‍Purpose of this document

This Job Applicants Privacy Notice (the “Privacy Notice”) applies to all prospective talent and job applicants at Fonoa, and tells you how Fonoa Technologies Limited (“Fonoa” or “we”) processes your personal data.

Fonoa is committed to protecting the privacy and security of all personal data we process. We want to be transparent about how we collect and use any information which concerns you. We have prepared this Privacy Notice in accordance with the General Data Protection Regulation (the “GDPR”).

In brief, this Privacy Notice explains what personal data about you we hold, why we process it and what legal grounds allow us to do so. It clarifies how we receive the information, who gets to see it and how long we keep it. It also explains your rights, such as access to your personal data.

It is important that you take the time to read this Privacy Notice carefully so that you are aware of how and why we are using your personal data, and what rights you can exercise.

Please get in touch with us if you have any concerns related to our privacy practices by sending an email to gdpr@fonoa.com.

What we mean by “personal data” and “processing”

“Personal data” is information relating to you (or from which you may be identified) which is processed by automatic means or which is (or is intended to be) part of a structured manual filing system. It includes not only facts, but also intentions and opinions about you.

"Processing" means doing anything with the personal data.  For example, it includes collecting it, holding it, disclosing it and deleting it.

Personal data – what we hold, why and on what grounds

We collect candidates’ data as part of our talent sourcing programme and during the recruiting process (application, interviews). This is necessary for our hiring decisions. This section of the Privacy Notice explains what types of personal data we process, why we need this information and how that is lawful.

Talent sourcing programme

As part of our talent sourcing programme, we obtain information about prospective recruits from LinkedIn or other publicly available professional networking platforms and social media. This applies to you if we got in touch with you to ask if you would like to be considered for a position.

When processing personal data in this way, we make sure processing is carried out in accordance with the platform terms and your privacy settings.

Information we collect in this way includes:

• links to your profile at LinkedIn and other professional networking platforms, your professional pages (if any) and social media accounts;
• your educational and professional background from publicly available sources that we believe is relevant to your potential application (primarily information available on your LinkedIn profile); and
• your email address if accessible to us through publicly available sources or by using professional recruiting tools.

The purpose of collecting information in this way is to proactively conduct research about your educational and professional background and skills, and to contact you if we think you would be suitable for a role with Fonoa.

Fonoa can process personal data in this way since we have a legitimate interest in sourcing talent. This will be limited to information which is accessible to us through publicly available sources.

Application and selection process

If you apply for a position at Fonoa (by sending us an application or by telling us you want to be considered), we will primarily process your personal data to assess your skills, experience and suitability to join us. We will also use your contact details to communicate with you regarding the recruitment process and to inform you on any related news.

Fonoa collects and processes the following types of personal data in connection with our application and selection process:

• contact details, such as your name, home address and email address;
• your personal CV and cover letter;
• further information relating to your academic background and qualifications, your career (including your job history), and your professional and personal competencies and skills;
• any other information you submit to us as part of the application or selection process, such as compensation history (to the extent you voluntarily disclose this information) and your personal situation;
• your expected salary and other job preferences you might have;
• information on your ability to work remotely, your expected place of work and any specific requirements in this regard (including status of a work permit if required for your place of work);
• your responses to questions we ask you in the application form or later during the selection process (may vary depending on the role);
• information from interviews, including any phone or video conversations with you (may be recorded and transcribed)
• Any other information collected during the recruitment process, for example during any assessments or aptitude tests we ask you to participate in;
• information about your educational and professional background from publicly available sources (e.g. information available on your LinkedIn profile); and
• links to your profile at LinkedIn or other professional networking platforms, as well as links to your professional pages (if any).

Our processing of your personal data is based on our legitimate interests in managing the selection process and making an appropriate employment offer.

We also need to process this information to decide whether to enter into a contract of employment or other type of engagement with you (i.e., to take steps prior to entering into a contract with you). In limited cases, we may also need to process information about you so that we can respond to and defend ourselves against legal claims.

We may also use some of the data obtained from you or relating to you to conduct data analytics, or to monitor, test, and enhance the effectiveness of our recruiting processes and tools, or to identify trends in market conditions and hiring practices. However, if we engage in such practices, your data will always be anonymized and it will not be possible to identify you.

Before you join Fonoa

If you are offered and accept a position with us, the information collected during the application and selection process will become part of your employment record.

However, if you will be joining Fonoa, we will also need to process some additional information about you.

First of all, we carry out a background check on all our new joiners. We use a third party to carry out these searches, which, depending on your role, will include some or all of the following: (i) criminal records, in compliance with the legislation of the country where you are based, (ii) education, (iii) previous employment; (iv) corporate affiliations (any directorships, shareholdings or appointments), (v) professional qualifications, (vi) public profile. 

