Job Applicant Privacy Policy

Last reviewed: June 14, 2024

Introduction

This Privacy Policy (“Policy”) explains how your information as a job applicant is collected and used by Roller Networks Pty LTD and its corporate group subsidiaries (“Roller” or “we”, “us”, “our”).

This Policy applies to all Personal Information related to job applicants that is Processed by the Company, whether in electronic format or in a structured filing system.

Terms used in this Policy

“Candidate” - Any applicant for a position at the Company as a temporary, full-time or part-time employee, intern, contractor or contingent worker.
“Personal Information” - Any information relating to you.
“Processor” - An entity that processes Personal Information on behalf of the Company.
“Processing” (and any variant of such term) – Any action taken on Candidate Personal Information such as collecting, recording, storing, organizing, altering, using, disclosing, transmitting or deleting, including if performed by automated means.

Data Controller

Roller Networks Pty Ltd is the primary Controller of the Personal Information for the purpose of this Policy. Our postal address is:

PO Box 562
South Melbourne, 3205
Australia

We can also be contacted through the following email address: info@rollersoftware.com.

The personal information we collect and our methods of collecting it

We will collect and Process Candidate Personal Information for the purpose of administering employment applications and for various necessary recruitment purposes prior to making a hiring decision and, where relevant, entering into an employment agreement.

Candidate Personal Information includes, for example, name, contact details, physical address, date of birth, photograph (if you proactively provide it with you CV), details of your qualifications, employment history, Information included in your CV or cover letter, job preferences, current and historic salary details (if permitted under law) together with salary expectations, details of your current benefit entitlements.

If you voluntarily provide us information about our gender, racial or ethnic origin, and health condition, we also will process that information.
Personal Information may also include names and contact details for references. Please note that it is your responsibility to obtain consent from your references prior to providing us personal information about them.

You are not under any legal obligation to provide us Personal Information. However, we do need it to consider your job application.

The Company collects Personal Information about Candidates from a number of sources, including you, the Candidate, other third parties such as references supplied by former employers, recruiters and recruitment agencies, individual referrals, information from employment background check providers and information from criminal records checks where necessary or required by law.

Should your application be successful, relevant data will be transferred to our HR information system.

Purposes of Processing Personal Information

Your Personal Information will be Processed for the purposes and on the basis detailed below. We may Process the Personal Information for additional purposes, provided that policy is given to you, and provided that we receive your consent if so required under the law.

Purposes	Illustrative Scenarios	Example of data categories	Legal Basis under UK and EU law
Recruitment – Reviewing your candidacy for the open position you applied for	Interviews, assessment tests and questionnaires, references from other parties	Contact details, birthdate, education, CV, referrals, employment history, salaries (if permitted under law) , work permits, social, identification documents, email correspondence with you.	Our legitimate interests in properly reviewing your candidacy and making a recruitment decision Steps necessary before entering into an employment contract with you
Defending or asserting legal claims relating to your candidacy	If you or a third party asserts a legal claim against us about how we handled your candidacy		Our legitimate interests in asserting or defending legal claims that impact the course of our business or reputation.
Retaining your candidacy for future positions beyond the ones you applied for	If we later have a job opening for a similar position that may be relevant to you		Our legitimate business interests in continuing to consider you for other open positions

Sharing Candidate Personal Information

We will share your Candidate Personal Information within our internal HR team. We may also share some of Candidate Personal Information with Processors engaged by us to provide services we require to use Candidate Personal Information for permitted purposes. Such Processors operate under our instructions. We aim to ensure that any Processor we use takes adequate measures to protect your Candidate Personal Information, by signing a data processing agreement with it, though we cannot guarantee the practices of these third parties are maintained and followed.

We do not sell your Candidate Personal Information to third parties.

Because we operate our business as a corporate group of companies, we may also share your Candidate Personal Information with companies in our corporate group for the same purposes set out above. These entities are those controlled by, under the control of, or under common control with Roller Networks Pty Ltd. These are primarily the following entities:

Roller Networks Australia Pty Ltd (incorporated in Australia)

Where required by law, we will also disclose your Candidate Personal Information to a governmental authority, in response to legal process or when we believe in good faith that the law requires it. The legal basis for this is a legal obligation we are subject to and our legitimate business interests in complying with binding requests of governmental authorities.

International data transfers

If we transfer your personal data for processing at locations outside your jurisdiction, we will abide by data transfer rules applicable to these situations.

