Effective Date: April 30, 2022
Varcharr Recruitment Privacy Notice
This notice (“Notice”) describes how Varcharr, Inc. and its subsidiaries and related companies (collectively, “Varcharr”) handle and protect your Recruitment Data, as defined below, to which Varcharr is provided access in connection with the recruiting process.
For additional information about our processing activities in connection with your general use of Varcharr websites and our use of cookies and similar technologies outside the scope of this Notice, please see the Varcharr Privacy Policy.

By making available your Recruitment Data, you confirm that:
  • You have reviewed this Notice;
  • You have provided any notices and obtained any consents needed to provide information concerning others (e.g., information about employment references); and
  • Your Recruitment Data may be transferred and processed worldwide, including in the US and other countries that may not be deemed to provide the same level of data protection as your home country, for the purposes and in the manner specified in this Notice.
Varcharr will process Recruitment Data in accordance with this Notice, unless in conflict with requirements of applicable law, in which case applicable law will prevail.
This Notice does not form part of any contract of employment offered to candidates hired by Varcharr.

  • Recruitment Data is identifiable information that an individual makes available to Varcharr in connection with the recruiting process. Recruitment Data may include a variety of information, such as candidate status, work history/job data, education, compensation, employer feedback, questionnaire results, contact information, previous addresses or names, additional information provided by the candidate (e.g., a cover letter), driver’s license number as required for certain positions, references, and criminal history where permitted by law.
  • Processing refers to any action performed on Recruitment Data, such as collecting, recording, organizing, storing, transferring, modifying, using, disclosing, or deleting.
  • Sensitive Recruitment Data is Recruitment Data concerning nationality or citizenship, race or ethnic origin, criminal history, or trade union membership. Varcharr does not request or consider information concerning religion, or sexual orientation, or political opinions in connection with recruiting.

You have various methods, both electronic and paper, to submit your Recruitment Information to Varcharr. Alongside collecting Recruitment Information directly from you, Varcharr may, to the extent permitted by law, collect Recruitment Information from third parties. For instance, from recruiters regarding a background or employment check, an employment reference (subject to your consent where required by law), from a recruiting or other website, or a credit check.

Processing and Retention
Varcharr processes Recruitment Information for legitimate human resources and business management purposes. These include identifying and evaluating candidates for Varcharr roles, record-keeping related to hiring processes, analyzing the hiring process and outcomes, and conducting background checks, where permitted by law. We process Recruitment Information for these purposes because it is essential for our legitimate interests in recruiting staff and administering our hiring processes. In addition, Recruitment Information may be used to comply with Varcharr’s legal, regulatory, and corporate governance requirements. If a candidate is hired, Recruitment Information may be used in connection with his/her employment in accordance with the terms of Varcharr’s Internal Privacy Policy.

In addition to using Recruitment Information for the position for which you have applied, Varcharr may retain and use your Recruitment Information to consider you for other roles. If you do not want to be considered for other roles or would like to have your Recruitment Information removed, you may contact Varcharr as specified under Inquiries, Complaints, and Objections below. Unless required for tax or other legal purposes or in connection with employment as specified above, or some other retention period is required by local law, we will retain your personal information for a period of 3 years after we have communicated to you our decision about whether to appoint you to a role to which you have applied. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted our recruitment and hiring processes in compliance with applicable law.

Sharing with Third Parties
We may share your personal information internally within Varcharr and/or its affiliates for the purposes described in this notice. Varcharr may transfer Recruitment Data to external third-party service providers performing certain services on behalf of Varcharr. Third-party service providers include recruitment operations, communication and verification providers used for the purposes of managing, coordinating, documenting and analyzing our recruitment efforts, facilitating communications, marketing and employment verification. Such third-party service providers have access to Recruitment Data solely for the purpose of performing the services specified in the applicable service contract, and Varcharr requires the service providers to undertake security measures consistent with the protections specified in this Notice.
Varcharr may be required to disclose certain Recruitment Data to other third parties as required by law, regulation or legal process (such as a court order or subpoena);  to law enforcement authorities or other government officials to comply with a legitimate legal request; to establish, exercise or defend our legal rights, and in connection with an investigation of suspected or actual fraud, illegal activity, security or technical issues; or in an emergency where the health or safety of a candidate or other individual may be endangered. In addition, in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of Varcharr’s business, Varcharr may transfer Recruitment Data to successor entities or parties.

Sensitive Recruitment Data
Varcharr may perform background and criminal checks where permitted by law, and may process other Sensitive Recruitment Data, such as citizenship or nationality information or health information, in order to evaluate a potential reasonable accommodation in the recruitment and hiring process where requested, for equal opportunity monitoring, when relevant for a position and permitted by law. We process personal data for these purposes when we are required to do so by law or if you have given your explicit consent.
If Varcharr intends to collect Sensitive Recruitment Data from third parties, you will be provided notice and the opportunity to consent. If you have a disability and would like Varcharr to consider a reasonable accommodation, you may provide that information during the recruiting process. We do not intend to collect any Sensitive Recruitment Data from you unless specifically requested for the purposes described above.

Security and Confidentiality
Varcharr employs technical and organizational measures designed to protect the integrity, confidentiality, security and availability of Recruitment Data, and to comply with applicable legal requirements for information security. Varcharr limits access to internal systems that hold Recruitment Data to individuals who need access for a legitimate business purpose.

Candidate Rights
You may exercise the following rights in relation to your Recruitment Data:
Access, Correction and Deletion: Varcharr will provide you access to your Recruitment Data that Varcharr holds to the extent required by law in your home country, regardless of the location of the Recruitment Data processing. You may request correction or deletion of that Recruitment Data, except where retention is required by your contractual relationship with Varcharr, in the context of a legal dispute, or as otherwise required by law. You also may request a copy of your Recruitment Data in machine-readable format in some cases, or object to the processing of your Recruitment Data. If access, correction or deletion is denied, the reason for the denial will be communicated to you.

Automated Decisions: Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. In the event that Varcharr relies solely on automated decision-making that could have a significant impact on you, Varcharr will notify you, provide you an opportunity to express your views and provide any other safeguards required by law.

Inquiries, Complaints and Objections: You may withdraw consent to the processing of your Recruitment Data or submit inquiries, complaints and/or objections to the processing of your Recruitment Data by sending a request in writing to: privacy@​varcharr.​gg.

The processes described in this Notice supplement any other remedies and dispute resolution processes provided by Varcharr and/or available under applicable law.
If you are located in the EU, you also may lodge a complaint with the data protection supervisory authority in your country.

Direct Marketing
Varcharr will not use Recruitment Data to offer you any products or services for personal or family consumption (“Direct Marketing”) or provide Recruitment Data to third parties for their Direct Marketing. These restrictions do not apply to contact or other personal data obtained in the context of a customer, consumer or other non-employment relationship with Varcharr.

International Data Transfers
Varcharr is a global organization. Accordingly, Recruitment Data may be transferred to and processed in the US and other countries that may not be deemed to provide the same level of data protection as your home country. When we transfer Recruitment Data to a country outside of your home country, we may use a variety of legal mechanisms authorized by law, including standard contractual clauses approved by the European Commission, other data transfer agreements, and consent of the data subject. You may obtain a copy of legal mechanisms we have put in place by contacting us as described above.

Changes to this Notice
Varcharr reserves the right to modify this Notice by posting changes to relevant Varcharr websites. If you submit additional Recruitment Data or request to be considered for a Varcharr position following the effective date of a modified Notice, your Recruitment Data will be handled in accordance with the Notice in effect at that time.