This Employee Privacy Notice (“Notice”) describes how we – Exelot Ltd. and our affiliates ("Exelot", "we", "our" or "us") - treat the personal data of our employees and contractors (“you", or “your”).
Specifically, it describes the personal data we typically receive or collect, how and for which purposes we may use such data, where we store it and for how long we retain it, with whom we may share it, our security practices, your choices and rights regarding such data, our role as Data Controller and how to contact our privacy team if you have any concerns regarding your privacy or this Notice.
Exelot operates globally, with its HQ in Israel and employees and contractors worldwide. While this Notice is intended to describe the broadest range of our data practices globally, those practices may be more limited in some jurisdictions based on the local legal requirements. For example, the laws of a particular country may limit the types of personal data we can collect or how we may process that data. In those instances, we will use reasonable efforts to adjust our internal policies and practices to reflect such local requirements.
Please read this Notice and make sure that you fully understand and agree to it.
1. DATA COLLECTION
We collect and receive the following categories of personal data:
Data received from you during your job application process
Throughout the application and recruitment process, you may provide us (or we may otherwise have access to) personal data about you, which in typical circumstances would contain your:
● Identifying information;
● contact details (e.g., phone number, personal email address);
● work history, technical skills, educational background, professional certifications, memberships and/or registrations to professional organizations;
● language capabilities;
● training records;
● social media or other public activity;
● salary history and expectations.
We may collect this data directly from you, as you provide it voluntarily through your application and candidacy review process (e.g., CV/Resume, cover letter, questionnaires), or from other sources such as your references, placement agencies, or our Service Providers (as defined in Section 5 below).
Data received from you during your employment
Once you join Exelot and during your employment with us, you may provide us additional personal data about you, such as:
● additional identifying and contact data (e.g., your profile picture, ID or Social Security Number, nationality, passport details, home address, gender, date of birth, marital status, residency, and work permit status, military status, username and hashed password for your accounts at Exelot);
● data concerning your immediate family members and emergency contacts you have provided (as necessary under applicable tax and benefits forms);
● data concerning your health (so we could best attend any special requirements or preferences you might have, or sick day permits);
● your religious or philosophical beliefs (to the extent necessary for us to respect your religious holidays, dietary requirements, or other work-related needs);
● your healthcare and medical information, such as information related to employee participation in wellness programs, executive physicals, health insurance programs as well as any health information required for us to ensure a safe place of work and comply with government guidelines and public health advice to prevent the spread of the COVID-19;
● your bank, health and benefits providers (e.g., your bank account for depositing your salary, your selected pension or insurance providers, mobile carrier, health providers);
● data concerning your expressed preferences or requests;
● voicemails, e-mails, call, and video recordings, correspondence, documents, and other work product and communications created, stored, or transmitted using our networks, applications, devices, computers, or communications tools;
● date of resignation or termination, reason for resignation or termination, information relating to administering termination of employment (e.g., references);
● meal orders and dietary preferences; and
● any other personal data you may provide us with during or concerning your employment by Exelot.
Data generated by us, other Exelot employees, or our Service Providers
We, other Exelot employees, or our Service Providers may create additional data about you, such as:
● job offer letters;
● employee ID number;
● data regarding your role, position, and team;
● salary, benefits, and stock options (if applicable);
● records of work absences, vacation/paid time off;
● entitlement and requests;
● performance appraisals, letters of appreciation and commendation, and disciplinary and grievance procedures (including monitoring compliance with and enforcing our policies);
● work travel plans;
● general video footage from Exelot’s CCTV security system;
● calendar events, participation in work events, and other data concerning your activities as an Exelot employee.
Data automatically collected or generated
When you use any of Exelot’s systems or devices, including when you connect to or use your Exelot e-mailbox account, Human Resource Information System and/or Performance review system, we and our Service Providers may collect or generate technical data about you.
Such data consists of connectivity, technical or aggregated usage data, such as IP address, non-identifying data regarding the device, operating system, browser version locale and language settings used, the cookies and pixels installed on such device, and the activity (clicks and other interactions) on such systems.
We mostly use this data to have a better understanding of how our employees generally and typically use and engage with such systems and devices, or in order to investigate any suspected illegal activity, abuse, or wrongdoing.
