Candidate Privacy Notice

1. Introduction and Scope

This Candidate Privacy Notice ("Notice") describes how Chinchill AI, Inc. (“Chinchill AI”, "Company," "we," "us," or "our") collects, uses, and protects your personal information when you apply for employment with us, whether for a full-time, part-time, contractor, or internship position ("Candidate" or "you").

This Notice applies throughout the recruitment process, from initial application through final hiring decisions, and supplements our general Privacy Policy regarding website use.

This Notice applies to candidates in all locations where we recruit. Depending on your location, additional privacy rights may apply under:

• European Union and United Kingdom: General Data Protection Regulation (GDPR)
• California: California Consumer Privacy Act (CCPA, CPRA)
• Other US States: Virginia CDPA, Colorado CPA, Connecticut CTDPA, Utah UCPA
• Canada: Personal Information Protection and Electronic Documents Act (PIPEDA) and provincial laws

IMPORTANT: Any personal information you provide is voluntary. However, if you do not provide certain information requested during the application process, we may not be able to consider your application or move forward with your candidacy.

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

2. Contact Information and Data Controller

Chinchill AI, Inc. is the data controller (or "business" under certain laws) responsible for your personal information.

For privacy questions or concerns:

Chinchill AI, Inc.

Email: [email protected]

Address:
299 California Ave
Startup Island TAIWAN -Silicon Valley Hub
Attention: Chinchill AI
Palo Alto, CA 94306-1935 USA

3. Personal Information We Collect

3.1 Categories of Personal Information

Basic Identification Information

• Full name
• Date of birth
• Government identification numbers (SSN, passport number - collected only post-offer for employment verification and tax compliance)
• Copy of identification documents (passport, driver's license, visa, etc.)
• Photograph (if provided)

Contact Information

• Email address
• Phone number(s)
• Mailing address
• LinkedIn profile or other professional social media

Professional and Educational Background

• Resume or CV
• Cover letter
• Work history and experience
• Job titles and responsibilities
• Educational institutions, degrees, certifications
• Professional licenses or credentials
• Language proficiency
• Skills and competencies
• References and contact information for references
• Salary history (where permitted by law)
• Salary expectations

Right to Work Information

• Work authorization status
• Citizenship or visa status
• Work permit documentation
• Information needed to verify eligibility to work in the United States

Application and Assessment Information

• Job position(s) applied for
• Application date and source (e.g., job board, referral)
• Responses to application questions
• Assessment and test results
• Interview notes and evaluations
• Work samples or portfolios (if submitted)
• Communications with recruiters and hiring managers
• Internal ratings and feedback from interviewers

Background Check Information (Where permitted by law and with appropriate consent)

• Employment verification
• Education verification
• Criminal history (where legally permitted)
• Credit history (for certain positions, where legally permitted)
• Professional reference checks
• Social media screening (limited and legally compliant)

Demographic Information (Collected separately for equal opportunity monitoring, optional)

• Gender
• Race or ethnicity
• Veteran status
• Disability status
• Other protected characteristics as required by applicable law

Note: We do not make hiring decisions based on demographic information. This data is collected solely for legal compliance and equal opportunity monitoring.

3.2 Sensitive Personal Information

• Government identification numbers (SSN, passport number - collected only post-offer for employment verification and tax compliance)
• Background check results (criminal history where permitted)
• Health information (if disclosed for accommodation requests)
• Demographic data for equal opportunity purposes

We collect sensitive information only when required or permitted by law, necessary for the specific position, you voluntarily provide it, or we obtain your explicit consent (where required).

3.3 How We Collect Information

• Direct submissions: Your application, resume, cover letter, forms you complete
• Interviews: In-person, phone, or video interviews (which may be recorded with your consent)
• Assessments: Skills tests, personality assessments, work samples
• References: Information from professional references you provide
• Background check providers: Third-party verification services (with your consent)
• Recruiting platforms: Applicant tracking systems, job boards, LinkedIn
• Public sources: Professional networking sites, publicly available information
• Referrals: Information from employees or others who refer you

4. How We Use Your Information

We use your personal information for the following purposes:

5. Legal Basis for Processing (GDPR)

If you are in the EU, UK, or other GDPR-applicable jurisdiction, we process your information based on

• Legitimate Interests: Evaluating candidates, making hiring decisions, improving recruitment
• Consent: When required by law (e.g., for certain background checks, future opportunity communications, interview recordings)
• Legal Obligation: Complying with employment laws, tax laws, equal opportunity requirements
• Contract Performance: Taking steps prior to entering into an employment contract

You may withdraw consent at any time where processing is based on consent, though this may affect our ability to proceed with your application.

6. Who We Share Your Information With

We may share your personal information with

6.1 Internal Recipients

• Hiring managers and interview panels
• Human Resources personnel
• Department heads and executives
• IT and security teams (for system access and security)

6.2 External Third Parties

Service Providers

• Applicant Tracking System (ATS) providers
• Background check companies
• Assessment and testing platforms
• Video interview platforms
• Email and communication services
• Cloud storage providers
• Recruiting agencies (if applicable)

Professional Advisors

• Legal counsel
• HR consultants
• Auditors

Government Agencies

• As required for legal compliance (e.g., EEOC reporting, tax authorities)
• In response to lawful requests (subpoenas, court orders)

Corporate Transactions

• In connection with mergers, acquisitions, or sale of business assets

With Your Consent

• References you authorize us to contact
• Other parties with your explicit permission

7. International Data Transfers

If you are applying from outside the United States, your information will be transferred to and processed in the United States, where our company is based.

For EU/UK candidates: The United States may not provide the same level of data protection as your home country. We implement appropriate safeguards including

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Binding Corporate Rules (if applicable)

For Canadian candidates: We comply with PIPEDA requirements for cross-border transfers.

