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Applicant Privacy Statement
Last updated: March 12, 2024
Applicant Privacy Statement
This Applicant Privacy Statement (“Statement”) explains how Gemini collects, uses and discloses personal information during the recruitment process. Generally, the personal information we collect from you helps us manage the recruiting and hiring process with you, conduct Gemini’s business, and comply with Gemini’s legal or contractual obligations. 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.
The California Consumer Privacy Act Employee and Applicant Disclosure provides additional information for California resident Applicants.
- 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;
- Data pertaining to work preferences and abilities;
- 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. When you choose to provide any such Sensitive Information, it will not be used in the hiring decision unless specifically permitted by law.
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 you about the recruitment and on-boarding process;
- Providing immigration assistance, such as facilitating filing of any necessary visas or work permits (as applicable);
- Improving 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 record-keeping 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
Your Personal Information will only be shared where lawful to do so and for legitimate business purposes. We will not sell or 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 (or jurisdiction where relevant) 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
When you access Gemini, we 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 Gemini’s website or job postings. We may use Cookies for various purposes, such as to enforce our terms, prevent fraud, and analyze your use and interaction with Gemini.
We may make use of third-party Cookies or analytics services.
Third-party tracking technologies are not controlled by us, and statements regarding our practices do not apply to these third-parties or their use of information. We make no representations regarding the policies or practices of such third parties. You may be able to opt out of the practices of some of these third parties if they are members of the Network Advertising Initiative (“NAI”) by visiting http://www.networkadvertising.org/choices or if they participate in the Digital Advertising Alliance (“DAA”) by visiting http://www.aboutads.info/choices. We are not responsible for effectiveness of or compliance with any third-parties’ opt-out options.
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.
6. Our retention of your information
We will retain personal information in accordance with the Company’s data retention schedule 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. If you are offered and accept employment with the Company, the information collected during the application and recruitment process will become part of your employment record.
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 Economic Area or a United Kingdom resident and you believe that we have not adequately resolved any such issues, you have the right to contact DPO@gemini.com or your local supervisory authority.