Effective Date: May 10, 2021
Last Updated: Feb 1, 2024
1.1. Terminal, Inc (“Terminal”, “we”, “us”, “our”), of 1 Letterman Dr, Building C3500, San Fransisco, California, 94129, is committed to protecting your privacy and meeting our legal obligations when you apply for a job or you (or an agent acting on your behalf) share your employment details with us.
1.2. This privacy notice explains what personal data we collect and use relating to employment and the associated candidates (“you”, “your”) during the recruitment process.
1.3. Although a US-based company, we provide products and services to several countries, therefore we are committed to ensuring we meet our legal obligations when processing your personal data under the data protection laws of these countries, which include the UK General Data Protection Regulation and the EU General Data Protection Regulation 2016/679 (together the “GDPR”), the UK Data Protection Act 2018 (“DPA 2018”), the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”); the Canadian Personal Information Protection and Electronic Documents Act (“PIPEDA”); the Mexico Federal Data Protection Law; the Colombia Data Protection Law 1581m; the Chilean Personal Data Protection Law No 19.628 and the Costa Rican Law on the Protection of Persons Regarding the Processing of their Personal Data No. 8968 of 2011, collectively referred to in this Policy as the “Data Protection Law”.
1.4. As an information-led business, we place great importance on ensuring the quality, confidentiality, integrity, and availability of the data we hold, and in meeting our data protection obligations where we process personal data. We are committed to protecting the security of your personal data. We use a variety of technical and organisational measures to help protect your personal data from unauthorised access, use or disclosure.
1.5. We update this privacy notice from time to time in response to changes in applicable laws and regulations, to our processing practices and to products and services we offer. When changes are made, we will update the effective date at the bottom of this document.
2.1. Terminal, Inc is the Controller of the personal data we hold about you. Personal data means any information about an individual from which that person can be identified, therefore does not include data where the identity of the person has been removed (anonymous data). There are “special categories” of more sensitive personal data which require a higher level of protection.
2.2. When you apply for a position or submit your Resume (or similar employment information) to us, whether directly or through an agency, or attend an interview in person or by remote means, we will collect your personal data. This includes (but is not limited to):
2.3. We may also collect special category data in accordance with employment equality requirements. We will only do this, for example, to make reasonable adjustments to enable all candidates to apply for vacancies, attend interviews and to commence employment. This is also necessary to ensure we meet our legal obligations when recruiting.
3.1. We will process your personal information for the following purposes and under the following lawful bases:
| Purpose | Lawful Basis for Processing |
| To assess your suitability for the role. | Processing is necessary for taking steps to enter into a contract with you or for the performance of our contract with you. |
| To make reasonable adjustments for you during the interview process and comply with our legal obligations under equality laws. | Processing is necessary for us to comply with our legal obligations. For special category data, the additional basis that we rely on relates to our obligations in the field of employment and the safeguarding of your fundamental rights. |
| To conduct pre-employment screening checks including checking your identity and your right to work. | Processing is necessary for us to comply with our legal obligations. For special category data, the additional basis that we rely on relates to our obligations in the field of employment and the safeguarding of your fundamental rights. |
| To contact unsuccessful applicants about future suitable vacancies | Processing is necessary for our legitimate interest of searching for suitable candidates for future vacancies based on their skills set out in the records we hold about candidates. |
4.1. We will only process sensitive ‘special category’ personal data where we meet one of the conditions required by law for doing so. This includes complying with legal obligations or exercising specific rights in the field of employment law. We may also ask for your explicit consent to process some special categories of personal data.
4.2. We process special categories of personal data when we collect or process information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work and to provide appropriate workplace adjustments.
5.1. We may need to share your personal data with engineering companies and third-party service providers located in countries where the data protection laws are not equivalent to those set by the GDPR Gold Standard. If we do so, we will use UK or EU-recognised international data transfer safeguarding mechanisms, such as EU-Standard Contractual Clauses with supplementary measures for EU citizen data, or the UK-approved International Data Transfer Agreement for UK citizen data. These mechanisms contractually oblige the entities in those countries to operate to the data protection standards expected within the UK and EU.
5.2. In such cases, the engineering companies will be a Controller and our service providers and suppliers will be Processors. Processors can only use your personal data in line with our instructions and not for any other purpose. Controllers may use your personal data for their own purposes and may determine the means by which your personal data is processed. These and other obligations are agreed in the data processing contracts between us.
5.3. Within Terminal, your personal data will only be shared with those who need to have access to it, which will primarily be our HR personnel and hiring managers.
6.1. We will retain your personal data for only as long as is necessary for the recruitment process. If your candidacy is successful and you are employed or hired by us, your data will be processed and retained as set out in our employee privacy notice, provided to you with your employment paperwork.
6.2. If your candidacy is not successful, we will retain your Resume, application details and interview notes for 12 months (from the date we notified you we would not move forward with your application), in order to inform you about any future vacancies we have that may be of interest to you. Please let us know if you would like us to delete your records before our retention period lapses and we will do so.
6.3. We will also retain personal data where it is necessary to comply with our legal obligations or as necessary in relation to legal claims. This is rare but may mean we need to retain your data for longer than 12 months.
7.1. Individuals whose personal data we process have the following rights:
7.2. If you wish to exercise any of your rights, please contact us at privacy@terminal.io. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
7.3. In addition to the above, please note that you have the right to make a complaint at any time to the relevant supervisory authority if you are concerned about the way in which we are handling your personal data.
8.1. You can contact Terminal, Inc in relation to data protection or this privacy notice by emailing privacy@terminal.io.
Last updated: 1st February 2024