Roller Networks USA Inc. (incorporated in Delaware)

Roller Networks Limited (incorporated in England)

Retention and security

Retention. We retain information about your candidacy for the initial period necessary for the recruitment process unless. We then retain the information for an additional period of 36 months for the purpose of considering you for other potential job opening, and in case the information is necessary to handle legal claims related to the application.

Personal information of unsuccessful Candidates will be deleted within 36 months of the decision. We will retain the information of Candidates we ultimately hire for as long as we employ them and for an additional period of 7 years thereafter.

Safeguards. We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of Candidate Personal Information. We also request our affiliates to implement such measures in order to secure the information we provide them. However, although efforts are made to secure Candidate Personal Information, we cannot guarantee its absolute protection.

EU and UK Rights

If you are in the EU or the UK, you have the following rights under the GDPR:

Right to Access and receive a copy of your Candidate Personal Information that we Process.

Right to Rectify inaccurate Candidate Personal Information we have concerning you and to have incomplete Personal Information completed.

Right to Data Portability that is, to receive the Candidate Personal Information that you provided to us, in a structured, commonly used and machine-readable format. You have the right to transmit this data to another person or entity. Where technically feasible, you have the right to have your Candidate Personal Information transmitted directly from us to the person or entity you designate.

Right to Object to our Processing of your Candidate Personal Information on the basis of our legitimate interest. However, we may override the objection if we demonstrate compelling legitimate grounds, or if we need to Process such Candidate Personal Information for the establishment, exercise or defense of legal claims.

Right to Restrict us from Processing your Candidate Personal Information (except for storing it): (a) if you contest the accuracy of the Candidate Personal Information (in which case the restriction applies only for a period enabling us to determine the accuracy of the Candidate Personal Information); (b) if the Processing is unlawful and you prefer to restrict the Processing of the Candidate Personal Information rather than requiring the deletion of such data by us; (c) if we no longer need the Candidate Personal Information for the purposes outlined in this Policy, but you require the Candidate Personal Information to establish, exercise or defend legal claims; or (d) if you object to our Processing based on our legitimate interest (in which case the restriction applies only for the period enabling us to determine whether our legitimate grounds for processing override yours).

Right to be Forgotten. Under certain circumstances, such as when our Processing of your Candidate Personal Information is based on your consent, you have the right to ask us to erase your Candidate Personal Information. However, notwithstanding such request, we may still process your Candidate Personal Information if it is necessary to comply with our legal obligations, or for the establishment, exercise or defense of legal claims.

If you wish to exercise any of these rights, contact us through the channels listed below.

When you contact us, we reserve the right to ask for reasonable evidence to verify your identity before we provide you with information. Where we are not able to provide you with information that you have asked for, we will explain the reason.

Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. If you are in the EU, then according to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority, particularly in the Member State of your residence, place of work or place of an alleged infringement of the GDPR. For a list of supervisory authorities in the EU, click here.

If you are in the UK, you can lodge a complaint to Information Commissioner’s Office (ICO) pursuant to the instructions provided here.

Additional information for Individuals residing in California

If you are an individual residing in California, we provide you the following information pursuant to the California Consumer Privacy Act (CCPA).

Please note that we do not sell your personal information and we have not done so in the preceding 12 months.

We also do not share your personal information for online behaviorally-targeted ads and have not done so in the past 12 months.

Categories of Personal Information (Under the CCPA)	Specific Types of Personal Information Collected	Business Purposes For Which the Information Is Used (Under the CCPA)	Specific Details on the Business Purpose
Identifiers of the Candidate	Your name, residential address	Auditing related to a current interaction with the Candidate Detecting security incidents and protecting against malicious, deceptive, fraudulent or illegal activity Exercising or defending our legal rights and the rights of our employees, customers, and agents Administration of our operations, including for safety purposes Compliance with applicable laws and regulations	Recruitment – Reviewing your candidacy for the open position you applied for Defending or asserting legal claims relating to your candidacy Managing the Company’s ongoing business Retaining your candidacy for future positions beyond the ones you applied for compensation and payroll
Other information that identifies, relates to, describes, or is capable of being associated with, the Candidate	Your telephone number, demographic information, employment status, title, family status, status in the U.S. and information on your right to work in the U.S.
Professional or employment-related information	Your professional education and training, employment history, references
Education information	Your professional education
Characteristics of protected classifications under California or federal law	Gender, racial or ethnic origin, health condition. These are considered sensitive information under the CCPA. We do not use or discloses this sensitive personal information for purposes other than those specified in the CCPA regulations.
Inferences drawn from any of the information identified above to create a profile about the Candidate	Assessment of characteristics, skills, abilities and aptitudes

The chart below explains the personal information we disclosed for a business purpose to third parties in the preceding 12 months.

