LAST UPDATED: September 23, 2024
1. Overview
This Job Applicant Privacy Policy (“Policy”) sets out the manner in which KIK International LLC and KIK Holdco Company Inc. (collectively, “KIK”, “we” or “our”) collect, use, process, disclose, and store personal information provided to us in the course of applying for a role with KIK in Canada (except Quebec) or the U.S., in order to carry out our recruitment process.
This Policy may be modified by KIK from time to time in order to reflect changes in law, regulator guidance and KIK's own business needs. If you have any questions or concerns about the contents of this Policy, please contact privacyofficer@kikcorp.com.
2. What personal information we collect and why?
KIK may collect, use, disclose, store or otherwise process the following types of personal information relating to any applicant to KIK, whether in electronic, paper, or oral recorded format (“Personal Information”), for the purpose of carrying out our recruitment process, as required by applicable law in order to fulfill KIK's legal, regulatory or administrative obligations, for another purpose set out in this Policy, or for any other purpose for which KIK or its affiliates may otherwise be permitted under applicable law:
| Category of Personal Information | Specific Personal Information Collected, Used, or Disclosed | Purpose(s) for Collecting, Using, or Disclosing Personal Information |
| Identifying Information |
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| Recruiting Information | Information collected about a candidate for employment with KIK, including but not limited to
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| Pre-employment health data |
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In addition, our third party providers of background check services will disclose background check data including criminal records history and drug screening data they have collected to us. You will be requested to sign a consent form from such third party providers for such disclosure.
3. Disclosures
From time to time, we may need to disclose Personal Information we hold to relevant third parties in the following circumstances and for the stated purposes:
- For Compliance Purposes: We may share Personal Information between KIK entities or with one of our service providers that provides administrative or other services to us, such as the management of our email system, the processing of our data, or the hosting of our databases.
- Sale of KIK: Personal Information may be disclosed by KIK or one of our advisors or service providers to buyers or prospective buyers in connection with the sale of a part of or the whole of KIK or KIK's assets.
- Government or Regulatory Request: We may disclose specified Personal Information to third parties in response to a valid administrative or judicial order, including court orders, subpoenas and search warrants, or similar information requests from government authorities or in order to comply with the requirements of a regulatory body that governs any of our professional practices.
- Litigation: We may have to disclose Personal Information in order to establish or exercise our legal rights or to defend the rights, property, or safety of our organization or others; or in connection with litigation in response to a discovery request. This information may be disclosed by KIK or by the service provider or the entity that holds the Personal Information in its servers on behalf of KIK.
- Crimes: We may disclose Personal Information to a private or public investigator in order to detect or prevent criminal activities, fraud, material misrepresentation, or material nondisclosure.
- Advisors and Service Providers: We may disclose some Personal Information to KIK's legal, HR, and/or recruitment advisors as is required to efficiently proceed with the application process as well as to third party service providers that assist KIK in carrying out the purposes stated in this Policy.
4. Security
KIK takes commercially reasonable steps intended to maintain physical, procedural, and technical security in its offices, information systems, and information storage facilities in order to protect Personal Information from loss, misuse, unauthorized access, erroneous disclosure, alteration, or destruction. We restrict access to Personal Information to those individuals who need access to this information in order to assist us in performing our duties and obligations. We require all third party service providers that host or otherwise manage our information systems to safeguard the Personal Information they have access to.
KIK employees are required to keep all Personal Information strictly confidential, to access it only on a need to know basis, and not to use it or to disclose it to third parties other than as permitted under this Policy, an agreement, or as permitted or required by applicable law. Failure to do so will be regarded as serious misconduct and will be dealt with in accordance with KIK’s disciplinary policy and procedure.
5. Your rights
Candidates may ask for access to the Personal Information we hold about them or ask for the amendment, correction, or deletion of information that is demonstrated to be inaccurate or incomplete, to the extent permitted or required by applicable law. An applicant may also ask for a copy of the Personal Information that we hold about them, and may exercise other rights they hold with respect to their personal information under applicable law. Such requests should be made by contacting privacyofficer@kikcorp.com. We will review all reasonable requests for access within the time frames defined by applicable law. If you have any questions about your privacy rights, please do not hesitate to contact us at the address below.
