Our Candidate Privacy Policy | Cleo

Candidate privacy notice 🔐

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Who is Cleo? 🤘

Cleo AI Ltd (hereafter “Cleo”, “we”, “us”, “our”) is located in 3rd Floor, 1 Ashley Road, Altrincham, Cheshire, United Kingdom, WA14 2DT and registered and incorporated in England and Wales, company registration number 09864205. Our registered address in the USA for Cleo AI Inc. is Corporation Trust Center, 1209 Orange Street, San Francisco, CA, 94016.

This notice gives an overview of what personal information we collect and how we use this information when you apply to a job at Cleo. This covers our responsibilities and your rights under the European Union’s General Data Protection Regulation (GDPR), as well as the California Consumer Privacy Act (CCPA).

What personal data do we collect from you? 📝

As part of the recruitment process, we collect and process personal data relating to your application. This includes name, address, contact details, qualifications, skills, experience and employment history, and other information that may be relevant for the recruitment process. Cleo may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from identity documents, or through interviews or other forms of assessments.

We may also collect personal data about you from third parties, such as recruitment and executive search agencies, professional networking sites or other public sources like social media and job boards.

If you’re invited to an interview and are offered a job at Cleo, we may also collect data through background checks, your immigration status for the country you’re applying in, or references from previous employers, managers or colleagues.

Additionally, we may also ask you to provide data relating to your age, ethnicity, gender identity, sexual orientation, disability & neurodiversity status and other “special category” data or personal information.

How do we use your information? 🎯

The General Data Protection Regulation (GDPR) and California Consumer Privacy Act (CCPA) state that we need to have a legal basis for using your personal data. This can be based either on a contractual duty, a legal duty, legitimate interest, public interest, vital individual interest, or if we have your consent.

We need to use your data to determine your suitability and eligibility for a role, as well as to contact you during, and facilitate the recruitment process. We may also keep your data to consider you for future opportunities (see below for how long we keep this data).

This may mean we have to share certain data with third parties, such as travel providers if you need to travel for an interview, or agencies to ensure you have the right to work in the country you’re applying for, to run background checks where necessary.

If you choose to provide any “special category data” (see above), we use this data to ensure we’re giving job applicants equal opportunity and treatment regardless of their demographic (public interest for GDPR purposes). Providing this data won’t affect your application in any way. We may use this data in an aggregated and anonymised format in order to track our DEI progress.

Who do we share and store your data with? 🤝

We may share and store your data in a range of different places, including on your application record, in HR and recruiting management systems and on other IT systems (including email). Data may also be stored in third countries in which case we have entered into agreements to secure the safety of your data according to applicable laws.

Your information may be shared internally for the purpose of the recruitment process (legitimate interest for GDPR purposes). This includes members of the HR and recruitment team, interviewers involved in the recruitment process and managers in the business area with a vacancy. Your data may also be shared with third parties that help us in our recruitment process. These include Executive Search agencies, recruitment software providers like Greenhouse and HiBob, cloud computing providers like AWS and Google Cloud, travel providers if you need to travel for an interview. With your consent, we may also collect information from referees you provide. Additionally we may share information with authorities where we have a legal obligation to do so.

If your application is successful, personal data gathered during the recruitment process will be transferred to your HR file and retained during your employment.

How long do we keep your data? 📆

Unless instructed otherwise, we will keep your data for up to 1000 days after we close the hiring process. We need to keep a copy of all applications for at least 6 months in case we face legal challenge about our decision.

What are your rights? 🧑‍⚖️

As a data subject, you have a number of rights. You can submit an access request and obtain a copy of your data, request us to change incorrect or incomplete data, require us to delete or stop processing your data, or simply object to our processing of personal data. We will not discriminate against you should you exercise any of the rights described in our privacy policy.

We may not always be able to follow your request, as we may be legally required to keep or use your data, where it is in our legitimate interest to do so.

To do any of the things above, please contact us at people@meetcleo.com. EU data protection laws give us one month to take action.

If you’d like to make a complaint about how we use your information, please email people@meetcleo.com and we’ll do our best to fix the problem. If you are applying in the US, then you can also contact us at 1-833-313-3171. 

If you’re still not happy, then you can refer your complaint to a data protection supervisory authority in the EU country you live or work in, or where you think a breach has happened. The UK’s supervisory authority is the Information Commissioner’s Office (ICO). For more details, visit their website at ico.org.uk.

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