GAN – Applicant Privacy Policy
Effective Date: 02-February-2024
GAN ( “Controller,” “we,” or “our”) understands the importance of protecting the privacy of our workforce. This privacy policy (“Privacy Policy”) explains our information practices and the rights and choices you may have in relation to how we collect, use, retain, and disclose the Personal Data (defined below) you may provide during your recruitment, including when you apply for a specific job or submit a resume or other information directly to GAN or through a third party platform like Teamtailor (the “Service”). By using the Service or otherwise providing information to us during your application and recruitment at GAN, you acknowledge and agree to the data practices described in this Privacy Policy.
If you are a California resident, please see the section below titled Your Privacy Rights and Choices; California Residents for our Notice at Collection and additional information provided pursuant to California law.
For the purposes of this Privacy Policy, GAN is the “Data Controller” or “Business” as defined by applicable data privacy laws. GAN processes prospective employees’ data for the purpose of managing and facilitating our recruiting practices and for other business purposes as described in this Privacy Policy.
TABLE OF CONTENTS
I. Information We Collect and How We Collect It
II. How We Use Applicant Information
III. Disclosures
IV. Your Privacy Rights and Choices; California Residents
V. Data Security and Retention
VI. Services From Other Parties
VII. Children’s Information
VIII. Changes to this Privacy Policy
IX. Contact Us
1. Data We Collect and How We Collect It
For purposes of this Privacy Policy, “Personal Data” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, and may include Usage Information. “Usage Information” refers to device, internet, and network activity information that we, our business partners, and our service providers may collect.
We may collect one or more categories of the Personal Data and Sensitive Personal Data (as defined by applicable laws in certain jurisdictions) listed below. We will collect the majority of Personal Data, including any Sensitive Personal Data, directly from you or through the Service. In limited circumstances, third parties may provide your Personal Data to us. These third parties may include your current or former employers; specialized recruiters and recruiting agencies; job boards, such as Indeed or LinkedIn; government agencies; courts; and/or background check service providers. Depending on your interactions with us, we may also obtain information about you from advertising networks, internet service providers, data analytics providers, operating systems and platforms, or social media platforms such as Facebook.
We may collect the following categories of Personal Data and Usage Information about you in the course of business and during your recruitment at GAN:
Identifiers and contact information, such as your full name, address, telephone number, email address, emergency contacts, signature or similar identifiers.
Demographic data, such as date of birth, gender, race, ethnic origin, marital status, family composition, disability, health and welfare or retirement benefits related information
Employment screening and hiring information, such as your resume, employment application, academic records, references, job title, position, hire dates, compensation, performance and disciplinary records, vacation and leave records, interview notes and summaries of an individual’s preferences, characteristics, attitudes, intelligence, abilities, and aptitudes.
We may supplement the data that you provide to us with information that we receive or obtain from other sources, such as our staff or personnel; vendors and service providers; professional advisers, partners, and agents of GAN; third parties with whom we interact; and publicly available sources.
We may also collect the following categories of Sensitive Personal Data about you in the course of business and during your recruitment at GAN:
Government identifiers, such as your Social Security number, driver’s license, state identification card, and passport and visa information, and immigration status and documentation.
Demographics such as Racial or Ethnic origin or gender required for government reporting.
We do not collect, use, or disclose Sensitive Personal Data to infer characteristics about individuals.
Usage Information
Usage Information we collect may include:
Cookies and Other Tracking Technologies, for more information, please visit https://careers.gan.com/cookie-policy
2. How We Use Applicant Information
We use your Personal Data, including Sensitive Personal Data, for our business purposes, including recruitment and employment, human resources, health and safety, to prevent fraud and other criminal activity, to maintain legal compliance, and for other purposes for which we may notify you.
Personal data about job applicants is collected and processed for purposes of screening, identifying, and evaluating candidates for positions; record-keeping related to hiring processes; analyzing the hiring process and outcomes; and conducting background checks, where and to the extent permitted by applicable law. If you are hired by GAN, this data may be transferred to our employee record files for the purpose of your employment. In addition, job applicant data and legal and regulatory compliance data may be used as necessary to comply with legal, regulatory, and corporate governance requirements.
We use applicants’ Personal Data to:
Comply with applicable laws and regulations;
Recruit and evaluate job applicants;
Conduct background checks;
Engage in corporate transactions requiring the review of employee records, such as for evaluating potential mergers and acquisitions;
Administer and maintain GAN’s operations, including for safety purposes; and
Exercise or defend the legal rights of GAN and its employees, affiliates, customers, contractors, and agents.
