Applicant Privacy Statement

Last updated: May 2, 2022


Applicant Privacy Statement

This Applicant Privacy Statement (“Statement”) explains how Gemini collects, uses and discloses personal information during the recruitment process. We reserve the right to change any of our policies and practices at any time. Your continued use of the services after any such updates take effect will constitute acknowledgement and (as applicable) acceptance of those changes.

  1. Personal Information we collect

As used herein, “Personal Information” means information that identifies or is reasonably capable of identifying an individual, directly or indirectly, and information that is being associated with an identified or reasonably identifiable individual. 

A. We may collect the following Personal Information directly from you: 

  • Identification Information, such as name, email, phone number, postal address, government identification numbers; your work permit or visa status;

  • Your resume or CV, cover letter, previous and/or relevant work experience or other experience, education, transcripts, or other information you provide to us;

  • Job and salary expectations, willingness to relocate, or other job preferences; or

  • Sensitive Information,such as gender, gender identity, sexual orientation, religion, marital status, race, ethnicity, whether you are a member of a trade union or a veteran, or have a disability, to the extent you provide us such information. 

Additional safeguards are in place for processing of Sensitive Information. We will only collect and use ‘Sensitive Information’ in cases where: (i) we have your explicit consent, (ii) is necessary for legal compliance, (iii) you have manifestly made such information available to us, (iv) it is necessary for reasons of substantial public interest, or (v) it is necessary for the exercise or defense of our legal rights. Sensitive Information will not be used in the hiring decision.

B. We may collect the following Personal Information automatically:

  • Online Identifiers, such as IP address; domain name;

  • Device Information, such as hardware, operating system, browser;

  • Usage Data, such as your interaction with us, our recruiting applications or our recruiting posts on other platforms; or

  • Geolocation Data. 

Our automatic collection of Personal Information may involve the use of Cookies, described in greater detail below.

C. We may collect the following Personal Information from third parties: 

  • Information from references or background checks (as applicable);

  • Information you make available publicly (e.g., your LinkedIn profile);

  • Information related to any assessment you may take as part of the interview process;

  • Immigration information from immigration advisors in the course of filing work permit or visas (as applicable).

2. How we use Your Personal Information

We will use your Personal Information for our recruitment process, including:

  • Evaluating your candidacy, such as assessing your skills, qualifications and interests against our career opportunities;

  • Verifying your information, by carrying out reference checks and/or conducting background checks (as applicable) if you are offered a job;

  • Communicating with youabout the recruitment process; 

  • Providing immigration assistance,such as facilitating filing of any necessary visas or work permits (as applicable);

  • Improving our recruiting our recruiting processes, to enhance our tools and improving diversity in our recruiting;

  • Complying with applicable law and other obligations, legal processes or other government requests; or

  • Complying with applicable internal governance processes such as meeting recordkeeping obligations and conducting audit. 

For residents of European Economic Area or the United Kingdom, we process personal data subject to applicable law on one or more of the following legal bases:

  • Contractual obligation: As necessary to potentially enter into an employment contract with you;

  • Legal obligation: For compliance with applicable legal obligations or in connection with legal claims; 

  • Legitimate Interest: For our legitimate interest in improving our recruitment process (to the extent that such legitimate interest is not overridden by your interests or fundamental rights and freedoms); or

  • Consent: Where we have your explicit consent.

3. Who may have access to your information

We will not share your Personal Information with third parties, except as described below:

  • Affiliates: We may share your Personal Information with our affiliates and our employees, for the purposes outlined above. 

  • Service Providers: We may share your Personal Information with third-party service providers to perform some of the services described above. We share your Personal Information with these service providers only so that they can provide us with services, and we prohibit our service providers from using or disclosing your Personal Information for any other purpose. Our third-party service providers are subject to strict confidentiality obligations. 

  • Law Enforcement: We may be compelled to share your Personal Information with law enforcement, government officials, and regulators.

  • Corporate Transactions: We may disclose Personal Information in the event of a proposed or consummated merger, acquisition, reorganization, asset sale, or similar corporate transaction, or in the event of a bankruptcy or dissolution.

  • Professional Advisors: We may share your Personal Information with our professional advisors, including legal, accounting, or other consulting services for purposes of audits or to comply with our legal obligations. 

  • Consent: We may share or disclose your information with your consent. 

4. International transfer of Personal Data 

Gemini operates internationally with many of our systems based in the United States. Therefore, we may need to transfer your Personal Data to other affiliates or third parties to fulfill the purposes described herein. When we transfer your personal data outside the country in which you are located, we endeavor to ensure safeguards are implemented such as: (i) adequacy decisions; (ii) our Binding Corporate Rules; (iii) suitable Standard Contractual Clauses; or (iv) other valid transfer mechanisms.

5. Cookies

We or our service providers may make use of the standard practice of placing tiny data files called cookies, flash cookies, pixel tags, or other tracking tools (herein, “Cookies”) on your computer or other devices used to visit our website or postings. We may use Cookies for various purposes, such as to enforce our terms, prevent fraud, and analyze your use and interaction with Gemini.

You also can learn more about cookies by visiting https://www.allaboutcookies.org, which includes additional useful information on cookies and how to block cookies on different types of browsers and mobile devices. Please note that if you reject Cookies, you will not be able to use some or all of our website or postings. If you do not consent to the placing of Cookies on your device, please do not visit, access, or use Gemini.

6. Our retention of your information

We will retain personal information for various purposes described herein, including for consideration for future roles, to analyze and improve our recruiting practices, to protect Gemini from potential legal claims and as required by applicable law or regulation.

7. Your rights in respect of your information

In certain countries, you may have certain rights under applicable privacy laws. This may include the right to request access, obtain or to update your information, request that it be deleted or anonymized, or object to or restrict us using it for certain purposes.

If you wish to submit a request to access, obtain or delete your personal information, please contact privacy@gemini.com. We will respond to any requests in accordance with applicable law. We are legally obligated to verify your identity when you submit a request. We may request additional information from you to verify your identity. 

If you are a European resident and you believe that we have not adequately resolved any such issues, you have the right to contact your local supervisory authority.