We have a legitimate interest to carry out these verifications, due to our contractual obligations, as well as to perform due diligence over all employment at Fonoa. As part of the background check process, you may also be asked to provide your consent or acknowledgment directly to our third-party provider. This enables the provider to carry out the checks in accordance with their procedures and applicable legal requirements.

Secondly, if you are offered a position, we may need further information from you if necessary for entering into a contract of employment or engagement or in order to comply with legal obligations. This may include:

• your eligibility to work in the relevant country, your identification documents and immigration status (we collect such information only where we need to ensure you are entitled to work);
• information listed in your offer letter and your contract with Fonoa, including your future salary and other benefits, your bank account details and other information which are or will be necessary for performing our contract with you; and.
• Information on your dependants, if added to benefits programs.

Finally, accepting a position at Fonoa means that you will be entitled to receive the equipment necessary to conduct your work and perks such as swag and seasonal gifts. To provide these to you as soon as possible, we will need your contact details and delivery address.

We will provide more information about our data processing at work in our Workplace Privacy Notice.

Unsuccessful applications

We do not process your personal data for any other purposes other than those listed above. However, if your application is unsuccessful, we may retain and process your personal data for the period determined by our data retention policy

Sensitive categories of personal data

Unless specifically responding to a question we ask, please do not include sensitive data in your application, such as information relating to your racial or ethnic origin, political opinions, religious beliefs, trade union membership, health status, sexuality, or information regarding criminal convictions.

We normally do not process such information. However, there are limited cases in which we may need to process certain types of sensitive personal data:

• For applicants in the United States, we may ask you to voluntarily provide demographic information (such as gender, race or ethnicity, veteran status or disability status) in accordance with Equal Employment Opportunity Commission (EEOC) requirements. This data is entirely optional, provided on the basis of your consent, and used only in anonymized and aggregated form for statistical and compliance purposes;
• If you are offered a position at Fonoa, our third-party background check provider may collect and process limited sensitive personal data, such as information relating to criminal records, where necessary to complete pre-employment screening in line with applicable laws. You may be asked to provide specific confirmations or acknowledgements directly to the provider as part of their process.

Where we do process sensitive personal data, we will ensure that any such processing is carried out in accordance with applicable data protection laws, and with suitable safeguards in place.

Where the data comes from

Your personal data may be gathered in different ways, but the major part is collected directly from you. It may be contained in your CV and cover letter, your application form or other documents you provide. Information about you is also gathered during interviews or assessments you take as part of our selection process.

In some cases, your personal data may also be collected from third parties:

• we may have collected information about you as part of our talent sourcing programme, where we obtain details from professional networking platforms and similar sources, including by using talent sourcing tools, in accordance with the relevant platform terms and your privacy settings;
• we may also receive information about candidates from third party recruiters or from someone who recommends you for a role at Fonoa (for example, our existing employee);
• while reviewing your application, we may refer to information on websites or social media, where they are legally allowed to share your data with us about your educational and professional background (e.g., information available on your LinkedIn profile)
• if you are offered and only after you accept a position at Fonoa, our third party provider will carry out a background check.

No obligation to share data

You are not under any statutory or contractual obligation to provide personal data during the application and selection process. However, in case you do not provide sufficient information necessary to assess your application (such as your previous experience and skills for a particular position), we may be unable to process your application properly.

Who gets to see information about you

Your personal data will be seen internally by our People and Talent team, the relevant hiring manager(s), and other interviewers. Information about you may be shared with Fonoa’s affiliated companies (subsidiaries) for the purpose of managing our talent sourcing, application and selection process.

Fonoa treats all personal data as confidential. This means that any information about you that we hold is subject to organisational and technical security measures, which are consistent with local and international information practices. We do our best to protect all confidential data against misuse, unauthorised access or disclosure, loss, alteration or destruction.

Access to confidential data is restricted to specific employees or departments, and these records can only be passed to others with management approval. This means that your personal data will not circulate freely within our organisation; it will be disclosed only to the individuals who “need to know” this information so that Fonoa can carry out or achieve its processing activities listed above.

Sharing your personal data with third parties

We may share your data with third parties who provide different services to us, but only where that is consistent with the purposes of processing identified above, and compliant with data protection laws. We will not share any information about you to third parties with unknown or questionable information security standards.

Specific circumstances in which your personal data may be disclosed include:

• professional talent sourcing and recruiting tools which we use to administer and streamline our talent sourcing, application and selection process (such as talent acquisition providers, applicant tracking systems, recruiting software providers, job boards, providers we use to record and transcribe interviews or other service providers that help us manage our recruitment process);
• if you are offered employment or engagement in a country where Fonoa does not have a local entity, we will work for us via a third-party provider, so your personal data required for setting up your employment or engagement will be shared with that provider (where such a provider is your employer of record, please note that they will also need to process various information to comply with local employment laws);
• background verifications of Fonoa personnel are carried out by a third-party provider, i.e. specialist agency (so your data may be shared with and collected by such third party on our behalf);
• if you are offered employment, we will provide equipment to you, so your data will have to be shared with a third party provider to the extent necessary for sending our equipment package to you;
• where necessary during recruitment or to set up your contract of employment or engagement with Fonoa, information may be shared with our professional advisors, such as legal, tax and immigration consultants;
• if you are offered and accept a position with Fonoa, your personal data may be shared with our payroll and benefits administration providers and entered into our HR management system provided by a third party (detailed information on Fonoa’s data processing activities applicable to our personnel will be provided to you in our Workplace Privacy Notice);

• where required by government departments, agencies and regulatory bodies (so that we comply with our legal obligations);

• data may be disclosed to organisations that host our IT systems.

