This Policy does not form part of any employment contract or contract to provide services. If you provide services to us through or in connection with another company, we are not responsible for that company’s privacy practices.
We collect, store, and use various types of personal information through the application and recruitment process or during the relevant engagement or employment with us. We collect such information either directly from you or (where applicable) from another person or entity, such as an employment agency or consultancy, background check provider, or other referral sources.
Information we collect. The type of information we collect about you may include:
How we use this personal information. We collect, use, share, and store personal information from job applicants for our and our service providers’ business and operational purposes in our recruitment and hiring process such as: processing your application; assessing your skills, qualifications, and interests; tracking your application through the recruitment process; contacting references; conducting background checks you authorize; evaluating you for current and future job opportunities, including matching your skills and interest to applicable job requirements; communicating with you throughout the hiring process; making hiring decisions; and fulfilling your requests. We will also use job applicant information for internal analysis purposes to understand the applicants who apply and to improve our recruitment process, including improving our diversity and inclusion efforts. We may sometimes need to use applicant information for legal purposes, such as in connection with any challenges made to our hiring decisions.
Information we collect. The type of information we have about you (and potentially your beneficiaries and emergency contacts) depends on your role with us and may include, where applicable:
How we use this personal information. We collect, use, share, and store personal information for the Company’s and our service providers’ business purposes, which include, where applicable:
We will disclose job applicant, employee, and contractor personal information to the following types of entities or in the following circumstances (where applicable):
If you have questions about this Policy, please email Privacy Department at [email protected]
This EU/UK Notice for residents of the UK and European Economic Area is provided in order to satisfy certain obligations that Lightspeed has under the EU General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”) and UK Data Protection Act 2018 (as amended from time to time) and any relevant transposition of, or successor or replacement to, that regulation (together, the “Data Protection Legislation”).
Under applicable law, Lightspeed is considered the “data controller” of the personal information we handle under this Policy. In other words, we are responsible for deciding how to collect, use and disclose this information, subject to applicable law. Our contact information appears in this Policy.
Data Protection Legislation may require us to explain to you the legal bases for our collection, processing, and use of your personal information. Our legal bases include:
Where the collection of personal information is required to comply with legal or contractual obligations, or to manage the employment relationship, the provision of personal information generally is mandatory. In all other cases, provision of requested personal information is optional; however, failure to provide the information may result in your inability to fully participate in the activity or benefit for which the personal information is requested, such as an optional benefit program. If you have any questions regarding whether provision of personal information is mandatory and the consequences for withholding such data, please contact us using the contact information in this Policy.
The personal information that we collect and process may also contain sensitive data relating to your race or ethnic origin, physical or mental health or condition, trade union membership, commission or alleged commission of criminal offences and any related legal actions. For example, Lightspeed may process health information in accordance with applicable laws, such as information on disabilities for purposes of accommodations in the workplace and for the purpose of arranging employee medical benefits. We only collect and process sensitive data where and to the extent permitted in accordance with applicable data protection laws.
Your personal information may be transferred to countries which may not have the same or equivalent data protection laws as the European Union. Where required, we make such transfers in compliance with Data Protection Legislation, such as through the use of model contractual clauses (as published by the European Commission).
We may retain personal information for so long as necessary for the purposes described above, unless a longer retention period is required or permitted by applicable law. To provide security and business continuity for the activities described in this notice, we may make backups of certain data, which we may retain for longer than the original data.
We take technical, administrative, physical, and procedural security measures to reduce the risk that personal information in our possession and control will undergo accidental or unlawful destruction, loss, alteration, or unauthorized disclosure or access. Please visit our Trust Page for more detailed information of our data privacy and security practices.
Where the Data Protection Legislation applies, you have certain legal rights to request access to, and rectification or erasure of, personal information that we hold about you.
In some cases, you are entitled to receive, in portable form, a copy of the personal information you have provided to us or to request that we transmit it to a third party. You may also object to our processing of your personal information or request certain restrictions on the processing. You may withdraw any consent you have provided for the processing of personal information (which will not affect the legality of any processing that happened before the request takes effect). All such rights may be exercised by contacting the applicable entity listed below or by contacting Lightspeed as described above, who will handle or route the request as appropriate. These rights are subject to legal exceptions and limitations, which we must consider when addressing the request.