3. Disclosures
We will only disclose your Personal Data to third parties with your consent, where required by law or to our employees, contractors, designated agents, service providers, or third parties who require such information to assist us with administering recruitment and employment-related processes, including entities that provide services to us or on our behalf. We may use service providers for various purposes, including, obtaining employment verification and background checks, chat or messaging providers, file sharing, data storage, or hosting providers. These service providers may be located outside of the country where you reside.
Our service providers must implement appropriate security measures to protect your Personal Data consistent with our policies, applicable regulations, and information security obligations applicable to us. We do not permit third parties or service providers who process your Personal Data on our behalf to use your Personal Data for their own purposes. We only permit them to process your Personal Data for specified purposes in accordance with our instructions.
We may also disclose your Personal Data for the following additional purposes when permitted or required by applicable law:
To GAN employees across our offices (including outside of your home state or country) for the purposes set out in this Privacy Policy and as necessary to administer the recruitment and application process;
To comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders. When we disclose your Personal Data to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum Personal Data necessary for the specific purpose and circumstances;
To government entities in response to employer accountability and discrimination audits;
To protect our legal rights and property;
During emergency situations or where necessary to protect the safety of persons;
If a business transfer or change in ownership occurs and the disclosure is necessary to complete the transaction. In these circumstances, we will use and share your Personal Data consistent with this Privacy Policy, including providing prior notice of any new or changed practices that materially impact your Personal Data, when applicable;
To other parties with your consent where such consent is required by law; and,
To other parties as permitted or required by law.
We may also share non-personal, deidentified and aggregated data with third parties. This data has been compiled from information collected through the Service and may, for example, include your internet traffic or geolocation data that is not linked to you or your identifiable information.
4. Your Privacy Rights and Choices; California Residents
GAN applicants may have certain rights with respect to Personal Data depending on the applicable data protection laws where you live, including any exemptions or exceptions. Please note that some of these rights may be limited where we have a legal obligation to continue processing the Personal Data, or where data may be exempt from disclosure due to reasons of legal professional privilege or professional secrecy requirements. However, generally, applicants have the right to request:
Access to Your Data. You may have the right to request access to your Personal Data and, where technically feasible, request a copy of your Personal Data. You may also have the right to obtain information about how we process or disclose your Personal Data.
Review and/or Correction of Your Data. You may have the right to request that we correct any inaccurate or incomplete Personal Data that we process.
Delete Your Data: You may have the right to request that we delete your Personal Data. Please note that we may not be able to delete certain information depending on legal exceptions or obligations. Please see the Data Security and Retention section below for more information about why we may retain your data.
Objection. You may have the right to (i) object at any time to the processing of your Personal Data for direct marketing purposes and (ii) object to our processing of your Personal Data where the legal ground of such processing is necessary for legitimate interests pursued by us or by a third party. We will then abide by your request unless we can demonstrate compelling legal grounds for the processing.
Restrict the Use and Disclosure of Data. You may have the right to request to restrict how we use your Personal Data, including your Sensitive Personal Data.
Revoke Consent. You may have the right to withdraw your prior consent to the processing of your Personal Data, including sharing your Personal Data with other parties (other than our service providers or other contractually restricted third parties).
Appeal. You may have the right to submit an appeal if you are not satisfied with the outcome of your request. Please send appeals directly to privacy@gan.com.
Non-Discrimination. In California, you have the right not to receive discriminatory treatment by us for exercising your rights and choices, this extends to applicants right not to be retaliated against for the exercise of their privacy rights.
Lodge a Complaint. If you are in the EEA, you also have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws. Please click here for a list of local data protection authorities in EEA countries. If you are in the UK, you have the right to lodge a complaint with the Information Commissioner’s Office, who can be contacted here.
Exercising Your Rights
If you would like to exercise any of these rights, please email privacy@gan.com. In order to protect your Personal Data, we may ask you to provide additional information to verify your identity. You may also submit a request to exercise your rights through an authorized agent, in which case your agent must present signed written permission to act on your behalf. You may be required to independently verify your identity with us and confirm that you have provided authorization to the agent.
If you are in the EEA or the UK and would like to exercise any of those rights or request further information, please:
Email us at privacy@gan.com;
Provide proof of identity and, if necessary, additional information to identify yourself; and
Provide the information to which your request relates.
