Aurora Labs - Privacy Policy

Last updated 04.10.2022

Introduction

We, at Aurora Labs, may collect, use, share and store the personal data of:

users in relation to their visit to our website: https://auroralabs.dev/ (the “Website”);
other persons (potential employees and contractors) during the application and recruitment process.

This Privacy Notice (the “Notice”) applies to the personal data collected and processed by Aurora Labs during any interactions with the Website, including job applications via the Website, or job applications on other third-party services (collectively, “Interactions” or “Services”). Additionally, we may collect and process your personal data from the following publicly available sources, provided collection of the data is necessary and relevant to the performance of the job which you apply for and provided we are allowed to do so by national laws: LinkedIn, Facebook, Twitter and other social media platforms/Google.
This Notice describes the categories of personal data that we collect, how we use your personal data, how we secure your personal data, when we may disclose your personal data to third parties, and when we may transfer your personal data outside of your home jurisdiction. This Notice also describes your rights regarding the personal data that we hold about you including how you can access, correct, and request the erasure of your personal data.
We will only process your personal data in accordance with this Notice unless otherwise required by the applicable law. We take steps to ensure that the personal data that we collect about you is adequate, relevant, not excessive, and processed for limited purposes.
The personal data that we collect, use, share, and store is mandatory in connection with our recruiting activities. Failure to provide or allow us to process mandatory personal data may affect our ability to accomplish the purposes stated in this Notice.

Personal Data collected by Aurora Labs

We, at Aurora Labs, may collect certain personal data directly from you as well as from other available sources to the extent relevant and permitted by applicable local law. The categories of personal data that are typically collected and processed in the recruitment context are:
Data that is collected automatically
When you visit our Website or perform any other Interactions with the Website, we automatically gather certain basic information that most websites do, subject to your consent, when necessary. This is information that we gather from all visitors of the Website, regardless of whether they perform any Interactions with the Website or not. We use this personal information for Website session data and local storage management. This includes information about:

how you use the Website, such as the pages you visit;
your IP address;
the date, times, and frequency with which you access the Website;
your operating system;
information about your browser;

Data that is given to us by you
When you submit a job application form, Aurora Labs, as the data controller, collects certain information that identifies you or could reasonably be used to identify you, and that is recorded in any form. Depending on the content provided, we may obtain the following personal data:

name, gender, address, personal and/or business telephone number, personal and/or business email address, date of birth, and other contact details; competencies, skills (including cognitive abilities and language speaking abilities as a result of any assessments carried out during the recruitment process), experience and education, e.g. your CV or resume, previous employments, educational details and qualifications, third-party references;
languages are spoken, citizenship, and nationality to enable us to check your suitability for a specific role and working location;
preferences, e.g. preferred country of employment, areas of interest as well as your preferred ways to be contacted by Aurora Labs);
your online user identity, e.g. usernames and other such information used in connection with authenticating you to our online recruitment management system;
technical Information: when you access our services online, our web servers automatically create records of your visit;
information collected during interviews: As part of our interview process we may maintain audio/video records of the interview (in case of telephone interviews or video-enabled interviews) as well as comments noted by our interviewers;
information collected from online assessments proctoring: as part of the recruitment process we may ask you to take certain tests which are necessary for assessing your suitability for a certain position. In such cases, we may also collect snapshots and/or audio/video recordings of you to ensure that the integrity of the tests is maintained. No biometric data will be collected from you.
other information, such as information found from public sources as well as information related to reference checks, depending on the position you are applying for, and where necessary for the recruitment activities;
additionally, once you have been shortlisted, we may collect additional information such as a copy of your Government ID, the expectation of compensation and remuneration details, information relating to your family members (for benefits administration), passport, visa, and work permit (in case of expatriate), background check reports including educational, employment and criminal checks, etc. as permitted under applicable laws. Also, in certain cases, we may collect your bank account details, details of the expenses incurred, and relevant bills to reimburse any expenses incurred by you during the interview process.

We collect this information in order to better understand the qualification and requirements of each person who submits a job application.
This information will be collected by us in a number of ways through multiple channels during the recruitment process and over time during our relationship with you:

directly from you (when you apply online or via email);
through referrals from your friends, a family of professional connects who work at/with Aurora Labs;
from third-parties (through recruitment agencies and background verification agencies), which may also include public sources such as professional networking platforms.

