Effective Date: July 1, 2024

Last Revised: July 15, 2024

OUR COMMITMENT TO PRIVACY

DIVVIA (“we”, “our”, “us” or the “Company”) is committed to maintaining the security, confidentiality and privacy of your Personal Information. This Applicant Privacy Notice (“Notice”) has been developed in compliance with applicable privacy legislation. In the event of a conflict between this Notice and applicable law, the legislation will govern.

APPLICATION

This Notice applies to the Company in ‎respect of the collection, use, disclosure and retention of Personal Information as part of the application and recruitment process in Canada. This Notice does not apply to the collection, use or disclosure of personal information of Company employees.

DEFINITIONS

“Business Contact Information” means information to enable an individual at a place of business to be contacted and includes the name, position name or title, duties, business telephone number, business address, business email or business fax number of the individual.

“Personal Information” means any information about an identifiable individual and includes Employee Personal Information but excludes Business Contact Information.

NOTICE

Why does the Company collect, use or disclose Personal Information?

The Company collects, uses and discloses Personal Information reasonably required for the recruitment process in accordance with applicable law. This includes, but is not limited to, the following purposes:

• to make decisions about hiring (including ‎employment history, ‎reference checks, background checks or criminal record checks (where permitted by applicable law)), academic history‎, promotions, ‎transfers, assignments, rewards, recognition, ‎incentives, remuneration ‎and termination of employment);
• to verify information provided by or about the candidate;‎
• to administer the relationship with Company clients (“Clients”) and meet the contractual and business obligations of the Company and its Clients;
• to manage and protect Company assets and property;
• to assist the Company in any dispute involving the Company and/or a Client and or/an employee, including with respect to bringing or ‎defending against complaints, claims or litigation;‎
• to investigate, manage and address legal matters such as harassment complaints, unlawful behaviour, criminal behaviour, fraud, civil claims, ‎and insurance matters;
• ‎to provide information to third parties in connection with transactions that we ‎contemplate or ‎carry out;‎
• generally, to manage the application and recruitment process; and
• as otherwise required or authorized by applicable law.

You have the right to withdraw your consent to the communication or use of your Personal Information. However, if you withdraw your consent, the Company will not be able to continue with the application process.

What type of Personal Information does the Company collect, use or disclose?

Personal Information collected, used or disclosed by the Company for the purposes referred to ‎above may include some or all of the following:

• Name, home contact information;
• Application for ‎employment, resume, covering letter, letters of reference, interview notes, ‎background or criminal record checks and reference checks;‎
• Employment status and history, including positions held, ‎evaluations, performance reviews, discipline, promotions/demotions, and awards or ‎commendations earned;‎
• Information about medical conditions or disabilities for the purpose of accommodation during the application process;
• If an offer of employment is made, date of birth, Social Insurance ‎Number (for income tax purposes), and benefits information, including information about spouses and ‎dependents (for benefits purposes);‎
• Other information required to administer the application process.

Where does the Company disclose Personal Information?

The Company may from time to time use third party service providers (“Service Providers”) for administrative and technical purposes and to store and maintain Company records which may include applicant Personal Information. Service Providers used by the Company to store or process Personal Information for the purposes described in this Notice may be located in jurisdictions outside of your province of residence or outside of Canada, and applicable laws in those ‎jurisdictions might permit foreign governments, courts, law enforcement or ‎‎‎regulatory agencies to ‎access, use or disclose the information in those jurisdictions.‎

The Company may also disclose Personal Information where required or permitted by law, including to law enforcement agencies, industry associations or regulatory bodies.

Retention

We will keep Personal Information used to make a decision affecting you for at least one year after using it to make the decision.

We will destroy, erase or make anonymous (to the extent permitted by applicable laws) documents or other records containing Personal Information as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the information and retention is no longer necessary for a legal or business purpose.

We will take due care when destroying Personal Information so as to prevent unauthorized access to the information.

Accuracy, Access and other Rights

In addition to any other rights outlined in this policy, you may, depending on your jurisdiction of residence, have the following rights:

Right to correct inaccurate information

We will make a reasonable effort to ensure that Personal Information we are using or disclosing is ‎accurate and complete. In some cases, we rely on you to ensure that certain information, such as your ‎address, telephone number and emergency contact information is current, complete and accurate.‎ If you demonstrate the inaccuracy or incompleteness of your Personal Information, we will amend the ‎information as required. If appropriate, we will send the amended information to third parties to whom ‎the information has been disclosed.‎

When a challenge regarding the accuracy of Personal Information is not resolved to your satisfaction, we ‎will annotate the Personal Information under our control with a note that the correction was requested but ‎not made.‎

Right to access

You may have a right to access your Personal Information held by the Company, subject to your jurisdiction of residence. Upon written request to the Company at [email address], we will provide you with access to your Personal Information under our control, information about the ways in which that information is being used and/or a description of the individuals and organizations to whom that information has been disclosed, as required by applicable law. The Company reserves the right to charge a reasonable fee for the reproduction or transmission of such information where permitted and in accordance with applicable law.

Where an access request is refused, we will notify you in writing, document the reasons for refusal and outline further steps which are available to you.

Right to data portability

You may have the right to obtain a machine-readable copy of your Personal Information or ‎‎to ‎‎have us transfer it to another third party of their choice.‎

Right to de-indexation

You may, in certain circumstances, have the right to request that we cease disseminating ‎your Personal Information or to ‎de-‎‎index any hyperlink that allows access to that Personal ‎Information by ‎‎‎‎technological means, if ‎‎such dissemination contravenes applicable law or a ‎‎court.‎

How does the Company protect Personal Information?

The Company protects the Personal Information in its custody or control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks.

QUESTIONS

Any questions or complaints regarding the privacy-related aspects of this Notice should be directed in writing to The Company’s Privacy Officer at: privacy@divvia.ca

If your question or concern relates to recruitment or human resources matters, please contact human resources at: hr@divvia.ca.

CHANGES

This Notice is subject to amendment from time to time.