8. How Long We Retain Your Information

We retain candidate information based on

8.1 If You Are Not Hired

Active consideration period: During the recruitment process and decision-making

Post-decision retention

• Minimum retention: 2 years to comply with legal requirements and defend against potential claims
• Talent pool retention: 2 years if you consent to be considered for future positions
• Geographic variations: Retention periods may vary based on local legal requirements

8.2 If You Are Hired

Information collected during recruitment becomes part of your employment file and is retained according to our employee data retention policies.

8.3 Legal Requirements

We may retain information longer when

• Required by law (e.g., EEOC record-keeping requirements in the US)
• Necessary to defend legal claims (until statute of limitations expires)
• Subject to legal hold or ongoing investigation

8.4 Deletion

When retention is no longer necessary, we securely delete or anonymize your information.

9. Your Privacy Rights

Depending on your location, you may have the following rights

9.1 Rights for All Candidates

• Access: Request what personal information we hold about you
• Correction: Request correction of inaccurate information
• Deletion: Request deletion of your information (subject to legal exceptions)
• Withdraw consent: Withdraw consent for future processing (where applicable)
• Opt-out: Opt out of future job opportunity communications

9.2 Additional Rights for EU/UK Candidates (GDPR)

• Data portability: Receive your data in a machine-readable format
• Restriction: Request limitation on processing
• Object: Object to processing based on legitimate interests
• Automated decision-making: Right not to be subject to solely automated decisions (Note: We do not use automated decision-making in hiring)
• Supervisory authority: Lodge a complaint with your data protection authority

EU Supervisory Authorities: https://edpb.europa.eu/about-edpb/board/members_en

UK Information Commissioner's Office: https://ico.org.uk/

9.3 Additional Rights for California Candidates (CCPA/CPRA)

• Know: Confirm whether we process your information and obtain details
• Access: Obtain a copy of specific information collected
• Delete: Request deletion (subject to exceptions)
• Correct: Correct inaccurate information
• Opt-out: We do not "sell" candidate information
• Sensitive data: Limit use of sensitive personal information
• Non-discrimination: Not be discriminated against for exercising rights

9.4 Additional Rights for Other US State Residents

Similar rights apply under Virginia CDPA, Colorado CPA, Connecticut CTDPA, and Utah UCPA.

9.5 Additional Rights for Canadian Candidates

• Access personal information we hold
• Challenge accuracy and completeness
• Withdraw consent for optional processing
• File a complaint with the Privacy Commissioner of Canada

9.6 How to Exercise Your Rights

To submit a request

Email: [email protected]

Mail

299 California Ave
Startup Island TAIWAN -Silicon Valley Hub
Attention: Chinchill AI
Palo Alto, CA 94306-1935 USA
Verification: We will verify your identity before responding to requests.
Response time: We will respond within the timeframe required by applicable law (typically 30-45 days).
Appeals: If we deny your request, you may appeal by contacting us at [email protected]. We will respond to appeals within the required timeframe.

10. Data Security

We implement appropriate technical and organizational security measures to protect your information, including

• Encryption of data in transit and at rest
• Access controls (limited to need-to-know basis)
• Secure applicant tracking systems
• Regular security assessments
• Employee training on data protection
• Confidentiality agreements with service providers

However, no security system is completely secure. We cannot guarantee absolute security.

Security incidents: If we experience a data breach affecting your information, we will notify you and relevant authorities as required by law.

11. Children's Information

We do not knowingly collect information from individuals under 18 years of age. Our positions are open to individuals who meet minimum age requirements for employment.

12. Equal Opportunity and Non-Discrimination

Chinchill AI, Inc. is an equal opportunity employer. We do not discriminate based on

• Race, color, ethnicity, national origin
• Sex, gender, gender identity, sexual orientation
• Age
• Religion
• Disability
• Veteran or military status
• Genetic information
• Any other protected characteristic under applicable law

Demographic information collected for equal opportunity monitoring is

• Voluntary
• Kept separate from your application
• Not used in hiring decisions
• Used only for statistical reporting and compliance

13. Automated Decision-Making

We do not make hiring decisions based solely on automated processing or algorithms. All hiring decisions involve human review and judgment.

If we use any automated tools to assist in screening (e.g., resume parsing, skills matching), these are used only to support human decision-makers, not replace them.

14. Recording of Interviews

If we record phone or video interviews

• We will notify you in advance
• We will obtain your consent where required by law
• Recordings are used only for evaluation purposes
• Recordings are deleted according to our retention policy

15. Changes to This Notice

We may update this Notice periodically. Changes will be posted with a new 'Last Updated' date.

For material changes affecting your rights, we will

• Provide notice through our careers page
• Email active candidates (where we have contact information)
• Obtain consent where required by law

16. Additional Information for California Residents

Categories of Personal Information Collected In the past 12 months, we have collected the following CCPA categories:

Sources of Information

• Directly from you (applications, interviews)
• References
• Background check providers
• Public sources (LinkedIn, professional websites)
• Recruiting platforms and job boards

Business Purposes for Collection

• Recruitment and hiring
• Verification and background checks
• Legal compliance
• Internal record-keeping
• Process improvement

Disclosure for Business Purposes

We disclose personal information to:

• Service providers (ATS, background check companies, assessment platforms)
• Professional advisors
• Government agencies (as required)

Categories disclosed include: A, B, C, G, H, I, J, K, L

No Sale of Information

We do not 'sell' candidate personal information as defined by the CCPA.

Retention

See Section 8 for retention periods.

Your CCPA Rights

See Section 9.3 for detailed California rights.

To exercise rights: Submit a request at [email protected]

Authorized agents: May submit requests with proper authorization documentation.