Recruitment Privacy Notice

COGNYTE GLOBAL RECRUITMENT PRIVACY NOTICE

Summary of this Notice

Last Updated: 31 August 2023

About this Notice	This notice explains our privacy practices and how we handle Personal Information related to you as a job candidate and applicant. Read More.
What Personal Information Do We Collect and Use?	We record, collect, store, and analyze Personal Information, including Personal Information connected to your identity and job application; contact information; other sensitive data; use of or access to equipment; and CCTV footage. Read More.
Sensitive Personal Information	We collect and use sensitive Personal Information you provide us for the purpose of supporting our recruitment process. Read More.
Whose Personal Information We Process	We process Personal Information related to our prospective (nominees) employees. Read More.
How do We Collect Personal Information?	We collect Personal Information directly from you during your recruitment process, through the application and recruitment process and from third parties. Read More.
Why We Collect and Use Personal Information?	We collect and use Personal Information primarily to manage our recruitment process, including management of access and usage, compliance with applicable laws, regulations, and diversity requirements, and for defense against cyber-security attacks. Read More.
Lawful Grounds for Processing Personal Information	All Processing of Personal Information related to you that is not based on the lawful grounds indicated in this policy, or if such lawful grounds may not be used for the Processing of Personal Information related to you based on your territory, is based on your consent. Read More.
How Long Do We Retain Personal Information?	We retain Personal Information for the period necessary to fulfill the purposes, rights, and obligations that this Notice outlines. We retain records relating to our job applicants for a maximum of 12 months following termination of unsuccessful job applications, and we retain records relating to successful applications subject to our employee privacy notice. Read More.
Who Has Access to Personal Information?	We will share Personal Information internally, mainly with members of our People (HR) and Finance departments, your direct potential manager, senior management, and our IT staff, if access to the Personal Information is necessary to them for the performance of their roles. Read More.
Who Do We Share Personal Information With?	We share Personal Information with our affiliates, suppliers, and vendors, to fulfil the purposes of processing outlined in this Notice. We share Personal Information with Institutions and authorities, when we are required to do so by law, or to respond to legal processes; to maintain our security; and, to protect our legal rights and interests. Read More.
Selling Personal Information	We do not sell Personal Information. Read More.
What Are Your Obligations?	It is important that the Personal Information that we hold about you throughout your job application is accurate and up to date. Please keep us informed if Personal Information related to you changes. Read More.
What Are Your Choices and Rights?	You may request to access, correct, delete, or obtain a copy of Personal Information we have about you. Depending on applicable law, you may have additional rights available to you. Read More.
How Do We Secure Personal Information?	We have implemented administrative, technical, and organizational security measures as well as policies and procedures to protect Personal Information. Read More.
International Data Transfer	We transfer Personal Information between various sites located in Israel, the EEA (European Economic Area), the U.S., Brazil, and additional territories. Whenever we transfer Personal Information beyond the country of origin, we will do so in accordance with applicable laws. Read More.

About this Notice

We at Cognyte Software Ltd. and our subsidiaries (collectively: “we”, “us”, and “our”) put great efforts in making sure that we secure Personal Information related to you and use it properly. This notice (this “Notice”) explains our privacy practices and how we handle Personal Information related to you as a job applicant when you apply for a job with us.

Specifically, this Notice will provide details about the Personal Information that you submit us as a job applicant, what we do with Personal Information and how we Process, retain, and share it, and the rights that you may have in connection with Personal Information.

This Notice does not apply to our processing activities related to you as a user of Cognyte’s goods and/or services, in which case, you are subject to our website privacy policy, available here.

What Personal Information Do We Collect and Use?

We collect two types of data and information from our Candidates:

Directly and indirectly from you, when you apply for a job, or from recruitment service providers or consultants if such were involved or when you use our websites (“Websites”) to apply for a job with us. For example, usage details collected automatically during your interaction with our Websites, such as the type of browser you use, browser language, IP address, type of operating system, device ID, cookies installed on the device, date/time stamp, referring/exit pages, clicked pages, the actions you take on the Websites and any other information your browser may send us.

