Global Career Privacy Notice

Last Reviewed: October 1, 2023

Privacy

We Respect Your Privacy

Orange Logic (the “Company”) is committed to respecting the privacy of individuals around the globe and we strive to be transparent about the data we collect and how we use and retain it on behalf of individuals, including data collected during recruitment and employment.

Orange Logic has implemented this Global Employee Privacy Notice (the “Notice”), providing job applicants (“Applicants”) and members of Orange Logic’s workforce (“Orange Logic Employees”) with clear, detailed, and easy-to-read information about the Company’s privacy practices and how we collect, use, process, and transfer their personal data. This Notice also describes our methods of collecting, processing, maintaining, protecting, and disclosing the personal data that we collect.

The terms referring to the individuals applicable in this Notice, Applicants and Orange Logic Employees, can further be described as follows:

• Applicants. An Applicant is an individual who has submitted information to Orange Logic (i.e. our Recruitment and Human Resources teams) in order to apply for a position posted by Orange Logic, or who has otherwise given consent to Orange Logic for consideration as a candidate.
• Orange Logic Employees. An Orange Logic Employee is a full or part time Orange Logic employee, independent contractor, consultant, or agency worker or intern.

Types of Data We Collect

The personal data Orange Logic processes about you may vary according to whether you are an Applicant or Orange Logic Employee, the type of processing performed, the jurisdiction you are located in, and applicable legal requirements. To that end, the Company may collect, use, and retain personal information including, but not limited to the following categories:

• Contact Information: Orange Logic may collect contact information, such as full name, residential addresses, telephone numbers, email addresses, and emergency contact details.
• Identification Data: Identification information may be collected, including date of birth, government identifiers, driver’s license or ID, passport, and other government or similar identifiers.
• Recruitment and Hiring Data: Information related to Applicant qualifications, past employment, educational background, references, residency and work permit status, official documentation in support of authentication or eligibility for employment (e.g., Form I-9 in the US) may be collected. Where relevant to the position, we may also collect information from professional licensing and certification bodies or training institutions.
• Employment Data: Employment data includes information related to Orange Logic Employee qualifications, including your role at Orange Logic such as position information, role changes, resignation/termination, resume/CV, work location, employment contracts, performance and disciplinary records, academic/professional qualifications, criminal records, immigration status documentation and/or residency permits and visas, ID/passport, training logs, etc. Some of this information may have been collected while the employee was an Applicant.
• Performance and Management Data: This shall include information related to Orange Logic Employee performance evaluations or reviews, disciplinary actions and grievances, training and development plans, and other performance records.
• Financial and Benefits Data: Orange Logic may process information relating to your banking details, tax information, payroll information, withholdings, salary, expenses, company allowances, etc. Where you enroll in benefits, Orange Logic will collect information related to employment benefits Orange Logic provides to you such as spouse/partner and dependent information, health information, vacation, leaves of absence, and accommodations information.
• Systems and Asset Usage Data: Orange Logic may collect information required to provide access to or in your use of our information systems, assets, and other company resources including IP addresses, activity logs, login information/credentials, software/hardware inventories, internal communications and video and audio recordings, and information collected in communications tools and platforms. 
• Internet Usage Data: Information collected includes online usage information when you browse Orange Logic websites including cookie information, traffic data or profiles, etc. This type of data may be grouped in with “Systems and Asset Usage Data” above.
• Publicly Available Information: This includes information that you’ve made public, such as your public profile on career networking sites (e.g., LinkedIn). 
• Voluntary Data: This is information that you choose to provide us in connection to a career opportunity or your existing employment with Orange Logic. For example, you may choose to participate in a voluntary opt-in survey (e.g., candidate experience feedback survey, employment experience survey, etc.) or voluntary assessment (e.g., behavioral assessment). These programs are entirely optional and will be communicated as such. 
• Sensitive Data. While we treat all data with the utmost care, certain data collected from Applicants and Orange Logic Employees may be more sensitive in nature. This is defined as “Sensitive Data” and may include demographic information, such as information about your racial or ethnic origin, gender, age, sexual orientation, veteran status, background check results, and health history (e.g., disability status). Sensitive Data will generally be collected directly from you. However, if legally required or permitted, and pursuant to your prior written consent, we may also collect Sensitive Data from background check providers. Your consent and provision of requested information is required prior to Orange Logic engaging background screening from the background check provider. Certain types of data that fall into the categories above may be categorized as Sensitive Data.

How is Data Collected?

We use different methods to collect your personal data. In relation to your job application with us or your participation as an employee, we may collect data about you from the following sources:

• Direct Interactions. This is information you provided directly to Orange Logic during the recruitment and/or onboarding process. For example, when you fill out the form found on our “Careers” webpage at http://www.orangelogic.com or provide your resume/CV to members of our Recruitment and Human Resources teams.