2. DATA USES
We may use your personal data as necessary for the performance of our agreement with you; for complying with applicable law, such as applicable labor laws, or regulations concerning data privacy and security; and based on our legitimate interests in managing the day-to-day of Exelot’s human resources, better understanding and supporting our candidates and employees, ensuring that our employees, clients, and assets are protected, and securing and enhancing Exelot’s reputation and values.
Specifically, we will use your personal data as follows:
● To assess your skills, qualifications, and overall fit to work at Exelot;
● To set up your employee files, finalize and submit all necessary tax and governmental forms, and process your salaries and benefits;
● To authenticate your identity, and allow you access to our facilities and systems;
● To ensure an appropriate and compatible work environment for our employees;
● To respect your personal preferences and requirements, such as religious holidays, dietary or accessibility needs;
● To evaluate your work, status, and performance, and manage your day-to-day activities at Exelot;
● To contact you with information about Exelot, information or documents concerning your employment with us (such as your salary slips, employee forms, or any other information or documents sent to all or some of our employees).
● To enhance our security and anti-fraud measures and mitigate risks, and to create aggregated statistical or inferred data regarding our candidates and employees, for further development and improvement of our recruitment and HR processes;
● To further develop, customize and improve our HR operations, based on our employees' common or personal preferences, experiences, and difficulties, including as related to employment terms, performance, compensation and benefits;
● To enable our business continuity, during your employment and following your departure;
● To contact you, or your family members, concerning work-related matters or emergencies;
● To act as permitted by, and to comply with, any legal or regulatory requirements (such as applicable labor laws), and to conduct any additional activities that may require the use of your personal data, for which we will request your specific approval in advance.
3. DATA LOCATION
Your personal data may be maintained, processed, accessed, and stored by Exelot, our Service Providers and business partners in Israel, the UK, the US, and other jurisdictions, as necessary for the proper performance of our company and for the proper handling of your employment with us, or as may be required by law.
While privacy laws may vary between jurisdictions, Exelot, its affiliates, and Service Providers engaged in processing hereunder, are each committed to protect personal data in accordance with this Notice, customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred.
4. DATA RETENTION
Exelot may retain your employee personal data for the duration of your employment with us, and then for an additional period, as reasonably necessary to comply with our legal obligations, to resolve disputes, prevent fraud and abuse, enforce our agreements or otherwise protect our legitimate interests.
Please note that during such period, any communications and/or electronically stored data that was generated during your employment at Exelot (including email account and correspondences, chats, and other means of internal and external communication that was made available to you during your employment) may be subject to occasional monitoring, through automatic and/or manual means, in order to protect the safety and confidentiality of Exelot’s information and to ensure our business continuity. It is your responsibility to ensure that any communications and/or data that is stored on or accessible via devices or systems Exelot made available to you, is work related and therefore may be monitored by Exelot and its authorized personnel.
Following such period, we may retain limited copies of your data, so to allow us to maintain a registry of everyone who ever worked at Exelot and to be able to contact them solely in this context (and such registry shall only contain such limited data as necessary for this purpose).
Note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and are free to securely delete it for any reason and at any time.
5. DATA SHARING
We may share your data with certain third-parties, including law enforcement agencies, our Service Providers, and our affiliates, in accordance with this Notice and as described below:
Compliance with Laws, Legal Orders, and Authorities: we may disclose or allow government and law enforcement officials access to certain personal data in compliance with applicable laws and regulations, including for national security purposes and other requirements, such as tax, audit, recordkeeping, reporting, verifying identity and eligibility to work, and equal opportunities monitoring requirements; complying with lawful requests and legal process, such as responding to subpoenas, search warrant or court order (or similar requirement) or requests from government authorities; protecting our, your or others’ rights, health, safety and property; investigating and deterring against fraudulent, harmful, unauthorized, unethical or illegal activity, or conduct in violation of our policies or procedures; Complying with government guidelines and public health advice, e.g., to prevent the spread of the COVID-19; pursuing legal rights and remedies, including investigating, making and defending complaints or legal claims; administering and enforcing internal policies and procedures; and sharing information with government authorities, law enforcement, courts or private parties for the foregoing purposes.