How long we keep your personal data

If you are successfully hired, Fonoa will generally keep information about you during your employment or engagement. The protection of your personal data will then be governed by our Workplace Privacy Notice, which you will receive in due course.

We normally store information about sourced candidates and applicants who are not successful for 12 months at most, unless there are specific legal grounds allowing us to retain data for a longer period (i.e., if there is a legal obligation to do so, or if we need data to respond to and defend ourselves against legal claims).

However, we do keep limited information for a period of up to 5 years, based on our legitimate interest in keeping track of previous applicants. This includes your name, email, link to your LinkedIn profile, the source of your application and outcome of the application process (i.e., rejection reason, rejection notes, scorecards and interviews). Our written communication with you such as emails may also be kept in accordance with our general data archiving and retention policy.

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If you would like us to delete your data immediately, feel free to send a request to gpdr@fonoa.com.

Transfers of personal data outside the EEA and UK

Our processing of your personal data will normally be limited to the territory of the EEA and the UK. Personal data can freely flow from the EU to the UK following an adequacy decision adopted by the European Commission.

However, we may occasionally (where necessary for our processing activities and as set out in this Privacy Notice) also transfer information outside these territories. In such cases, we always ensure that transfer is lawful and that appropriate security arrangements are in place (e.g., adequacy decision permitting free flow of personal data or other safeguards as per the GDPR).

Access to your personal data and other rights

We try to be as open as we reasonably can about processing of personal data. If you would like specific information, just ask us.

You also have a legal right to make an access request.  If you exercise this right and we hold personal data about you, we are required to provide you with information on it, including giving you a description and copy of the personal data we process and telling you why we are processing it.

You also have the following legal rights:

• to have your personal data rectified, erased or to have processing restricted;

• to object to processing;
• if you have provided us with personal data (e.g. your address), you may have the right to be given the data in machine readable format for transmitting to another data controller (only applies if the ground for processing is consent or performance of a contract between us); and
• to lodge a complaint with a supervisory authority.

If we have relied on your consent to process personal data, you may withdraw it at any time – though if you do so, that will not affect the lawfulness of what we have done before you withdraw consent.

We will invest our best efforts to enforce your rights; however, please note they are not absolute.

There are scenarios where applicable law or regulatory requirements allow or require us to refuse your request. In addition, information may have already been destroyed, erased or made anonymous in compliance with our record retention obligations and practices. In the event that we cannot provide you with access to or rectification or deletion of your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

We will not discriminate against you for exercising any of your rights described in this Privacy Notice.

Fonoa as data controller

Fonoa Technologies Limited is the data controller responsible for processing of your personal data. This means that we are responsible for deciding how we hold and use personal information about you.

We will only use your information for the purposes identified in this Privacy Notice, in accordance with data protection laws. If we need to process your personal data for other purposes, we will duly notify you and, where necessary and appropriate, ask for your consent.

Contact details

If you have any questions about this Privacy Notice and our data practices, you can send us an email to gdpr@fonoa.com.

Fonoa’s international reach

We have an international mindset and embrace diversity. We are very committed to finding highly qualified and talented team members, which is why Fonoa looks for candidates who will remotely from various locations across Europe and beyond. We endeavour to comply with privacy legislation in each jurisdiction where we operate. Where we employ or engage personnel via third-party employers of record, we also rely on them in complying with local laws.

However, privacy legislation and an individual’s right to privacy can differ from one country to another. This Privacy Notice has been prepared to explain activities of Fonoa group as a whole. We may at times adopt specific information handling and privacy practices to address issues unique to operations and legal requirements in certain jurisdictions.

No automated decision-making

We do not make automated decisions concerning your application without human involvement. Our hiring decisions are made based on a combination of factors, such as your education, job experience, qualifications, expectations and cultural fit.

Status of this Privacy Notice and changes to it

This Privacy Notice does not constitute or form part of a contract of employment. It does not create any contractual rights or obligations.

This Privacy Notice may be updated or amended by us at any time, especially if we need to use your personal data for new purposes. Should we update this Privacy Notice during your selection process, we will provide you with the updated version if we make any substantial (as determined by us) changes. We may also from time to time inform you in other ways about our processing of your personal data.

Last updated on: 7 May 2025