6. Enforcement
- Monitoring: All information created, accessed or stored using the KIK’s computer and telecommunications systems is subject to monitoring, auditing and review in accordance with applicable law. Any Personal Information that is stored in KIK’s computers and telecommunication systems might be accessed through these monitoring activities by KIK’s employees who have been assigned to such tasks. The accessed Personal Information will not be used for any purpose other than such monitoring and any further internal or external investigation of potential misconduct, fraud or other wrongdoing uncovered through such monitoring.
- Training: We have procedures in place for training KIK employees in the implementation of this Policy.
- Updating: We will review and update this Policy periodically as needed.
- Inquiries: Any question, comment or complaint about this Policy, or with the collection, use, management, or disclosure of Personal Information by KIK should be directed to privacyofficer@kikcorp.com.
7. Storage, retention, and transfer of personal information
Candidate Personal Information will be stored or transferred to KIK's corporate facilities, or to service providers, in Canada and the United States as applicable. We take measures to ensure that recipients in other jurisdictions (i) provide an adequate level of protection; and (ii) will not use your Personal Information for purposes other than those described in this Policy.
We retain Personal Information and dispose of it in accordance with our records management policy or agreements, as applicable, and in accordance with applicable laws.
8. Candidates in California
The additional disclosures in this Section 10 apply only if you reside in California. These disclosures do not reflect our practices where an exception or exemption applies under the California Consumer Privacy Act ("CCPA"). Please see Section 2 above for information about the categories of personal information that we collect from candidates. These categories correspond with the following categories under the CCPA's definition of "personal information" and "sensitive personal information" (in the following bullets, a "consumer" means a candidate residing in California):
Personal Information:
- Identifiers such as a real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, driver's license number, passport number, or other similar identifiers.
- Any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, physical characteristics or description, address, telephone number, passport number, driver's license, insurance policy number, education, employment, employment history, bank account number, credit card number, or any other financial information, medical information, or health insurance information, but excluding publicly available information that is lawfully made available to the general public from federal, state, or local government records.
- Characteristics of protected classifications under California or federal law.
- Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer's interaction with an internet website application, or advertisement.
- Geolocation data.
- Audio, electronic, visual, or similar information.
- Professional or employment-related information.
- Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).
- Inferences drawn from any personal information to create a profile about a consumer psychological trends.
Sensitive Personal Information:
- A consumer's social security, driver's license, state identification card, or passport number.
- A consumer's account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.
- A consumer's precise geolocation.
- A consumer's racial or ethnic origin, religious or philosophical beliefs, or union membership.
- The contents of a consumer's mail, email, and text messages unless the business is the intended recipient of the communication.
- Personal information collected and analyzed concerning a consumer's health.
We do not sell or share for cross-context behavioral advertising any of the personal information that we collect about California candidates. We do not use candidates’ sensitive personal information to infer characteristics about them and only use sensitive personal information for purposes referred to in Subsection 1798.121(a) of the CCPA, including:
- To perform the services or provide the goods reasonably expected by applicants in their role as candidates, including those services and goods that are reasonably necessary for us to administer the recruitment process;
- To detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information, including in or via our premises, computers, software, networks, communications devices, and other similar system;
- To resist malicious, deceptive, fraudulent or illegal actions directed at us and to prosecute those responsible for those actions;
- To ensure the physical safety of natural persons;
- To verify or maintain the quality or safety of our services and products; and
- To perform functions that are required under laws that apply to us.
Our CCPA Privacy Policy is available at here.
9. Contact information
Any candidate can contact us at any time if they have questions or requests with respect to the contents of this Policy or any matters related to KIK's handling of their personal information. Please feel free to contact privacyofficer@kikcorp.com.