Legal grounds for collecting Personal Data

We are required to warn you about the legal basis on which we treat your personal data. We shall treat your personal data legitimately, fairly, and transparently. We only gather and process information about you when we have a legal basis to do so. These legal grounds depend on your use of the Website, meaning we collect and use your information only when:

Performance of an agreement. It is required for the performance of an agreement to which you are a party or to take steps at your request prior to entering into such an agreement.
Legitimate interest. It serves a legitimate interest (that is not outweighed by your data protection interests), such as research and development, marketing and promotion of our activities, and protection of our legal rights and interests.
Consent. You give us permission to collect and use your personal data for a specific reason.
Legal obligation. Aurora Labs needs to process your personal data to comply with a legal obligation.

The purpose of collecting your personal data

Aurora Labs uses and collects your personal data for the following purposes:

User Assistance. Aurora Labs uses and collects your personal data in order to communicate with you for providing customer service and, if necessary, provide our feedback on job applications.
Website Development. In order to optimize your user experience, we may use your personal data to operate, maintain, and improve our Website.
Encouraging Legitimate Interests. Generally, We process personal data for the purposes of our legitimate interest, for example, for legal compliance purposes, regulatory, or other corporate governance requirements, security purposes, submitting reports as required by applicable laws or regulations, to comply with our legal obligations, and resolve any disputes that we may have, or to maintain the ongoing confidentiality, integrity, availability, and resilience of the Website and Interactions.
Identifying and evaluating job applicants. Identifying and evaluating your job application, including assessing skills, qualifications, and interests for the purposes of determining suitability for the position for which you have applied.
Verifying your information. Verifying your information and carrying out employment, background, and reference checks, where applicable, subject to your consent where required by applicable law.
Communicating. Communicating with you about the recruitment process and your application.
Keeping records. Keeping records related to our hiring processes, for only as long as appropriate under the circumstances. In addition to using your personal data for the position for which you have applied, we may retain and use your personal data to inform you about and consider you for other positions that may be appropriate for you with your consent.
Marketing purposes. Sending you emails and messages about new features, products and services, and content.
Securities. By collecting your personal data, we safeguard the Interactions from being abused from any spam attacks, or fraud. To ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution. The legal ground of this is the Terms of Use and Legitimate interest.
We will only process your personal data for the purposes we collected it for or for compatible purposes. If we need to process your personal data for an incompatible purpose, we will provide notice to you and, if required by law, seek your consent. We may process your personal data without your knowledge or consent only where required by applicable law or regulation.
We consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of this information, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements when determining the appropriate retention period for personal information.

Data retention

Retention of data that is collected automatically
We will only hold your personal data on our systems for the period necessary to fulfill the outlined purposes. The personal data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. The collection of such data is absolutely necessary for the operation of the Website and conducted on the basis of the performance of an agreement to which you are a party and safeguard a legitimate interest of our company.
Retention of data that is given to us by you
All your personal data that is given to us by you directly will be deleted:

in two years or sooner if Aurora Labs will not need this information to pursue any legitimate purpose; or
if you request the deletion of your personal data.

Under some circumstances, we may anonymize your personal data so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
If you are offered and accept employment with Aurora Labs, 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 our employee personal data policies. If you do not become an employee, or, once you are no longer an employee of Aurora Labs, we will retain and securely destroy your personal data in accordance with the applicable laws and regulations.

Who do we share User’s Personal Data with

We use certain third-parties to facilitate the usage of our Website and meet legal and regulatory requirements relevant to Aurora Labs. Such third-parties may use your personal data in delivering their services to us or comply with regulatory requirements. The third-parties may be the following:
Database services. Aurora Labs may share the information collected about you with database services providers in order to properly and securely retain your personal data.
Service providers. Your personal data can be shared with service providers to help us analyze how you and other users perform Interactions in order to improve the Website’s functionality. We may employ third-party companies and individuals to facilitate the Interactions and assist us in analyzing how our Website is used.
Auditors and lawyers. Aurora Labs may transfer your personal data to auditors, accountants, and lawyers in order to complete financial, technical, and legal audits, as well as for other legal requirements.
Affiliates. Any of our group companies or affiliates.
Supervisory authorities. Aurora Labs may be required to share your personal data with supervisory authorities, law enforcement agencies, or government officials. We will only do this if we are required to do so by law or a formal request, if it is necessary to prevent physical injury or financial loss, or if we are required to report illegal activity.
In addition, Aurora Labs may also engage third-party service providers, such as recruitment agencies/search firms and providers of recruiting software and applicant tracking system, with whom Aurora Labs contracts as part of its normal business operations to carry out recruitment-related functions. Aurora Labs diligently selects such service providers and enters into written agreements with them ensuring that such providers (i) have adopted adequate data protection and security measures to safeguard your personal data; (ii) only use your data as instructed by Aurora Labs and for no other purposes; and (iii) store your personal data only within the terms of the agreement.
Other cases of sharing your data. We may also disclose your personal data for the following additional purposes where permitted or required by applicable law:

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 protect the rights and property of Aurora Labs in any claims and courts.
During emergency situations or where necessary to protect the safety of persons.
Where the personal data is publicly available.
If a business transfer or change in ownership occurs and the disclosure is necessary to complete the transaction. In these circumstances, we will limit data sharing to what is absolutely necessary, and we will anonymize the data where possible.
For additional purposes with your consent where such consent is required by law.

Securing your Personal Data

Aurora Labs uses appropriate administrative, technical, personnel, and physical measures to protect your personal data. All electronic data are kept secure on corporate drives with only select authorized individuals having access to the information. Your personal data are also protected through confidentiality undertakings entered into by all persons processing your personal data.

Rights of the Users

Right to withdraw permission. You have the right to withdraw your permission if you have consented to the processing of your personal data. Please keep in mind that even if you choose to withdraw your consent, we may be allowed to continue processing your personal data to the extent required or permitted by law.
Right to object to the processing of your personal data. You have the right to object to the processing of your personal data if the processing is carried out on a legal basis other than consent. You may object to such processing by providing a ground related to your particular situation to justify the objection.
Right to gain access to your personal data. You have the opportunity to learn whether your personal data is processed, to receive disclosure about specific aspects of the processing, and to seek a copy of the data being processed.
Right to verify and seek rectification. You have the right to verify the accuracy of your personal data and ask for it to be updated or corrected.
Right to have your personal data deleted or otherwise removed. You have the right, under certain circumstances, to obtain the erasure of their data, unless the processing is justified by our legitimate interests, necessary to fulfill a legal obligation, for reasons of public interest, or to assert, exercise, or defend legal claims.
Right to make a formal complaint. Users have the right to file a complaint with their competent data protection authority (depending on their residence and the applicable data protection legislation).

Cross-border Personal Data processing

The personal data that Aurora Labs collects may be stored and processed and transferred between any of the countries in which Aurora Labs operates to enable the use of the information in accordance with this Notice. You agree to such cross-border transfers of personal data.

Minors

Our Website and Interactions are not intended to appeal to persons under 18 years old. We will take appropriate steps to delete any unauthorized private information of a child that has been collected if it is discovered that such has been inadvertently collected. You understand that you must be at least 18 years old to perform any Interactions.

Third-party intervention

You are aware of the links contained on the Website which belong to third parties and not to Aurora Labs. We are not responsible or liable for third-party policies and terms of processing your personal data.
The Website may, from time to time, provide links or references to other websites. We have no control over such websites and are not responsible for the content of these websites. This Notice does not extend to your use of such websites. You are advised to read the privacy notices or statements of other websites prior to using them.

General

Transfer rights. You may not transfer any of your rights under this Notice to any other person. We may transfer our rights under this Notice where we reasonably believe your rights will not be affected.
Unenforceable Provisions. If any court or competent authority finds that any provision of this Notice (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Notice will not be affected.
Right of remedy. Unless otherwise agreed, no delay, act, or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
How to complain. The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority. The supervisory authority in Gibraltar is the Gibraltar Regulatory Authority which may be contacted at info@gra.gi or by telephone: (+350) 20074636.

Read this Privacy Notice

Before using our Website and performing any Interactions, Aurora Labs recommends reading this Notice carefully and completely in addition to, our Terms and Conditions, and Cookies Policy available on the Website. If you do not agree with this Notice, then you should refrain from performing any Interactions.

Updating the Policy

We reserve the right to amend or update this Notice at any time. Whenever these changes are made, an updated complete version and/or consolidated version of the Notice will be uploaded to the Website.

Contact

Aurora Labs is the controller of data for the purposes of GDPR. If you have any questions, we advise you to contact us immediately, using the following e-mail: support@aurora.dev