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Docebo – Recruitment Privacy Policy

Effective Date: 24/04/2023

This Privacy Policy covers the personal data we collect about you as a Docebo job candidate (“you,” or “the Candidate“) during the recruiting process for employment or internship opportunities, via the Docebo website, career portals or via our recruiting programs and events.

A reference to “Docebo”, “We” and “Us” means Docebo S.p.A. and/or any of its other corporate affiliates involved in the recruitment process.

This Privacy Policy explains how Docebo collects and uses your personal data and the choices and rights available to you about the collection and use of your information, including how to update and correct your personal data.

By submitting your personal information to Us, you acknowledge that you have read this Privacy Policy carefully and understood the use of your personal information. If you do not want your information processed in accordance with this Privacy Policy, please do not interact with Us.

If you are offered and you accept a role at Docebo, your personal data collected during the recruiting process will become part of your employee records and will be governed by the Docebo Employee Privacy Policy, which will be provided during the employee onboarding process.

WHAT INFORMATION WE COLLECT ABOUT YOU:

In this Policy any reference to ‘personal data’, ‘personal information’ or just simply ‘information’  is intended as any information that can identify or relate to you as individual person. We collect the following personal information from you as further described below:

(a) Information provided voluntarily by you (when you submit a job application or provide personal information during the interview process)

Contact information, such as name, personal email address, phone number, your photo, physical address, immigration status and related information (e.g. national ID, right to work, passport, visa status).

Professional and educational information, such as information more closely related to your qualification and professional level, work history, professional references, language capabilities, training records, résumé/CVs, references provided, background information provided or confirmed by academic institutions and training/certification providers.

Background check information (including criminal checks and checks against local or international sanctions lists), only to the extent required to assess your eligibility for the position and where permitted by the applicable law. In these cases, you may be contacted by a third-party provider to request authorisation for the disclosure of your information. At that time you will have with further information about the process and what personal data it might involve.

Docebo does not request Sensitive information (such as those suitable for revealing religious beliefs, political opinions,  trade union membership, health information or sexual orientation, racial or ethnic origin, or information relating to actual or alleged criminal history) from you unless permitted or required by local law (for example, to comply with equal opportunity laws, or to provide accommodations that you may request), or with your prior consent .

Any other information you may choose to share with Docebo.

(b) Information We receive from other sources

From time to time, We may receive information about you from:

  • other Docebo employees (e.g. who have referred you for a position);
  • external recruitment agencies or executive search agencies;
  • other individuals (including your current or past employer, coworkers for reference);
  • third-party providers for background or criminal checks, when required by the role; and
  • professional social networks (e.g. Linkedin), publicly accessible websites and job boards (e.g.  Lever) .

We will collect this information only where these third parties are legally permitted or required to share your personal information to Us.

(c) Information We collect automatically from you

Device information, including your information from your device when you visit our Docebo Career page, through cookies, web beacons and similar technologies. For more information on how We use these technologies and how to turn them off from collecting your information, please see our Cookie Policy.

HOW WE USE YOUR PERSONAL INFORMATION (AND IN THE EUROPEAN ECONOMIC AREA (EEA), SWITZERLAND AND UK, WHICH LEGAL BASIS WE RELY ON):

We collect and process personal information for a variety of purposes, including:

Type of personal information

Purposes

Legal basis (EEA, UK and Switzerland only)

Contact information

Professional and educational information

For recruiting purposes, to determine your suitability for a role and to make hiring decisions

Performance of a contract with you

Contact information

To inform you about potential future job opportunities

Your consent to process your data

Contact information

To assist you with obtaining an immigration visa or work permit, only when Docebo is able to sponsor you in that jurisdiction

To comply with a legal obligation

Docebo business legitimate interests

Contact information

Device information

To improve our recruitment process for future candidates

Docebo business legitimate interests

Sensitive information

To provide reasonable accommodations during the recruitment process

To pursue and monitor our initiatives on diversity and equal opportunity and comply with anti-discrimination laws

To comply with a legal obligation or, if required under applicable law, to the extent you have provided your prior consent

Contact information

Professional and educational information

To fulfill a referral request submitted as part of Docebo Referral program

Your consent to process your data

Contact information

Professional and educational information

Background check information

To perform pre-employment screening, including references and other individuals which can confirm professional and educational information about you, and background checks, where required

To comply with a legal obligation and for Docebo business legitimate interests

Contact information

To establish, exercise, or defend against legal claims

To comply with a legal obligation

A quick note on our use of automated assessment tools

In certain cases, such as when you are interested to join the Docebo R&D team, We may process your personal information with assistance of automated assessment tools. However, all decisions about your answers and results will always involve a review and/or intervention of a member of the Docebo team.

HOW WE SHARE YOUR PERSONAL INFORMATION:

We may share your personal information with the third parties listed below in the following circumstances:

Service Providers

We may provide your personal information to companies that provide services to the extent they are involved in your hiring process (e.g. recruitment agencies or background check providers). These companies are authorized to use your personal information only as necessary to provide these services to Us, in compliance with this Privacy Policy and appropriate data processing terms signed with them.