• Referrals and References. If you are referred by an existing employee of Orange Logic, we will collect information from the individual who referred you. Where references are provided during recruitment, we may receive information from your previous employers, supervisors, or other references.
• Recruitment and Staffing Partners or Job Websites. We may collect information from recruitment and staffing partners and jobs and networking websites (e.g., LinkedIn) if you apply to us through those sources.
• Professional Licensing and Certification Bodies. Where it is relevant for the position, we may receive information from professional licensing and certification bodies, identity verification services, and educational and training institutions.
• Background Check Providers. Where permitted or required by local law, we receive background check information from third-party background check providers (e.g., ADP). Background check providers will provide us with Sensitive Data. Please note that Orange Logic will not engage a background check provider to perform a background check without your explicit rewritten consent.
• Data Providers. We may receive information such as your education, work experience, and contact information from various third-party data providers who are permitted to provide us with your information. These providers collect your information from publicly available sources, or through third parties they work with. 
• Publicly Available Sources. We may receive information from other publicly available sources, such as information that you have chosen to make public online (e.g., your public LinkedIn profile). 
• Automatic Collection. When you submit an application online (e.g., through our careers web page), in addition to the information you provide directly to us (see Direct Interactions above), we collect information sent to us by the device you use, such as your mobile device/computer IP address, device identifiers, and how you arrived at our website. For more information, please see our Cookie Policy.

Orange Logic will only process your personal data where we have a legitimate business reason or legal requirement to do so. The section below outlines the main reasons for processing and the types of data involved.

Purpose of Processing: How We Use Your Data

We use personal data only as permitted by law, such as in the following circumstances:

• Recruitment and Hiring. Orange Logic may use your personal data in recruitment to review and process your information, allowing us to determine suitability and eligibility for a role. This includes the verification of qualifications (e.g., highest education received, employment history), administering background checks, etc.
• Compensation and Benefits. We use this information to manage payroll, taxes, and benefits. This information may also be used to process work-related claims and requests (e.g., worker compensation, insurance claims, expense and travel management) and leaves of absence. 
• Training and Awareness. We use this information to manage the effectiveness of training, help us with creating and updating employee training and other development opportunities, and enforcing mandatory training completions. 
• Performance Reviews. Your information collected as an Orange Logic Employee may be used to review how you are performing at work and to help determine your work performance requirements and career development needs.
• Information Technology and Security. We use this information to maintain the security of Orange Logic’s information systems, assets, resources, and premises and to provide you with access to them, to manage our general operations and assets, to provide role-based services/access to you, and to protect your information and safety. 
• Directory. We use contact and identification information internally to compile employee directories and to send assets (e.g., Company-issued devices, workspace equipment, etc.) to your work environment (e.g., your home address). Emergency contacts may also be established for you, which may be used to respond to and manage emergencies, crises, and business continuity. 
• Investigations and Disciplinary Actions. Your information may be used as necessary to investigate and support decisions on disciplinary actions or terminations, conduct grievance management, or when necessary to detect fraud, unauthorized breaches, or other types of wrongdoing. 
• Day-to-Day Business Operations. Your information is used for other legitimate purposes that are reasonably required for day-to-day operations at Orange Logic, such as managing employee and customer relationships, accounting, financial reporting, business analytics, employee surveys, operational and strategic business planning, expense management, etc.
• Internal Reporting. Orange Logic may use your data to analyze metrics, including recruitment metrics, for aggregated reporting (e.g., assessing the efficiency of our internal processes).
• Legal Requirements. Your information may be used as legally required and to comply with laws and regulations (e.g. labor and employment laws, health and safety, anti-discrimination laws, etc.) or to exercise or defend our legal rights. 
• Other Purposes With Your Consent. If you voluntarily choose to participate in an optional program (such as surveys), we will use your data according to any purposes provided to you during the opt-in process.

Orange Logic generally collects personal data directly from you or from a third-party pursuant to your permission and will only use such data for the reasons it was collected. If we need to use the data for another legitimate business purpose, we will notify you directly and will obtain your permission where required. Where Orange Logic asks for a category of personal data not described above, the reason for doing so will be made clear to you prior to our collection.

‍Legal Basis for Processing

Orange Logic may collect and process your information where it is necessary in order to take steps, at your request, prior to potentially entering in an employment contract with you. 

Where you are from a jurisdiction that requires a legal basis for processing personal data (such as the EEA or UK), Orange Logic’s legal basis will depend on the personal data concerned and the context in which we collect it. We will normally collect personal data from you only for the reasons set forth below:

• Performance of a Contract. We need it to administer our contract with you, including an employment contract;
• Legitimate Interest. It satisfies a legitimate interest which is not overridden by your data protection interests or fundamental rights and freedoms;
• Legal Obligation. We need to comply with a legal obligation or exercise our rights in the field of employment; or

We may also rely on your consent in certain situations. Consent means that access to or use of specified personal data has been freely-given based on an informed decision. 