Service Providers and Business Partners: we engage selected third party companies and individuals to perform services complementary to our own (e.g. hosting services, human resources software and service providers, data analytics services (such as compensation and benefits analytics), data and cybersecurity services, background check services, fraud detection and prevention services, payroll and payment processing services, benefit providers, e-mail distribution and monitoring services, and our business, legal, financial and compliance advisors) (collectively, "Service Providers"). These Service Providers may have access to your personal data, depending on each of their specific roles and purposes in facilitating and complementing our Services, and may only use it for such purposes.
Exelot Partners and Customers: we may disclose certain personal data to our partners and customers, such as your name, position, and contact details, and in some cases (if required for you to provide professional services on Exelot’s behalf) additional data such as your ID and existence of a background check (if any), to those partners requiring such data for security and regulatory reasons.
Other Exelot Employees: your fellow employees may have access to certain personal data, such as your identity, role, profile picture, and contact details, as may be available to them in the internal employee directory, and additional data depending on their specific roles and responsibilities, and need for such data (e.g., payroll data may be disclosed to HR, Finance and Legal personnel, as well as to your managers, all solely on a “need to know” basis).
Protecting Rights and Safety: we may share your personal data with others, if we believe in good faith that this will help protect the rights, property, or personal safety of Exelot, yourself, any of our clients or partners, or any other members of the general public.
Exelot Group: we may share personal data internally within the group, for the purposes described in this Notice. In addition, should Exelot Ltd. or any of its subsidiaries undergo any change in control or ownership, including by means of merger, acquisition, or purchase of substantially all or part of its assets, or will be considered or found eligible for a government grant and/or a potential investment, personal data may be shared with the parties involved in such an event. If we believe that such an event might materially affect your personal data then stored with us, we will use reasonable efforts to notify you of this event and the choices you may have via e-mail or prominent notice in our internal systems typically used for such notices.
Additional sharing: for the avoidance of doubt, Exelot may share your personal data in additional manners, pursuant to your explicit approval, if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may share or otherwise use non-personal data in our sole discretion and without the need for further approval.
6. DATA SECURITY
In order to protect your personal data held with us and our Service Providers, we are using industry-standard physical, procedural, and electronic security measures, including encryption where deemed appropriate. These measures provide sound industry standard security, however, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any personal data stored with us or with any third parties. We continue to regularly seek new ways and tools for further enhancing the security of our system and the integrity of the personal data that we hold.
7. DATA SUBJECT RIGHTS
If you wish to exercise your rights to access, rectify, erase or port your personal data held with Exelot, or to restrict or otherwise object to its processing, or to exercise any similar rights afforded to data subjects under the laws that apply to you - please contact us at privacy@exelot.com.
Please note that we may require additional information, including certain personal data, in order to authenticate and process your request. Such additional information may be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request), in accordance with Section 4 above. We may redact from the data which we will make available to you, any personal data related to others.
Please also note that such rights are not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal data that we hold about you. In the event that we cannot accommodate your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
8. ROLES AND RESPONSIBILITIES
Certain data protection laws and regulations typically distinguish between two main roles for parties processing personal data: the “data controller”, who determines the purposes and means of processing; and the “data processor”, who processes the data on behalf of the data controller.
Exelot is typically the “data controller” of its candidates’ and employees’ personal data, and with respect to which, assumes the responsibilities of a data controller (solely to the extent applicable under the law), and as set forth in this Privacy Notice. In such instances, our Service Providers processing such data will assume the role of “data processors”.
9. ADDITIONAL INFORMATION
Updates and amendments: we may update and amend this Notice from time to time by distributing an amended version. The amended version will be effective as of the published effective date. We will use reasonable efforts to provide advance notice if any substantial changes are involved, via any of the communication means available to us. After this notice period, all amendments shall be deemed accepted by you.
Questions, Concerns, or Complaints: if you have any comments or questions about this Privacy Notice or if you have any concerns regarding our data practices or your privacy, or your personal data held with us, or if you wish to make a complaint about how your personal data is being processed by Exelot, please contact us at privacy@exelot.com.
Last updated: January, 2022