Affiliates and Subsidiaries

We may share the information We collect within the Docebo group of companies to the extent they are involved in your hiring process.

Legal Authorities

We may also disclose your personal data as required by law, such as to comply with a subpoena or similar legal process when We believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. Unless We are prohibited by law, We will notify you of any disclosure requirement.

● Potential parties involved in a business transaction

In case Docebo decides to merge with, or is acquired (entirely or partially) by another company, or sell some of the services provided or a business unit, your personal data might be disclosed, under conditions of confidentiality, to our advisers and any prospective purchaser’s advisers. In this case We will inform you, via email and/or a prominent notice on our website, of any change in ownership, use of your personal data, and choices you may have regarding your personal data.

● Others

We may also disclose your personal data to any other third party with your prior consent (e.g. when you connect Docebo Services with third-party integrations).

HOW YOUR INFORMATION IS KEPT SECURE:

The security of your personal information is important to Us.

We follow generally accepted security standards and We have adopted commercially reasonable security measures to protect your personal data against accidental or unlawful destruction, loss, alteration, or unauthorized disclosure or access. We may use third-party products and services to secure or store your information.

Depending on where you live, you may have a legal right to be notified in case of security breach. Overall, if you have any reason to believe that your interactions with Us are no longer secure, please notify Us immediately at privacy@docebo.com.

We may, subject to applicable law, transfer your information outside the country where you are located and to where information protection standards may differ (e.g. your information may be stored on servers located in other jurisdictions). We will utilise appropriate safeguards governing the transfer and usage of your personal information. See the following Section ‘How we transfer your data’ for further information.

HOW WE TRANSFER YOUR DATA:

Your personal information may be transferred to, and processed in, countries other than the country in which you are based, where Docebos ’affiliates, subsidiaries, partners or our third-party service providers operate.

Some of these countries might not offer an adequate level of protection and security. As a result, We take measures to ensure that your information is safe and protected in compliance with the applicable data protection laws, including:

  • if you are resident in the EEA, United Kingdom or Switzerland, relying on Standard Contractual Clauses (and/or UK International Data Transfer Addendum), to transfer your data outside the EEA, United Kingdom and Switzerland;
  • implementing organisational, contractual and technical security measures with our third-party service providers;
  • establishing an intra-group data transfer agreement for internal transfers of personal data within Docebo group of companies around the world.

HOW LONG WE KEEP YOUR INFORMATION:

We will retain your information for the time needed to fulfil the purposes described above, unless a longer retention period is required or permitted by law. This retention period is not always the same, but could vary depending on your location and the local legal requirements. Please contact Us to understand more how long we keep your details by using the information given under the “Contact us” section below.

After the expiration of the applicable retention period, We will either delete your information or, if this is not possible (for example, because the information has been stored in backup archives), We will securely store your information and isolate it from any further use until deletion is possible.

In case you do not want to remain in contact for future Docebo opportunities, or withdraw your consent regarding this purpose, We will promptly stop using your information collected for these purposes. However, We might keep a permanent record of the fact that you have asked Us not to process your information so that We can respect your request in future.

EXERCISING YOUR RIGHTS:

Regardless your location, you have the right to know if We process your data, to amend or update inaccurate or incomplete information about you, to request deletion of your personal data, or request that We no longer use it. You may submit a request for access (i.e. request information on personal data collected, used, disclosed or processed by Docebo) as well.

If you are a resident of EEA, United Kingdom or Switzerland you can also submit a request (i) for rectification, or (ii) to object to our processing of your personal data, or even (iii) to have your data available in a structured, electronic format (‘data portability’).

Where you gave Us consent to use your information for a specific purpose, you can ask Us to withdraw that consent, but this will not affect the lawfulness of any processing activity already taken place before your withdrawal.

In some circumstances, We might need to verify your identity and your relationship with Docebo before proceeding with your request for security reasons.

In order to exercise your rights described above and/or submit inquiries or complaints regarding our processing of your personal data, you can do so at any time by contacting Us using the information given under the “Contact us” section below.

If you believe that We have not been able to assist you with your requests, you have the right to lodge a complaint with your local competent supervisory authority (contact details for European data protection authorities for countries can be found here and for the United Kingdom here).

CHANGES TO THIS PRIVACY POLICY:

We may change all or part of our Privacy Policy from time to time to reflect our data collection practices, in case of new processes or tools involving your personal data, or as required by the law. Changes to our Privacy Policy will be effective immediately once published. We invite you to periodically review our Privacy Policy to be informed of any relevant changes, especially before providing any data to Us.

CONTACT US:

If you have any questions or concerns relating to our data protection practices, or wish to exercise any of your rights, please contact the hiring manager you worked with, or the privacy team at privacy@docebo.com or by mail at Docebo headquarter:

Docebo S.p.A.

Legal department

Via Parco 47 – 20853 Biassono (MB) – ITALY

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