If we ask you to provide personal data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and let you know whether providing your personal data is mandatory or not, as well as the possible consequences if you do not provide it.

Similarly, if we collect and use your personal data in reliance on our legitimate interests (or those of a third party) that are not listed in the table above, we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us using the contact details provided in the Contact Us section below.

Where Orange Logic relies on your consent for certain recruitment processing activities, you may withdraw your consent at any time. This can be done by contacting our Compliance team at compliance@orangelogic.com. If consent is withdrawn, we will no longer be able to consider your application for employment.

Data Management

Who We Share Your Data With

Orange Logic does not sell personal data, nor do we allow personal data to be used by third-parties for their own marketing purposes. Orange Logic may share your personal data for the purposes set forth above with the following recipients: 

• Internally. Information collected from you may be used to establish, manage, change, or terminate your employment with Orange Logic.
• Third-Party Service Providers. As permitted by applicable law, information collected from you may be shared with third-parties to provide services to you on behalf of Orange Logic, such as applicant tracking system or recruitment solution, background check providers, insurance and benefit providers, and payroll support and leave management services. Third-parties cannot use your data for their own independent purposes. 
• Government Authorities or Law Enforcement. As legally required, your data may be shared with government authorities or law enforcement if Orange Logic in good faith believes we are compelled by any applicable law, regulation, legal process or government authority or where necessary to exercise, establish, or defend legal rights.

We will obtain your consent prior to any disclosure of your personal data where required by law. 

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you; (3) investigate and defend ourselves against any third-party claims or allegations; (4) protect the security or integrity of our business operations; or (5) exercise or protect the rights and safety of Orange Logic, our customers, personnel, and others. We attempt to notify individuals about legal demands for their personal data when appropriate and at our discretion, unless prohibited by law, court order, or when the request is an emergency.

All service providers we engage to process your personal data on our behalf are subject to a robust privacy, compliance, and security vetting and due diligence process and are required to enter into an agreement with Orange Logic that ensures the appropriate use and protection of your personal data.

Retention of Personal Data

Orange Logic will retain your personal data no longer than necessary to carry out the purposes provided in this Privacy Notice and any other policy/notice provided to you, and as required or permitted under applicable law. 

Orange Logic Employees. Orange Logic will keep your data until termination of your employment with us, in addition to any reasonable period of time to respond to any inquiries/administrative matters or as required by applicable local law. Where we have no continuing legitimate business need or legal requirement to process your data, we will delete your data. If deletion is not feasible, Orange Logic will securely store and isolate your data until deletion is possible. 

Applicants. If you apply for a position or provide interest in a career with Orange Logic, your information is retained for determination of your eligibility for a current or future role. If you are offered and accept a role with Orange Logic, we will retain your information in order to manage your employment or assignment with us in accordance with an employment contract between you and Orange Logic and as further described above.

The retention periods vary depending on your jurisdiction and the local applicable laws. For questions regarding retention of your data, please contact us using the contact information provided in the “Contact Us” section below.

Your Rights in Relation to Your Personal Data

Regardless of your location (US, EU/EEA, UK, Switzerland, Vietnam, etc.), and whether you are an Applicant or Orange Logic Employee, you have the right to make choices about your personal data. These include:

• Right to Access. The right to be provided with a copy of your personal data. Note that a small fee may be charged for this service.
• Right to Rectification. The right to require us to correct incomplete or inaccurate personal data we have about you.
• Right to Erasure/To be Forgotten. The right to ask us to delete personal data when there is no legitimate reason for processing. If we are unable to comply with your request, we will notify you within 48 hours.
• Right to Restrict Processing. The right to require us to restrict personal data processing, where applicable.
• Right to Request Data Portability. The right to request transfer of your personal data in a commonly used, machine-readable format.
• Right to Object to Processing. The right to object to the processing of your personal data.
• Right to Withdraw Consent at Any Time. The right to withdraw your consent at any time in which we rely on your consent to process your personal data.

If you have questions about the type of personal data we have, or if you want to access, modify, restrict, or delete your personal data, please contact Orange Logic using the contact information listed in the “Contact Us” section below. 

How We Protect Your Data

Processing of the information you provide Orange Logic is always performed in a manner that is compliant with applicable data protection laws and regulations, including the world’s toughest data privacy law, the European Union General Data Protection Regulation (GDPR).

Orange Logic has implemented a security and privacy program that aligns with applicable laws and regulations and industry standards/best practice security frameworks, including ISO/IEC 27001:2013, comprising of technical and organizational measures that protect the privacy and security of your personal data. These include controls that are built to ensure the confidentiality, integrity, and availability of your personal data, such as access controls, encryption, risk management, asset management, vulnerability management, incident management and response, and disaster recovery. Orange Logic Employees can learn more about these technical and organizational controls by accessing the internal resource center’s Trust Center.