We use industry standard tools and software to monitor your navigation and usage of the Website, your usage pattern-logs and other communications information. We may also use cookies and/or similar technologies (“cookies”), which store certain information on your computer, and which allows us to enable automatic activation of features and improve your experience. Most browsers will allow you to erase such cookies, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies, or change the applicable settings, your experience on our websites may be limited. For more information, please see our Cookies Policy, to manage your cookie preference, please visit the Cookies Settings available in the Website’s footer.

Directly from you when submitting your application and candidacy review process. When you apply for a job with us, we will ask you to provide certain Information that will help us evaluate your qualifications and candidacy and stay in touch with you during the application and recruitment process. For example, when submitting a form or communicating with us through our website this includes information such as contact details-first and last name, job title, date of birth, place of birth, phone number, email, or physical address. If as part of your recruitment process you visit our offices, we may also process personal information related to you captured on our CCTV systems and ID number, for security purposes only.

Personal Information related to eligibility, such as: salary, benefits, tax and pension-related information, performance-related data, recruitment history and background checks;
Eligibility information, such as: resume/CV, cover letter, employment history (employers, job titles, length of employment) and educational background and training, linguistic capabilities, job skills, personal interests;
Verification and background information and documents such as: diplomas, certificates, national IDs, driver’s license, passport, social security, birth certificate;
Reference materials and documents such as: job references and letters of recommendation, job salary/payment history, military records, titles and licenses, immigration visa status, security clearance, background checks including criminal history (where permitted by law);
Publicly available information, such as social media information.

Sensitive Personal Information

Subject to any limitations under applicable laws, we collect and use the following sensitive Personal Information that you provide us and that we receive or collect about you for the purpose of supporting our recruitment process:

An individual’s government issued ID, such as a national or state identification card, social security number, driver’s license, or passport number.
The contents of an individual’s mail, email, and text messages unless we are the business that is the intended recipient of the communication.

We do not use or disclose such sensitive Personal Information to infer characteristics about you or for cross-contextual behavioral advertising.

Whose Personal Information We Process?

We may process Personal Information related to you if you are a current, former, or prospective employee, partner, worker, intern, agency worker, consultant, director, or contractor of ours.

We may also Process Personal Information in relation to dependents or other family members of the above people, in the circumstances set out in the section titled “Why We Collect and Use Personal Information? “.

How Do We Collect Personal Information?

We obtain the categories of Personal Information listed above from the following categories of sources:

Through the application and recruitment process, either directly from you when you apply for a job, or from recruitment service providers or consultants if such were involved.
From third parties including former employers, or other information providers, and, subject to applicable laws, through background checks.
If you use our online application system to apply for a job, our HR platform service provider will collect Personal Information related to you on our behalf. Comeet Technologies Inc is our third-party service provider that handles our job recruitment process. (See further information under Comeet’s privacy policy available at: Privacy Policy | Comeet Help Center). We may decide to change our job recruitment service provider.
From publicly available sources, such as social media.

Why We Collect and Use Personal Information?

We collect and use Personal Information primarily to manage our recruitment process (the “Purposes”), including:

To fulfill or meet the reason you provided the information. For example, to assess your skills, qualifications, and process your application and candidacy for any of our positions;
To communicate with you regarding such recruitment processes;
To enable the use of the Website. For example, to submit your CV;
To contact you with proposals and tailored information regarding new relevant positions in Cognyte, which you might be a suitable candidate for;
To provide, support, personalize, and develop our website by learning about your preferences and general trends relating to the Website;
To personalize your website experience and to deliver content relevant to your interests, regarding new positions, events, offers, including targeted offers and ads through our websites, third-party service providers’ sites or via email;
To administer and inform you about compensation and benefits or information relating to your potential employment;
To manage, maintain and document recruitment and other HR-related activities and personnel based on aggregated statistical data, that has been rendered deidentified, for further development and improvement of our recruitment processes;
to manage business operations and governance, for example: auditing, HR development and handling fraud and other violations of the law;
to comply with legal and other mandatory requirements, including to obey orders and subpoenas, and to comply with supervision and enforcement actions;
to support any corporate structure change, including mergers, acquisition, and other corporate transactions;
to monitor your use of any information and communication systems that we will make available to you during your recruitment process and for cyber security purposes; and,
To act as permitted by, and to comply with, any legal or regulatory requirements, including equal opportunity, diversity, and inclusion requirements and to protect our legal rights;

Lawful Grounds for Processing Personal Information

All Processing of Personal Information related to you that is not based on the lawful grounds indicated below, or if such lawful grounds may not be used for the Processing of Personal Information related to you based on your territory, is based on your consent.

