This Policy describes the ways your personal information and data is collected, used and shared and the rights and options available to you with respect to your information.
Start.io is the data controller, as described below in this Policy.
You hereby agree to the use of: (a) electronic means to provide you with any notices given pursuant to this Policy; and (b) electronic records to store information related to this Policy.
- Information processed by Start.io in regard of Candidates
- In the course of hiring process, you will be required to submit to Start.io information about you. That information will include personal information (such as: name, phone number and email), and information about your background and professional experience.
- Start.io does not ask you, and you will refrain from providing us, any Sensitive Information about yourself or biometric information when you engage us as a Candidate. In addition, if you are under the age of eighteen (18), please do not submit your application to be employed by Start.io.
“Sensitive Information” means information revealing, consisting or concerning (directly or indirectly) any of the following information as to the data subject: (a) racial, ethnic or communal origin; political affiliations or opinions; (b) religious or philosophical beliefs or other beliefs of a similar nature; (c) intimate affairs or sexual life; (d) government identification number, student identification number or otherwise; (e) economic position, financial data, credit worthiness data, financial account, payment card number; (f) the commission or alleged commission of any offence, any proceedings for any offence committed or alleged to have been committed, the disposal of such proceedings or the sentence of any court in such proceedings, criminal record; (g) political parties or trade-union membership; and (h) physical or mental health or condition, health insurance, medical and/or biometric data.
- Start.io may collect, or use the services of third parties to collect, additional information in regard of you, which is public available (such as by using Google search, LinkedIn and Facebook). In addition, Start.io may contact other persons who know you, subject to your consent, for obtaining additional information such as recommendations.
- We may use third parties’ services to store and manage your data (such as “Commit”). These third parties are processors of the data, will keep it in confidentiality and process it for Start.io purposes only.
- Start.io will use the information you provide or collected or shared with Start.io about you for the following purposes: (a) for contacting you in the course of the hiring process and provide you with related notices or documents; (b) to search for additional information about you; (c) to decide whether to engage with you in an employment agreement or otherwise; (d) to search for other Candidates with a similar resume; and (e) to comply with any applicable law, including sharing it if such information is required by law to be provided to competent authorities.
- The information you voluntarily provide to Start.io and Start.io collects otherwise in regard of you will be stored by Start.io for a period of eighteen (18) months as of the last engagement with you as a Candidate (if you become an employee, the following section will apply). Following these eighteen (18) months period, Start.io will keep the following information only: name, phone number and email. This information will be kept for a period of additional eighteen (18) months for the following purposes: (a) to identify you if you re-engage Start.io as a Candidate; (b) to identify you if your details are provided to Start.io by a third party (such as recruiting company); (c) to protect Start.io interests in case of dispute, or legal proceeding of any kind involving you.
- Information processed by Start.io in regard of Employees
- When engaging Start.io as an Employee you will be required to submit to Start.io the following information:
- Information which is requested to engage in a binding employment agreement and paying your salary, such as: name, phone number, email, home address and bank account.
- Information which is requested by the local authorities of financial institutes (such as tax authorities and banks), which will include the following information (part of it may be Sensitive Information): your income, marital status, name of spouse, number and name of children. By submitting the form requested by these authorities you hereby agree and authorize Start.io to use that information for the purpose of this form only.
- During your employment, Start.io will process data in regard of your performance. Such data may be collected from any employee of Start.io (such as your managers, colleagues or employees reporting to you) or from the company engagement with you (such as conversations or recurrent meetings). Such information will be stored at Start.io human resources department and will be available to (i) your manager; (ii) human resources department employees; (iii) company senior management (VP or C level). This information will be used for HR purposes, such as valuating your performance at Start.io, including: promotion, change of position or termination of employment.
- You may be requested by us to provide and thereafter use your fingerprints (biometric data) for the following purposes only: (i) identify you by our attendance system (your fingerprints will be saved locally) for the purpose of documenting your working hours; and (ii) enable you to enter Israeli office front door system.
- Start.io does not ask you, and you will refrain from providing us, any Sensitive Information about yourself, other than the specific information outlined in Sections 2.1-2.3 above.
- Start.io will use the information you provide or collected by or shared with Start.io about you for the following purposes (“Purposes”): (a) for contacting you in the course of your employment; (b) to exercise and enforce your employment agreement; (c) to manage the financial aspects of Start.io engagement with you; (d) HR purposes as described above; (e) for Start.io’s reasonable business purposes and interests, including: managing, monitoring, processing your information, recruitment and staffing; (f) for the purposes outlined in Section 2.3; (g) for administration of compensation, benefit programs, payroll and other employee-related administration; performance management, education and training; (h) advancement and succession planning; (i) workplace management; (j) to protect you, the Company, its workforce, and the public against injury, theft, legal liability, fraud, or abuse; (k) to protect Start.io interests in case of dispute, or legal proceeding of any kind involving you; and (l) to comply with any applicable law, including sharing it if such information is required by law to be provided to competent authorities.