We also take measures to ensure that third-parties that process personal data on our behalf also have appropriate security controls in place.

International Transfers

As a global organization, Orange Logic may, pursuant to valid business purposes, transfer and process your personal data outside of your country of residence to other countries where Orange Logic, our affiliate entities, and our third-party service providers operate – including our corporate headquarters in the United States. These countries may have data protection laws that are different from the laws of the region where you reside. Where Orange Logic transfers your data to another country, we will ensure that the transfer complies with applicable law. 

Internal Transfers. We have established and implemented appropriate technical and organizational security measures for the adequate protection for internal transfers of personal data of Applicants and Orange Logic Employees in the European Union (“EU”)/European Economic Area (“EEA”), the United Kingdom (“UK”), and elsewhere. All Orange Logic affiliate entities with access to information are within the scope of our ISO/IEC 27001:2013 certification.

External Transfers. If we need to transfer your personal data outside of Orange Logic to a third-party service provider who handles data on our behalf, Orange Logic relies on other agreements, such as the European Union (“EU”) Standard Contractual Clause (the “SCCs”).

Where your data originates from the EU/EEA and is transferred to an Orange Logic affiliate entity or a service provider in the United States, Orange Logic relies on the SCCs as a valid transfer mechanism to ensure the privacy of your personal data. Where personal data originates in the UK, Orange Logic will rely on the International Data Transfer Agreement. Where personal data originates in Switzerland, Orange Logic will rely on a Swiss addendum to the SCCs, developed in accordance with the Swiss Federal Data Protection and Information Commissioner (“Swiss DPA”) guidance. For questions regarding other jurisdictions, please use the contact details in the “Contact Us” section below.

Orange Logic has entered into agreements ensuring appropriate and suitable safeguards with its affiliate entities and third-party service providers, including the SCCs where appropriate.

Information for California Residents

The California Consumer Privacy Act (“CCPA''), as amended by the California Privacy Rights Act (“CRPA”), requires businesses to disclose whether they sell or share personal data. California law provides you with specific rights in addition to those listed in the “Your Rights in Relation to Your Personal Data” section above regarding your “Personal Information” subject to certain exceptions. Those additional rights include:

• The right to request disclosure of Personal Information sold or shared;
• The right to opt-out of the sale of sharing of Personal Information; and

• The right to non-discrimination for exercising your rights

In addition to exercising your rights, you may contact us at +1 949-396-2233 and we will respond in accordance with our legal obligations. We will verify your identity, and the identity of any third-party agent acting on your behalf, before we comply with the request and ask for your cooperation with our identity verification process. Please note that we are only required to respond to two such requests per individual each year.

Orange Logic does not sell or share your Personal Information as defined by California law.

How Orange Logic Handles Disputes Relating to Personal Data

Orange Logic hopes to resolve any disputes relating to our data protection practices between you and Orange Logic. However, if you have a dispute with us relating to our data protection practices, you can raise your concern or dispute by contacting our Privacy Team via email at compliance@orangelogic.com or by mail at:

Orange Logic Privacy Compliance

Orange Logic LLC

4199 Campus Drive, Suite 550

Irvine, CA 92612

Right to Complain to a Supervisory Authority

While Orange Logic hopes to resolve any dispute between us, you have the right to lodge a complaint with local competent supervisory authority in the country where you work or where you consider any data protection rules to have been breached regarding our practices and handling of your personal information.

European Economic Area and United Kingdom. You can find your local data protection authority below:

• European Union: https://edpb.europa.eu/about-edpb/about-edpb/members_en 
• United Kingdom: https://ico.org.uk/make-a-complaint/ 

Contact Us

If you have any questions regarding personal data practices by Orange Logic, please contact our Data Protection Officer (DPO) below.

Orange Logic Privacy Compliance

Orange Logic LLC

4199 Campus Drive, Suite 550

Irvine, CA 92612

Email: compliance@orangelogic.com 

Telephone: +1 949-590-4938

Existing Orange Logic Employees can direct questions or inquiries about this Privacy Notice to Orange Logic’s Compliance team using the internal ticketing system, Link. Alternatively, you may raise any questions or concerns directly with your manager or Human Resources.

Changes in the Privacy Notice

Orange Logic reserves the right to amend the Privacy Notice from time to time at its sole discretion. You can see when this Privacy Notice was last updated by checking the "Last Updated" date displayed at the top. If we update this Privacy Notice in a way that impacts your rights, we will provide notice by email, on our website, or via another communication method when we make material changes.

We will comply with applicable law with respect to any changes we make to this Privacy Notice and seek your consent to any material changes if this is required by applicable law.