Zeta Global Corp., 3 Park Avenue, 33rd fl. New York, NY 10016 (“Zeta”) is committed to protecting the privacy and security of your personal information.
This privacy notice describes how we collect and use personal information about you during recruitment activity, in accordance with relevant data protection legislation.
Zeta is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you, for telling you what information we collect and what we do with it, and for enabling you to exercise your privacy rights.
This notice describes what we do with the personal information of people who interact with us as a result of any recruitment activity. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
- Data protection principles
When we obtain personal information from or about you we will:
1) Only use that information lawfully, fairly, and in a transparent manner.
2) Collect information only for legitimate purposes that we have clearly explained to you, and not use it in any way that is incompatible with those purposes.
3) Ensure that the information we collect and use is accurate, up to date, adequate for and relevant to the purposes we have told you about and limited only to what is necessary to achieve those purposes.
5) Keep information about you only as long as necessary for the purposes we have told you about.
6) Use reasonable means to prevent information about you from being lost or misused.
- The kind of information we hold about you
Personal information, means information about you from which you can be identified. It does not include data where your identity has been removed (anonymous data), or aggregated statistics that cannot be related back to a specific person. We may collect, store, and use the categories of personal information about you set out in the table in Appendix A.
- How is your personal information collected?
We typically collect personal information about potential candidates through the application and recruitment process, either directly from candidates or sometimes from an employment agency. We may also collect additional information from third parties including former employers, personal connections, credit reference agencies or other background check agencies.
- How we will use information about you
We will only use your personal information for lawful purposes, including:
Considering your CV or application and throughout your participation in any recruitment process with Zeta. By consenting for Zeta to collect your personal information, you acknowledge that Zeta will retain your information for up to two (2) years following an application to consider you for other opportunities, analyze and report on application and hiring trends, defend legal claims, comply with employment laws, or other legitimate purposes related to Zeta’s hiring process. In rare cases, we may also use your information to protect your (or someone else’s) health or safety, or in the public interest.
Change of purpose
We will only use your personal information for the purposes described in this notice, unless we notify you in advance and obtain your consent for a different use of your personal information.
- How we use sensitive personal information
We may collect some sensitive personal information during our recruitment process, including information about your race or ethnicity, sexual orientation, or religion. We will only collect this data if you choose to provide it to us. We use this data to understand the diversity of our applicants and workforce, to report diversity statistics, and to ensure that we are maintaining an equitable and inclusive workplace.
- Information about criminal records
Background screening may be a condition for obtaining employment with Zeta Global. A background investigation will only be performed if you provide your consent.
- Automated decision-making
We do not envisage that any decisions will be taken about you using automated means.
- Data sharing
We may have to share your data with third parties, including third-party service providers (e.g., recruiters, companies that perform background checks, and software providers), and other entities in the Zeta group. We require third parties to respect the security of your data and to treat it in accordance with the law. We will transfer your personal information to the United States and may transfer it to other countries outside the European Economic Area (EEA). If we do, you can expect a similar degree of protection in respect of your personal information as you would receive for transfers within the EEA.
We may also share your personal information with third parties where required by law or to protect Zeta’s rights.
All our third-party service providers and other companies in the Zeta group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal information for specified purposes in accordance with our instructions.
Transferring information outside the EEA
We will transfer the personal information we collect about you to the United States to share with Zeta Global human resources, and potentially to third party service providers who are based in the United States or elsewhere.
To ensure that personal information originating from an EEA country receive an adequate level of protection we have put in place an intra-company data transfer agreement that incorporates EU Standard Contractual Clauses to establish a lawful basis for processing your information outside the EEA.
- Data security
We have put in place measures to protect the security of your information, whether it is physically held or virtually held by Zeta. These measures include use of username and password security (both internally and externally where information is held by third party providers) and secured servers with limited access control to persons with appropriate clearance.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
- Data retention
How long will you have my information?
We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. That usually means that if you do not join us as an employee, we will keep your data for retention period of a maximum of 2 years. If you do join Zeta as an employee, we will hold your data for the length of your employment, plus an additional period as required by local tax, employment, and other laws.
- Rights of access, correction, erasure, and restriction
Your duty to inform us of changes
It is important that the personal information we hold about you during any recruitment process is accurate and up to date. Please let us know promptly if your personal information changes during the application or recruitment process.
You have the right to:
- Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. Please note, however, that in many cases we may have legal reasons for maintaining personal information and may not be able to delete it upon request.
If you want to exercise these rights, please inform your Zeta HR contact in writing.
You will not have to pay a fee to exercise the rights described above. However, we may charge a reasonable fee for repeated requests for access within a 12-month period.
We may need to request specific information from you to help us confirm your identity in order to exercise the rights described above. This is an appropriate security measure to ensure that personal information is not disclosed to someone who does not have the right to receive it.
- Right to withdraw consent
You have the right to withdraw your consent for our processing of your personal information at any time, however, we may still have legal requirements or other grounds for continuing to process your information. To withdraw your consent, please inform our HR team.
- Data protection queries and complaints
If you have any questions about this privacy notice or how we handle your personal information, please contact the HR team. You may contact Zeta’s Data Protection Officer at privacy@zetaglobal.com. If we are unable to resolve any issues you may have, you may also have the right to contact your local privacy authority, which varies by the country, state, or province where you reside.
- Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice if we make any substantial updates whilst you are engaged in any recruitment process with us. We may also notify you in other ways from time to time about the processing of your personal information.
- Contact details
Address: 3 Park Avenue, 33rd fl. New York, NY 10016
E-mail: privacy@zetaglobal.com
Appendix A
Personal Information:
Candidate-provided information on resume/CV and job application may include:
- identification and contact information of the candidate;
- information on current job of the candidate;
- information on career history of the candidate;
- other information that the candidate has chosen to include.
We may also review your LinkedIn or other social media profiles, as well as other materials you may have posted online.
Purposes of processing include the following:
- selection procedure administration;
- negotiation of employment agreements where applicable;
- registration of the candidate and offering similar job opportunities in the future;
- conducting pre-employment background screening and checking your references;
- verifying employment and educational history;
- contacting you during the course of your application process
- working with third-party recruiters; and
- meeting any applicable legal requirements to which we are subject