California Residents
In the preceding 12 months, GAN has collected, used, and disclosed the categories of Personal Data in the below chart to our service providers for specific, limited business purposes, including the purposes listed in the How We Use Information section of this Privacy Policy. We do not “sell” or “share” any Personal Data (Personal Information as defined by the CCPA), as indicated below.
Compliance with Section 7027(m). GAN does not use or disclose Sensitive Personal Data for purposes other than those specified in Section 7027(m) of the implementing regulations of the CCPA.
California “Shine the Light” Notice. California law requires us to inform California residents who have provided us with personal data that they may request information from us about our disclosures to third parties for their direct marketing purposes. We do not provide personal data to third parties for their direct marketing purposes.
Categories of Personal Data Collected; Purpose for Collection and Use; Shared or Sold?
- Identifiers (name and contact details (for example, your email address, mailing address, phone number and social media handles)).
Shared
- Inferences (preferences, such as which employment opportunities you are interested in).
Not Shared
- Professional Information (such as your current or previous employer(s), job title, function, and the nature of your duties and responsibilities).
Not Shared
- Protected Classification Characteristics (such as age, gender, religion, and disability information, which you may provide to us in connection with an application for employment)
Not Shared
- Education information (such as your university transcripts and other information relevant to hiring qualifications).
Not Shared
Data Transfers
GAN is a U.S.-based business comprised of offices in multiple jurisdictions. Your Personal Data may be transferred within our offices’ integrated computer networks in the United States, and with third parties in other countries that may not be subject to data protection laws similar to those in the jurisdiction in which information is provided to or received by us.
It may be necessary to transfer Personal Data from your home jurisdiction to another country to obtain access to our applicants’ Personal Data to enable our recruitment process, and for other purposes as set out in this Privacy Policy.
If we transfer Personal Data from within your home jurisdiction to other countries, we implement adequate safeguards to appropriately protect such transfer of Personal Data, including on the terms of a valid data transfer agreement incorporating the appropriate terms or as permitted under applicable data protection laws.
5. Data Security and Retention
We implement reasonable physical, technical, and organizational safeguards designed to protect your Personal Data against accidental loss and unauthorized access, use, alteration, or disclosure. In addition, we limit access to Personal Data to those employees, agents, contractors, and other third parties that have a legitimate business need for such access.
Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Data for as long as necessary to fulfill the purposes for which we collected it, as required to satisfy any legal, accounting, or reporting requirements, or as necessary to resolve disputes. To determine the appropriate retention period for Personal Data, we consider our statutory obligations, the amount, nature, and sensitivity of the Personal Data, the purposes for which we process your Personal Data, and whether we can achieve those purposes through other means.
If you are offered and accept employment with us, the Personal Data we collected during the application and recruitment process will become part of your employment record, and we may use it in connection with your employment consistent with this Privacy Policy or applicable law. If you do not become an employee, we will retain and securely destroy your Personal Data in accordance with our policies and applicable laws and regulations. Unless you have consented or there is a contractual or regulatory requirement that specifies otherwise, we generally retain Personal Data about applicants for no more than 18 months.
6. Services From Other Parties
Please note that this Privacy Policy does not apply to the practices of third parties, including our workforce recruitment vendors like Teamtailor or other platforms. When you access a third party’s website or services through links on our website, information collected from you by others on those third-party websites, is governed by those entities’ privacy policies. GAN is not responsible for and does not control the security or privacy of your information when you visit those sites or use those services. We encourage you to read the privacy policy of every website you visit.
7. Children’s Information
We do not recruit or employ, or intend to collect Personal Data from, anyone we know to be a child under the age of 16. If we learn that we have unknowingly collected or received Personal Data from a child under 16, we will make reasonable efforts to delete such information from our records. If you believe that we might have any information from or about a child under 16, we ask that a parent or guardian contact us at privacy@gan.com.
8. Changes to this Privacy Policy
Please review the Effective Date at the top of this page to determine when this Privacy Policy was last revised.
From time to time, we may modify this Privacy Policy. If we update this Privacy Policy, we will notify you by posting a new Privacy Policy on this page. If we make any material changes to this Privacy Policy, we will notify you as required by law, which may include by email to the email address you provided to us, if available. We encourage you periodically to check this page for updates.
9. Contact Us
If you have any questions about this Privacy Policy or need to access this Privacy Policy in an alternative format due to disability, please contact us at privacy@gan.com
If you have any questions about our practices with respect to your Personal Data or would like to make an access or other request, please contact us at privacy@gan.com
