Creatopy Candidate Privacy Notice

Last Updated: August 14, 2025

1. Introduction.

We respect the privacy rights of individuals and are committed to handling personal information responsibly and in accordance with applicable law. It is important that you read this Notice carefully as it sets out how Creatopy Inc. and its affiliated entities ("Creatopy", "we", or "us") handle your personal information when you apply for a position with us and the rights you have in connection with that information.

This notice applies to your job application, but it does not form part of any employment contract.

When you visit the Careers section of our website, we may collect certain information automatically from your device. How we collect, use, and disclose this information is covered in Creatopy’s main Privacy Policy, which applies to the use of our website. This Notice does not apply to the general use of our website.

2. What information do we collect?

We collect personal information that is necessary and relevant to evaluate your application and manage our recruitment process. This information may be collected directly from you when you apply, from third-party sources such as professional recruiting firms or background check providers, or from publicly available sources. As part of our recruitment process, we only collect personal information that’s necessary, relevant, and appropriate for evaluating your application. Here's what that includes:

a) Identifiers and Contact Information: To identify and communicate with you, we may collect the following information: full name, gender, and nationality/citizenship, date and place of birth, personal identification number (e.g., CNP or Social Security Number, passport or government-issued ID details), residential addresses (both permanent and temporary), phone number(s) and email address, your signature.

b) Professional and Academic Background: To understand your qualifications and experience, we may collect: your resume (CV), cover letter, or any submitted application materials, educational history, degrees, certifications, or diplomas, details about your previous and current employment, including job titles and responsibilities, references or recommendation letters, licenses or memberships in professional organizations (if applicable).We may collect information provided by referees as part of verifying your qualifications and work history. This includes contact details and professional information of individuals you've listed as references

c) Recruitment Assessment Data: To evaluate your fit for the role, we may use: results from aptitude or technical tests (e.g., coding challenges), as well as panel or team assessments, internal notes or feedback from interviewers, and documents used to verify your employment eligibility. We may use interview recording and transcription tools that capture audio and/or video content for assessment and note-taking purposes. We seek separate permission before recording.

d) Publicly Available and Online Information: We may review public content related to your professional profile, such as: LinkedIn or other professional social media profiles, public portfolios or project platforms (like GitHub, Behance, etc.), data from recruitment platforms or vendors (e.g., BambooHR, Glassdoor, ZipRecruiter).

Sensitive Personal Information

Creatopy does not typically require you to share sensitive personal information, such as details about your race, ethnic background, religion, health status, or sexual orientation, during the recruitment process.

However, in certain situations, we may request or receive such information on a voluntary basis, and only when necessary for legitimate recruitment-related purposes. For example, we may collect data about your disability status to, comply with anti-discrimination laws, or fulfill government reporting obligations. We may also ask for information about any physical or mental health conditions to arrange reasonable accommodations during the application or interview process.

If you choose to share any other sensitive information with us, it will be handled in accordance with applicable privacy laws and only with your explicit consent, where required.

We handle all this information responsibly and only use it to support the recruitment process. If you have any questions or want to learn more about how we protect your data, feel free to reach out.

3. Why Do We Use Your Information and What is Our Legal Basis?

We use your personal information to determine if you are a good fit for the role and to manage the hiring process. This includes:

a) Assessing your application and qualifications for the role.

b) Communicating with you about your application and scheduling interviews.

c) Verifying your information and conducting reference checks.

d) Complying with legal obligations, such as immigration and anti-discrimination laws.

e) Considering you for future roles that may be a good fit, if you agree to it.

If you are hired, the information collected during recruitment will become part of your employee record and will be governed by our employee privacy notice.

We only process your personal information when we have a valid legal reason to do so under data protection laws.

These are the main reasons we rely on:

a) To Take Steps Toward an Employment Contract: We need to use your personal data to assess your application, communicate with you during the hiring process, and decide whether to offer you a job. This is necessary for us to potentially enter into a contract of employment with you.

b) Our Legitimate Interests: We have a genuine interest in running a smooth and effective recruitment process. This includes things like organizing interviews, reviewing applications, and managing candidate records. We always make sure that this interest doesn’t override your privacy rights.

c) To Meet Legal Requirements: Sometimes, we’re legally required to process your data, for example, to comply with employment laws, equal opportunity requirements, or other relevant regulations.

d) With Your Consent: In certain situations, we’ll ask for your explicit permission, for example: If we’d like to keep your application on file for future job openings or if we need to process sensitive information (like health data) for accessibility or accommodation purposes. You can withdraw your consent at any time.