- We will use third parties’ services which will process your data (such as: data storage and management), and provide Start.io with relevant services for execution of the above Purposes, such as pay slips generating, tax, payment processing services, accountant and legal services (“Third Parties”). These third parties are data processors and will keep your data in confidentiality and process it for the Purposes only. Start.io will share the relevant information with these Third Parties for the Purposes outlined above.
- The information Start.io processes in regard of you during your employment at Start.io will be stored by Start.io for a period of seven (7) years as of termination of your employment at Start.io, or the minimum period required or permitted by law, for the following purposes: (a) to identify you if you re-engage Start.io as a Candidate; (b) to identify you if your details are provided to Start.io by a third party (such as recruiting company); (c) to protect Start.io interests in case of dispute, or legal proceeding of any kind involving you; and (d) if such information is required by law to be provided to the competent authorities.
- Security cameras
Public areas in Start.io offices may be recorded (video shooting) by security cameras. In offices which are handled by third parties, these security cameras will be operated by these third parties. Such recording will be made and used for security purposes only and will be stored by Start.io for a period of up to six (6) months. Private areas (such as rest rooms and kitchens) or private offices are not recorded.
- Transfer of your information upon special events such as merger or acquisition
In the event of merger, sale or transfer of all or a portion of our assets or shares or other reorganization or reconstruction in our ongoing business, or upon bankruptcy, dissolution or other liquidation or insolvency events, the information that we receive, collect or obtain, as outlined in the preceding sections, may be shared with or transferred to, that respective entity, provided that it will undertake to be bound by the provisions of this Policy, with reasonably necessary changes taken into consideration. Upon such transfer or sharing of information, that entity will assume full and exclusive responsibility for all subsequent use and processing it makes of the information and we will be released from any liability to you, regarding the succeeding entity’s use and processing of the information by it.
- Aggregated or anonymized information
Anonymized or aggregated information, which does not identify you personally will be used by us in any way.
- Transfer of Data Outside Your Territory
Your information will be stored and processed in Israel, the United States and in other various locations throughout the globe. If you are a resident in a jurisdiction where transfer of your personal information to another jurisdiction requires your consent, then you hereby provide your express and unambiguous consent to such transfer.
- Legal basis for processing of data
Process (including: collection, use and share) of information you provide us is performed on the following legal basis:
Candidate: (i) to fulfil your engagement with Start.io as a Candidate; and (ii) legitimate interests of Start.io as outlined above.
Employee: your consent in your employment agreement. If such consent has not been provided, it is based on: (i) to fulfil your engagement with Start.io as an Employee; and (ii) legitimate interests of Start.io as outlined above.
- Your Rights with the Data
You have the right to exercise any of the following rights, as well as other rights granted to you in accordance with the laws apply to you by contacting Start.io HR (“End User Right(s)”):
- Right to know your data / data portability: you have the right to receive a copy of the data collected about you, other than (i) data shared with Start.io in confidentiality by third parties (such as your former managers or colleagues); and (ii) data generated for internal purposes of Start.io whose disclosure will affect Start.io legitimate interests.
- Right to erasure (right to be forgotten): you have the right to request us to delete or remove the personal information collected about you. We will delete any information which is not necessary to protect our legitimate interests while engaging you as Candidate or Employee, as outlined above, or prevent us from being compliant with any applicable law
- In addition to the above you have the right to lodge a complaint with a supervisory authority.
- Information Security
Security measures are implemented to reduce the risks of damage, loss of information and unauthorized access or use of information. However, these measures are unable to provide absolute information security. Therefore, although efforts are made to secure your personal information, it is not guaranteed and you cannot reasonably expect that our databases will be immune from any wrongdoings, malfunctions, unauthorized interceptions or access, or other kinds of abuse and misuse.
- Changes to this Policy
This Policy may be changed from time to time. Changes will take effect 30 days after an initial notification is posted through Start.io HR portal and/or in the following link: https://www.start.io/employees-candidates-privacy-policy/. However, if the Policy is amended to comply with legal requirements, the amendments will become effective immediately upon their initial posting, or as required. The most up-to-date Policy is accessible through the following link: https://www.start.io/employees-candidates-privacy-policy/.
Last update: January 6, 2021