If you have any questions, concerns or complaints relating to our handling of personal information, please contact us as described in this Policy. You may also contact the relevant governmental authority (e.g., the UK Information Commissioner’s Office for UK individuals) with a complaint related to our handling of your personal information. However, we invite you to give us a chance to resolve the situation directly. Your privacy is important to us, and we will do our very best to address your concerns.
To exercise your rights in this EU/UK Notice or under the Data Protection Legislation (including to request further information on the mechanisms we have put in place in relation to personal information transfers outside the EU), to notify us of your preferences, please contact us as follows:
Data Protection Officer: John Genter
Lightspeed Systems Privacy Department
12013 Fitzhugh Rd.
Austin, TX 78736
Email: [email protected]
Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Lightspeed Systems has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR:
Pursuant to Article 27 of the UK GDPR, Lightspeed Systems has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR:
The EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. Data Privacy Framework (UK Extension to the EU-U.S. DPF), were respectively developed in furtherance of transatlantic commerce by the U.S. Department of Commerce, the European Commission and the UK Government to provide U.S. organizations with reliable mechanisms for personal data transfers to the United States from the European Union/ European Economic Area and the United Kingdom, while ensuring data protection that is consistent with EU and UK laws.
Lightspeed Systems is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Lightspeed Systems commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF in the context of the employment relationship.
Accountability for Onward Transfer
In the event Lightspeed Systems transfers personal data covered by this Policy to a third party acting as a controller, we will do so consistent with any notice provided to Data Subjects, any consent they have given, and only if the third party has given us contractual assurances that it will (i) process the Personal Data for limited and specified purposes consistent with any consent provided by the Data Subjects, (ii) provide at least the same level of protection as is required by the Data Privacy Framework Principles, and notify us if it makes a determination that it cannot do so; and (iii) cease processing of the Personal Data or take other reasonable and appropriate steps to remediate if it makes such a determination. If Lightspeed Systems has knowledge that a third party acting as a controller is processing Personal Data covered by this Policy in a way that is contrary to the Data Privacy Framework Principles, Lightspeed Systems will take reasonable steps to prevent or stop such processing.
Lightspeed Systems remains liable under the Data Privacy Framework Principles if an agent processes Personal Data covered by this Policy in a manner inconsistent with the Principles, except where Lightspeed Systems is not responsible for the event giving rise to the damage.
If you have any questions, concerns or complaints relating to our handling of personal information, please contact us as described in this Policy. You may also contact the relevant governmental authority (e.g., the UK Information Commissioner’s Office for UK individuals and the relevant Data Protection Authorities for EU individuals) with a complaint related to our handling of your personal information. However, we invite you to give us a chance to resolve the situation directly. Your privacy is important to us, and we will do our very best to address your concerns.
Under certain conditions, an individual may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted, provided that the individual has invoked binding arbitration by delivering notice to Lightspeed Systems, and following the procedures and subject to conditions set forth in Annex I of the DPF Principles.
This section applies only to California residents and are intended to supplement this
policy with information required by California law.
For detailed information on categories of data collected, purposes of collecting/disclosing data and recipients of disclosures, please refer to Sections 1 & 2 of this Policy.
Exercising your rights: If you are a California resident, there are some additional rights that may be available to you under the California Consumer Protection Act (“CCPA”) and the California Privacy Rights Act (“CPRA”), including:
If you’d like to exercise your rights, please contact us as described in this Policy. Please provide details about the kind of request you are making. In order to protect your information from unauthorized access or deletion, we may require you to provide additional information to verify your identity. If we cannot verify your identity, we will not be able to fulfill your requests to know, access, correct, or delete your information. You will not be discriminated against for exercising any of your privacy rights under the CCPA/CPRA.
This policy was last updated 08/31/2023 . Effective Date: 08/31/2023
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