Accuracy of Information

We rely on the information you provide during the application process to evaluate your candidacy. Providing false or misleading information in your application may result in disqualification from the recruitment process or, if discovered after hiring, may lead to disciplinary action up to and including termination of employment. By submitting your application, you confirm that all information provided is complete, accurate, and truthful to the best of your knowledge.

4. Who do we share your information with?

Your information is shared only with those who need it for the recruitment process. This includes:

a) Internal Teams: Hiring managers and other relevant team members at Creatopy Inc.

b) Our Group Company: We may share your information with other companies in our corporate group to assist with recruitment and administrative functions

c) Service Providers: We use third-party vendors for things like our HR platform , background checks, and communication tools . We have data processing agreements with these vendors to ensure they protect your data.

d) Legal Authorities: If required by law.

e) Change Ownership or Control: We may also share your personal information to another company as part of a merger, acquisition, divestiture, restructuring, reorganization, or other sale or transfer of some or all of our assets to that company.

A note on CCPA:We do not “sell” or “share” your personal information as defined by the CCPA. The information you provide during your application is used solely for the recruitment and hiring purposes outlined in this notice.

5. International Data Transfers

By applying for a role, your personal data will be collected by and transferred to Creatopy Inc. in the United States.

For our recruitment process, your data may be accessed by our teams and service providers in other countries, including by our processor, Creatopy SRL, in Romania. We use legally-approved safeguards to protect your data when it is transferred internationally, such as:

a) Standard Contractual Clauses (SCCs).

b) Data processing agreements with our group companies and vendors that require them to protect your data.

6. How long do we keep your information?

We only keep your data for as long as we need it.

a) If your application is unsuccessful, we will retain your information for up to 6 months after the process ends to address any legal requirements.

b) If you consent to be in our talent pool, we will keep your information for up to 2 years to contact you about future opportunities.

c) If your application is successful, your data will be retained as part of your employee file in line with our employee data retention policies.

7. Your Privacy Rights

We believe in giving you control over your personal information. Depending on where you live, you may have the right to make the following requests about your data.

a) Access and Know: You can ask for a copy of the personal information we hold about you and request details about how we collect, use, and share it.

b) Correct Your Information: You can ask us to fix any inaccurate or incomplete information we have about you.

c) Delete Your Information: You can request that we delete your personal information, subject to certain legal exceptions.

d) Object to or Restrict Processing: You may have the right to object to our processing of your personal data, ask us to limit how we use it, or opt-out of your information being "sold" or "shared." You can also ask to limit the use of your sensitive personal information.

e) Take Your Information With You: You may have the right to receive your personal information in a structured, machine-readable format.

f) Withdraw Your Consent: If we process your information based on your consent, you can change your mind and withdraw that consent at any time.

g) Fair Treatment: We will not treat you differently for exercising any of your privacy rights.

h) Lodge a Complaint: You may have the right to file a complaint with your local data protection authority if you have concerns about how we handle your information.

To exercise these rights, please contact our data controller, Creatopy Inc., using the details below. Alternatively, if you are located in the European Economic Area (EEA) or the UK, you may direct your request to our EU representative, Creatopy SRL, whose details are also provided below.

Regardless of which entity you contact, we may take reasonable steps to verify your identity before responding to a request. Please note that certain information may be exempt from such requests under applicable law. For example, we may need to retain certain data to comply with our legal obligations. You will not be discriminated against for exercising your privacy rights.

8. Contact Us

If you have any questions or would like to exercise your privacy rights, feel free to reach out to us using the contact details below.

Creatopy Inc - Data Controller

Address: 490 Post St Ste 500 PMB 2080 San Francisco, CA 94102 United States

Email: privacy@creatopy.com

For individuals located in the European Economic Area (EEA) or the UK:

Creatopy SRL - EU representative

Address: Trade Center Building, 28E Nufarului St, 4th floor, 345 Oradea, Bihor County, RO 410583

Email: dpo@creatopy.com

We may update this notice from time to time. The latest version will always be available on our Careers page.