Categories of Personal Information (Under the CCPA)	Categories of third parties to whom we disclose your information and the specific business or commercial purpose for the disclosure
Identifiers of the Candidate	With other companies in our corporate group, for the same purposes indicated in the chart above. With outside legal counsels, for the purpose of handling complaints and lawsuits relating to your candidacy. With third parties to which a law or binding order requires us to disclose your information to. Our purpose in doing so complying with our obligations under the law or the binding order. With the target entity of our merger, acquisition or reorganization, and legal counsels, and advisors, for the purpose of facilitating the structural change in the operation of our business within a different framework, or through another legal structure or entity (such as due to a merger or acquisition).
Other information that identifies, relates to, describes, or is capable of being associated with, the Candidate
Professional or employment-related information
Education information
Characteristics of protected classifications under California or federal law
Inferences drawn from any of the information identified above to create a profile about the Candidate

Your rights under the CCPA if you are a resident of California

Knowing the personal information, we collect about you

You have the right to know:

The categories of personal information we have collected about you.
The categories of sources from which the personal information is collected.
Our business or commercial purpose for collecting personal information.
The categories of third parties with whom we share personal information, if any.
The specific pieces of personal information we have collected about you.

Right to deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

Delete your personal information from our records; and
Direct any service providers to delete your personal information from their records.

Please note that we may not delete your personal information if it is necessary to:

Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us.
Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes.
Debug to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act.
Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the ability to complete such research, provided we have obtained your informed consent.
Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which you provided the information.

Comply with an existing legal obligation.

We also will deny your request to delete if it proves impossible or involves disproportionate effort, or if another exception to the CCPA applies. We will provide you a detailed explanation that includes enough facts to give you a meaningful understanding as to why we cannot comply with the request to delete your information.

Right to correct inaccurate personal information

If we receive a verifiable request from you to correct your information and we determined the accuracy of the corrected information you provide, we will correct inaccurate personal information that we maintain about you.

In determining the accuracy of the personal information that is the subject of your request to correct, we will consider the totality of the circumstances relating to the contested personal information.

We also may require that you provide documentation if we believe it is necessary to rebut our own documentation that the personal information is accurate.

We may deny your request to correct in the following cases:

We have a good-faith, reasonable, and documented belief that your request to correct is fraudulent or abusive.
We determine that the contested personal information is more likely than not accurate based on the totality of the circumstances.
Conflict with federal or state law.
Other exception to the CCPA.
Inadequacy in the required documentation
Compliance proves impossible or involves disproportionate effort.

We will provide you a detailed explanation that includes enough facts to give you a meaningful understanding as to why we cannot comply with the request to correct your information

Protection against discrimination

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA.

Exercising your CCPA rights by yourself or through an authorized agent

If you would like to exercise any of your CCPA rights as described in this Policy, please contact us by e-mail at info@rollersoftware.com.

We will ask you for additional information to confirm your identity and for security purposes, before disclosing the personal data requested to you, by using a two or three points of data verification process, depending on the type of information you require and the nature of your request.

You may also designate an authorized agent to make a request under the CCPA on your behalf. To do so, you need to provide the authorized agent written permission to do so and the agent will need to submit to us proof that they have been authorized by you. We will also require that you verify your own identity, as explained above.

Minors

We do not recruit or employ individuals under the age of 18. We do not knowingly collect Personal Information about individuals under that age, other than Personal Information about your minor underaged children that we may process for purposes like HR administration, tax reporting provision of insurance, etc. We do not sell Personal Information about minors.

Contact us

If you wish to exercise any of these rights, or if you have any questions or comments about this Privacy Policy, please contact us at: info@rollersoftware.com

We reserve the right to ask for reasonable evidence to verify your identity before we handle you data subject request. Where we are not able to provide you the information that you have asked for, we will explain the reason for this.

Changes to Our Privacy Policy

From time to time, we may change this Privacy Policy. If we do so, we will make efforts to proactively notify you of such changes. In any event, the latest version of the Privacy Policy will always be accessible on our website.