We Process your job application related data to perform the recruitment process contract with you.
We will also Process Personal Information related to you to comply with our obligations under applicable law and to protect your and others’ vital interests.
We will further rely on our legitimate interests, which we believe are not overridden by your fundamental rights and freedoms, for example: (1) our HR and corporate management purposes; and (2) cyber security and fraud detection.

How Long Do We Retain Personal Information?

Retention periods can vary based on how long the recruitment process lasts and the period between when you first apply and when a hiring decision is made in connection with your application.

If your application for employment is successful, Personal Information received during the recruitment process shall be transferred to your personnel file and retained during your employment subject to our then in effect employees’ privacy policy, to be provided to you upon request by our relevant HR department.

If your application for employment is unsuccessful, we will retain Personal Information related to you for a period of 6 months following the notification of our decision. In the US region, and due to regulatory requirements, we will keep such information for a period of 12 months.

However, you can let us know that you would like us to save Personal Information related to you for a longer period, to consider for future job postings. If you do so, we will retain personal information related to you for an extended duration of up to an additional 6 months.

Upon the conclusion of these periods, or if you withdraw your consent during the extended period, personal information related to you shall be deleted or destroyed.

Also, at any time, you can opt-out of the collection of Personal Information by our service providers (Please see “What are your Choices and Rights” section).

Note also that we will maintain a record with details about your submission of the application with us, such as your name, interview dates and locations, our decision whether to hire you or not, and other relevant information to establish, exercise, and defend legal claims, for internal review, oversight and operation of our HR efforts, and if we are required under law to retain Personal Information related to you.

Who Has Access to Personal Information?

We will share Personal Information internally, mainly with members of our HR and Finance departments, your potential direct manager, senior management, and our IT staff in appropriate circumstances if access to the Personal Information is necessary for performance of their roles.

Access to Personal Information related to you within our subsidiaries is restricted to those who need to obtain access to it for the purposes outlined above, and generally they will only have access to that part of the information relating to you that is relevant to the particular purpose concerned.

We may disclose certain Personal Information related to you to our auditors and other professional advisors or consultants providing services to us that require such disclosure.

We will share Personal Information in the following instances:

With our third-party service providers, such as the job recruitment service provider that handles our job recruiting, hiring, and on-boarding process, or with any additional service provider which helps us with the recruiting process. Comeet Technologies Inc is our third-party service provider that handles our job recruitment process. (See further information under Comeet’s privacy policy available at: Privacy Policy | Comeet Help Center). We may decide to change our job recruitment service provider, With third party service providers that provide legitimate business functions for us, which will include processing Personal Information. Such third-party service providers are engaged by us for the provision of, among others, data storage, information security and employee background checks.
With competent supervisory authority, if we determine that doing so is in accordance with, or is otherwise required by applicable law, regulation, judicial or legal process.
With law enforcement or other authorities (including immigration, health, tax, national security) when it is necessary to protect the interests of our company or individuals.
With another entity when it is required as part of a merger, acquisition, or assignment of part or all our business with that entity, or any other change of corporate structure.

Selling Personal Information

We do not sell Personal Information for the intents and purposes of the California Consumer Privacy Act (CCPA). However, we engage third parties to provide us with services such as analytics, marketing automation and user experience and allow them to collect Personal Information on our Websites These third-parties do not pay us for collecting such information, but the right granted to them to collect Personal Information may be considered as disclosure for the purpose of sale or sharing for cross-context behavioral advertising under applicable laws governing the protection of privacy. At any time, you can opt-out of the collection of Personal Information by such service providers by contacting us.

What Are Your Obligations?

It is important that Personal Information that we hold about you during the recruitment process is accurate and current. Please keep us informed if Personal Information related to you changes.

You must inform your dependents whose information you provide to us about the content of this Notice and provide them with a copy of this Notice and any relevant policies.

You must also comply with this Notice and our policies, standards, and procedures that are brought to your attention when handling any information to which you have access in the course of your relationship with us, including any Personal Information related to other individuals. In particular, you will not access or use any information for any purpose other than in connection with and to the extent necessary for your work with us. These obligations continue to exist after termination of your job application with us.

