the ways that we process it are determined by the requirements of all the countries in which the position is located.

We usually collect personal data directly from you when you apply for a role with us, such as:

  • your name;
  • address;
  • contact information;
  • work and educational history;
  • achievements;
  • your performance in code challenges and/or case studies (if you partake in any);
  • any other information you voluntarily provide to us in connection with your candidacy.

If you receive an offer from us, we may also:

  • request and collect identity documents
  • conduct a background and immigration check and
  • to the extent permitted by applicable law, we may also collect data related to criminal offences and proceedings.

We also collect similar personal data about you indirectly from third parties, such as professional recruiting firms, your references, prior employers, GAN Integrity employees with whom you have interviewed or who recommended your candidacy, and, to the extent permitted by applicable law, employment background check providers. We may also collect personal data about you online to the extent that you have chosen to make this information publicly available. For example, we may find your profile on professional and social media websites (such as LinkedIn), and contact you about suitable roles.

Sensitive personal data is a subset of personal data that includes ethnicity, health, trade union membership, philosophical beliefs, sexual orientation, and other categories as prescribed by law. We may collect sensitive personal data about a candidate to the extent permitted to do so by applicable laws (e.g., anti-discrimination and equal opportunity laws) and to support our efforts to create an inclusive and diverse work environment. We may also collect sensitive personal data to the extent that a candidate chooses, without being asked, to voluntarily disclose it during the recruiting process. Under limited circumstances and to the extent permitted by applicable law, we may also collect sensitive personal information relating to health and medical characteristics, such as status of infection, test results, and vaccination status, to address our public health and workplace safety obligations and to protect GAN Integrity and its employees, clients, and third parties.

Use of your personal data

We collect and use your personal data for legitimate human resources and business management reasons, including:

  • identifying and evaluating candidates for potential employment, as well as for future roles that may become available;
  • maintaining records in relation to recruiting and hiring;
  • ensuring compliance with legal requirements, including those relating to public health and workplace safety;
  • fostering our diversity and inclusion programs and practices;
  • conducting background checks, including, to the extent permitted by applicable law, and if you receive an offer from us, criminal history checks;
  • protecting our legal rights to the extent authorized or permitted by law; and
  • protecting the workplace and communicating with medical professionals, law enforcement, or other public authorities in the event of an emergency or public health event, such as when the health or safety of you or one or more individuals may be endangered.

We may also use your personal data for GAN Integrity analytics purposes, including in aggregated/pseudonymized form, to improve our recruitment and hiring process and augment our ability to attract successful candidates.

Legal basis for processing your personal data

Our processing of your personal data for the purposes mentioned above is based:

  • in part, on our legitimate business interests in evaluating your application to manage our relationship with you, to ensure that we recruit appropriate employees, and to evaluate and maintain the efficacy of our recruiting process more generally; and in operating our business and protecting GAN Integrity and its employees, clients, and third parties.
  • in part, on our performing contractual and precontractual measures relating to our potential employment relationship with you;
  • in part, on our complying with applicable law with regard to personal data necessary to satisfy our legal and regulatory obligations, including with regard to public health and workplace safety;
  • in part, on your consent, if we offer you the opportunity to participate in our talent pool program or if we collect sensitive personal data for legally permitted purposes other than compliance with our legal obligations regarding public health and workplace safety.

Data recipients and international data transfers

Your personal data may be accessed by recruiters and interviewers working in the country where the position for which you are applying is based, as well as by recruiters and interviewers working in different countries within GAN Integrity’s global offices. Individuals performing administrative functions such as payroll and IT personnel within GAN Integrity may also have limited access to your personal data to the extent necessary to perform their jobs. In some countries, you may have fewer rights under local law than you do in your country of residence, but we have put in place legal mechanisms designed to ensure adequate data protection for your personal data when it is processed by GAN Integrity subsidiaries and affiliates within the GAN Integrity global organization and by GAN Integrity’s service providers, including the transfer of your personal data to countries other than the one in which you reside.

We use third-party service providers to provide a recruiting software system. We also share your personal data with other third-party service providers that may assist us in identifying and recruiting talent, administering and evaluating pre-employment screening and testing, and improving our recruiting practices.

