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Flipdish Applicant Privacy Policy

This Applicant Privacy Policy describes how we collect and use personal data about you during and after the process of your application to work with Flipdish Limited trading as Flipdish, or its subsidiaries (“Flipdish”, “we”, “us” or “our”). Flipdish is incorporated in Ireland with company registration number 555703 and having its registered office address at First Floor, Heron House, Corrig Road, Sandyford Business Park, Dublin 18, D18 Y2X6, Ireland. This Applicant Privacy Policy provides details of the way in which we process personal data in line with our obligations under the General Data Protection Regulation (No. 2016/679) (“GDPR”), the Data Protection Act 2018 (Ireland) and any other laws which apply to us in relation to the processing of personal data (collectively referred to as “Data Protection Laws”). In this Applicant Privacy Policy, “controller”, “personal data”, “process” (and its derivatives) and “processor” have the meanings given to those terms in Data Protection Laws.

Personal data generally means information that can identify a person and processing generally covers actions that can be performed in connection with personal data such as collection, use, storage and disclosure. Flipdish is the controller of your personal data processed in connection with your application to work with Flipdish. We process personal data of applicants across a range of systems and tools, including *.flipdish.com (the “Website”), communications platforms (email, Google Workspace etc.), Thomas International (psychometric assessment and aptitude tests) and Greenhouse software (an applicant tracking software).

Purpose of the Applicant Privacy Policy

The purpose of this Applicant Privacy Policy is to explain Flipdish’s data processing activities, including how and why we process personal data. In addition, this Applicant Privacy Policy outlines our duties and responsibilities regarding the protection of such personal data.

Personal Data We Collect

We collect personal data about you when you provide it directly to us through the Flipdish Hiring Process (the “Process”), when third parties such as recruitment agencies, former and current employers and educational institutions provide us with personal data about you, or when personal data about you is automatically collected in connection with your use of the Website.

Personal Data Collected Directly From You

We receive personal data directly from you including, but not limited to:

  • Biographical information. Information such as name, date of birth, gender, marital status, national identification information and in some cases, residency and work permit status.

  • Contact information. Information such as email address, residential address and telephone number.

  • Historic and current employment information and educational information. Information such as previous employers, references from previous employers, previous roles, period of time spent in previous roles, current role, background check, educational institutions attended, educational results obtained and degrees awarded.

  • Other information. Information that may be necessary for us to make a recruitment decision or otherwise voluntarily provided by you.


The provision of personal data is necessary for assessing your application and, if successful, entering into any contract with Flipdish governing employment. The minimum information required to be provided is biographical information, contact information and historic and current employment information and educational information. If such personal data is not provided, it may not be possible to proceed with your application or to commence the employment relationship.

Personal Data Collected From Third Party Sources

Third parties such as recruitment firms, previous employers and educational institutions may provide us with personal data in relation to you. We may also collect personal data from public sources such as social media (e.g. LinkedIn etc.) where you have a publicly available profile.

Such personal data includes, but is not limited to biographical information, historic and current employment information and educational information and other information.

Personal Data Collected We Automatically Collect

Some personal data is automatically collected when you use the Website, such as:

  • IP address;

  • device identifiers;

  • browser information; and

  • cookie data (as explained in our Cookie Policy)


Such information is collectively referred to as “automatically collected information”.

    Our Legal Justification for Processing Personal Data

    The below table sets out why we process your personal data as described above, the legal justification that supports this processing and the categories of personal data processed.

    Why we process your personal data

    Legal justification

    Categories of personal data

    Administration and recruitment management

    To:

    • manage the application process and assess your suitability for roles. In certain cases, psychometric tests may be used in respect of specific roles;

    • communicate with you in relation to your application; and

    • verify information and to conduct background checks as necessary

    Such processing is in Flipdish’s legitimate interest to ensure effective recruitment processes and that roles are suitably filled and recruited for

    In respect of the verification of information, we have a legitimate interest in verifying the information provided is true and accurate and to conduct background checks as appropriate to ensure the prudent management of Flipdish’s business and recruitment processes

    Biographical information, contact information and employment information

    In respect of psychometric tests, the tests may involve questionnaires that relate to cognitive abilities / emotional intelligence

    Training, quality monitoring and evaluation

    To:

    • monitor and improve our recruitment and hiring processes and ensure that the Website is used in accordance with our terms and conditions and policies

    Such processing is necessary for the legitimate interests pursued by us in monitoring and improving our recruitment and hiring processes and ensuring that the Website is used in accordance with our terms and conditions and policies.