What Are Your Choices and Rights?

You have the following rights:

You may request to confirm that we Process Personal Information related to you.
You may request access, correct, delete, transfer or to obtain a copy of Personal Information related to you and, subject to certain exceptions and applicable law, you may have additional rights available to you.
If the laws of the European Union apply to the processing of Personal Information related to you by us, you may find a summary and further details about your rights under EU (European Union) data protection laws, is available on the EU Commission’s website at: ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.

You may also request that Cognyte cease using personal information related to you for direct marketing purposes. Please note that you may manage the receipt of marketing information from us by clicking on the “unsubscribe” link located on the bottom of the email.

We do not Process Personal Information or otherwise use it to make decisions about you that are solely based on automated Processing, and we do not create a profile about you.
To exercise any of the abovementioned rights, please contact us)at: [email protected]. Upon your request and based on the rights afforded to you under applicable law, we will respond to your request promptly.
Only you or a person authorized to act on your behalf may make a request concerning Personal Information that we retain about you. You may also make a verifiable request on behalf of a minor under your charge.

Please note that: (a) we may require additional information in order to verify your request; (b) if you will not respond within 14 days from our initial verification email, you will be notified that your request was closed, and we will not be able to accommodate it; (c) your request may be recorded by us for legal obligations; and (d) we may charge a reasonable fee or refuse to act on a request if such request is excessive, repetitive, manifestly unfounded, or if we required to or allowed by the applicable law or regulation. You will not receive discriminatory treatment and you will not be retaliated against for exercising your rights.

AT ANY TIME, CONTACT US IF YOU WANT TO WITHDRAW YOUR CONSENT TO THE PROCESSING OF PERSONAL INFORMATION. NOTE HOWEVER, THAT EXERCISING THIS RIGHT WILL NOT AFFECT THE LAWFULNESS OF PROCESSING BASED ON CONSENT BEFORE ITS WITHDRAWAL. YOU MAY ALSO OBTAIN INFORMATION ABOUT THE POSSIBILITY OF DENYING CONSENT AND THE CONSEQUENCES OF SUCH DENIAL.
You have a right to lodge a complaint with a privacy and data protection supervisory authority of your habitual residence, place of work or of an alleged infringement of applicable laws governing the protection of privacy. You can also contact us at: [email protected].

We will do our best to respond to your request within 30 days of its receipt (unless otherwise required under applicable laws). If we require more time (up to an additional 30 days), we will inform you of the reason and extension period in writing. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. The response we provide will also explain the reasons for our inability to comply with your request, if applicable.

How Do We Secure Personal Information?

We have implemented administrative, technical, and organizational security measures, as well as policies and procedures, based on industry best practices, to protect your Information. These measures and procedures are designed to protect Personal Information against risks, such as temporary or permanent loss, destruction, and unauthorized or unlawful access, alteration, use or disclosure. Please note, however, that there are inherent risks in transmission of information over the internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use of your information will never occur.

We require our suppliers and vendors to apply similar security measures and procedures when they access or use Personal Information that they process on our behalf.

International Information Transfer

We transfer Personal Information between various sites located in Israel, the EEA, the U.S., Brazil, and additional territories to operate our business efficiently, to improve performance, and to create redundancies to protect information in the event of an outage or other malfunctions. Such a transfer is done in accordance with applicable law.

Before transferring the Personal Information, we will assess risks involved with the transfer, enter into relevant information transfer agreements, adhere to applicable security and confidentiality requirements, or take such other measures to lawfully transfer the Personal Information.

If applicable laws permit us to rely on your consent to transfer Personal Information related to you, then by submitting your application you signify your consent to such transfer.

Our policy towards children

Cognyte does not intend and does not knowingly collect or sell personal information from children under the age of sixteen (16). We reserve the right to request proof of age when needed. If we learn that we collected personal information from children under the age of sixteen (16) we will delete that information promptly. Please contact Cognyte at [email protected] if you have reasons to suspect that Cognyte collected such information.

Got any questions?

We are committed to protecting your privacy. Should you have any questions concerning this Policy, please contact us at: [email protected] or send a letter to our headquarters located at Maskit 33, Herzliya Pituach, 4673333, Israel.