Except to the extent necessary to accomplish the GAN Integrity uses and purposes described in this Privacy Notice, we do not disclose your personal data to third parties. We also prohibit our service providers from using your personal data for non-GAN Integrity purposes. We do not otherwise share or sell your personal data to third parties. We maintain processes designed to help ensure that any processing of personal data by third-party service providers is consistent with this Privacy Notice and protects the confidentiality, availability, and integrity of your personal data in compliance with applicable law. Where required by law, we put in place additional legal mechanisms designed to help ensure adequate data protection for your personal data when transferred to another country. If you would like more information about these legal mechanisms, which may include the EU’s Standard Contractual Clauses, please contact us at the address provided at the end of this Privacy Notice.

In addition, we may disclose or transfer your personal data in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business.

Data retention

If you accept an offer of employment with us, any relevant personal data collected during your pre-employment period will become part of your personnel records and will generally be retained for the duration of your employment, in accordance with specific country requirements and with the privacy notice applicable to GAN Integrity employees.

If we do not employ you, your data will be retained for up to six months unless otherwise required by applicable law. You may also be invited to our talent pool program so you can be considered for potential future roles. In that case, the personal data we obtained from your recruitment process will be retained for as long as you remain a member of the talent pool. You can withdraw from the talent pool at any time by contacting us using the details at the bottom of this Privacy Notice.

To the extent that we have collected personal data, including sensitive personal data, for the specific purpose of fulfilling our legal obligations regarding public health or workplace safety, we will retain that data for the duration of those legal obligations. Thereafter, we retain a minimal amount of your personal data to establish our compliance with those obligations.

We may want to remain in contact with you and consider you for future employment opportunities. In such an event, we will seek your consent to include you in one of our recruiting or job agent programs that provides you ways to further learn about and stay in touch with GAN Integrity, either prior to or after you formally apply for a job opportunity.

Participation in these programs is entirely optional.

Security

We use generally accepted standards of technical and operational security to secure your personal data. Only authorized personnel of GAN Integrity and of our third-party service providers are permitted to access personal data, and these employees and third-party service providers are required to treat this information as confidential. Despite these precautions, we cannot guarantee that unauthorized persons will not obtain access to your personal data.

Your rights

We take reasonable steps that are designed to keep your personal data accurate, complete, and up-to-date for the purposes for which it is collected and used. We also have implemented measures that are designed to help ensure that our processing of your personal data complies with this Privacy Notice and applicable law.

In accordance with applicable law, you may have one or more of the following rights:

  • a right to request information about the personal data we hold about you, including the details of how we use that information and who we share it with;
  • a right to request a copy of the personal data that we hold about you;
  • a right to amend or rectify your personal data if any of the information held about you is incorrect or out of date;
  • a right to portability of your personal data;
  • a right to request erasure of your personal data;
  • a right to demand that we cease the processing of your personal data or that we restrict the processing of your personal data;
  • a right to withdraw your consent to the processing of your personal data, to the extent our processing relies on your consent as the lawful basis for processing. This right may not apply if there are other legal justifications to continue processing or we need to retain certain personal data where required or permitted under applicable law; and/or
  • a right to provide us with instructions as to the processing of your personal data in case of death.

In addition, and where granted by applicable law, you may have the right to lodge a complaint with a competent data protection authority.

If you would like to make a request to access, review, correct, delete or port the personal data we have collected about you, to assert a right with regard to your personal data, or to discuss how we process your personal data, please contact us using the contact details at the bottom of this notice.

To help protect your privacy and security, we will take reasonable steps to verify your identity before granting you access to your personal data. We will make reasonable attempts to promptly investigate, comply with, or otherwise respond to your requests as may be required by applicable law. Depending upon the circumstances and the request, we may not be permitted to provide access to personal data or otherwise fully comply with your request; for example, producing your information may reveal the identity of someone else. We reserve the right to charge an appropriate fee for complying with your request where allowed by applicable law, and/or to deny your requests where, in GAN Integrity’s discretion, they may be unfounded, excessive, or otherwise unacceptable under applicable law.

CONTACTS

If you have any questions about this Privacy Notice please contact our People department at hr@ganintegrity.com. You can also contact our Data Protection Officer at dpo@ganintegrity.com.

GAN Integrity reserves the right to modify this Privacy Notice. We will post any changes to our Privacy Notice on this page. Please check this page regularly to keep up-to-date.