    Biographical information, and contact information, historic and current employment information and educational information and automatically collected information

    Website services

    To:


    • troubleshoot issues; and

    • conduct data analysis

    It is in Flipdish’s legitimate interest to operate and maintain the Website and for related analysis purposes

    Automatically collected information

    Enforcing and defending our rights

    To:

    • ensure that our recruitment processes are managed properly and to establish, exercise or defend our legal rights

    • enforce applicable terms and conditions and policies;

    • address legal or administrative proceedings whether before a court or statutory body;

    • protect against or deter fraudulent, illegal or harmful actions; and

    • ensure the Website is used in accordance with the our terms and conditions of use and policies

    It is in Flipdish’s legitimate interest to enforce and defend its rights

    Biographical information, contact information, historic and current employment information and educational information and other information as may be necessary in the establishment, exercise or defence or defence of our legal rights

    In respect of the Website, automatically collected information

    Legal obligations

    To:


    • ensure Flipdish complies with its legal obligations in terms of its hiring processes; and

    • comply with other legal obligations.



    Such processing may be required by law

    We will disclose personal data where we receive a legally binding request to disclose personal data from law enforcement or other bodies or where we have a legitimate interest in assisting law enforcement or other agencies in respect of an investigation.


    Biographical information, contact information and historic and current employment information and educational information

    Individual Data Subject Rights

    Data Protection Laws provide certain rights to data subjects (the “Data Subject Rights”). Data Subject Rights include the right of a data subject to:

    • receive detailed information on the processing (as per transparency obligations on controllers) which we have provided through this Applicant Privacy Policy;

    • access personal data;

    • rectify or erase personal data (i.e. right to be forgotten);

    • restrict processing;

    • data portability;

    • object to processing based on legitimate interests. We shall no longer process the personal data unless we demonstrate compelling legitimate interest grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims;

    • withdraw consent to processing based on consent without affecting the lawfulness of processing based on consent prior to the withdrawal of consent;

    • complain to the Data Protection Commission (www.dataprotection.ie) or a competent data protection supervisory authority. We ask that you first contact [email protected] to give us an opportunity to address any concerns; and

    • to not be subjected to automated decision making.

    These Data Subject Rights will be exercisable by you subject to limitations as provided for under Data Protection Laws.

    In relation to the processing of your personal data by Flipdish, you may contact us or make a request to exercise any Data Subject Right by contacting [email protected]. Your request will be dealt with in accordance with Data Protection Laws.

    Disclosing Your Information

    Flipdish may be required to disclose personal data in some scenarios such as if you violate applicable policies or laws. Flipdish may disclose such personal data, at our sole discretion, if we believe it is necessary or appropriate in connection with investigation, prevention or detection of fraud, IP infringement, piracy, other unlawful activity and / or to protect and / or to protect our rights or the rights of third parties and / or prevent physical and / or other harm and / or financial loss. This may require disclosure of biographical information, contact information, historic and current employment information and educational information and / or other information.

    Flipdish may engage other companies and people to perform tasks on our behalf (i.e. processors) and may need to share personal data with them to provide you with our services such as Greenhouse, a third party recruitment software providers and applicant tracking systems and Thomas International, a psychometric assessment and aptitude test provider.

    Flipdish may share your personal data in respect of the Process with wholly-owned subsidiaries of Flipdish on a controller to controller basis. These entities are Flipdish UK Limited, Flipdish GmbH and Flipdish, Inc. Flipdish may also share your personal data in respect of the Process with certain employer-of-record service providers from time to time, where relevant.

    Data Retention

    We will keep personal data only for as long as the retention of such personal data is deemed necessary for the purposes for which that personal data are processed (as described in this Applicant Privacy Policy) unless we are required to retain your personal data for a longer period (e.g. in the event of legal proceedings or investigations). In general, personal data of applicants’ will be retained for a period of eighteen (18) months for unsuccessful applications. If you enter into an employment relationship with Flipdish, your personal data will be retained in accordance with the retention information set out in the Employee Privacy Policy.

    Data Transfers Outside the EEA

    We may occasionally transfer personal data outside of the European Economic Area to countries that are not deemed to grant an adequate level of protection. Any such transfers will be in accordance with applicable law and appropriate safeguards such as the standard contractual clauses approved under EU law from time to time. If you require further information, please contact [email protected].

    Third Party Links

    On occasion we include links to third parties on the Website. Where we provide a link it does not mean that we have any control over the linked website or its privacy policy or that we endorse, or approve that website’s policy towards visitor privacy. You should review the linked website’s privacy policy before sending them any personal data.

    Changes

    The manner in which we process personal data will evolve and we will update this Applicant Privacy Policy from time to time to reflect changing practices. We will update the “Last Modified” date accordingly at the end of this Applicant Privacy Policy. Please review this Applicant Privacy Policy from time to time.

    Contact

    For further information about this Applicant Privacy Policy or the processing of your personal data please contact us at [email protected].

    Last Modified

    This Policy was last updated on 22 June 2022.