California Privacy Rights Notice: If you are a California resident, you have certain rights under California privacy laws. Please see the California Privacy Rights section below for important information about your rights. 

This Candidate Privacy Policy describes how TextNow, Inc. and its subsidiaries, affiliates, and related entities (collectively, “TextNow”, "Company," "we," or "us") collect and use personal information about you during the application and recruitment process. This Candidate Privacy Policy applies to job applicants/candidates (“you” or “your”) only.  

This Candidate Privacy Policy explains the types of personal information we collect, how we use it, when we may disclose it to third parties, how long we retain it, and your rights and choices regarding your personal information.  

We will use your personal information in accordance with this Candidate Privacy Policy unless otherwise required by applicable law.  

Types of Personal Information We Collect 

In this Candidate Privacy Policy, personal information means any information about an identifiable individual collected in connection with the recruitment process. This does not include information that has been aggregated or de-identified so that it can no longer reasonably be associated with you. We may collect, store, and use the following categories of personal information in connection with our recruiting activities: 

• Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses. 

• Work history and other relevant experience including information contained in a resume, CV, cover letter, or job application. 

• Education information including degrees awarded, transcripts, and other information provided in support of the job application. 

• Compensation information, including salary expectations. 

• Information collected during phone screenings and interviews. This may include telephone interviews, audio recordings, video recordings, and transcriptions.  

• Details of how you heard about the position you are applying for. 

• Demographic and diversity information that you voluntarily provide or that we are required to collect under applicable law, such as gender, race or ethnicity, veteran status, citizenship or work authorization status, disability status, or information provided in connection with a request for accommodation.  

• Reference information, and information received from background checks, where applicable, including information provided by third parties. 

• Information related to previous applications to the Company or previous employment history with the Company. 

• Your information from publicly available sources, including online, that we believe is relevant to your application or a potential future application (e.g. your LinkedIn profile).  

• Other information you voluntarily provide to us in connection with your application or during the recruitment process, including through interviews, correspondence, application forms, or other submissions. 

We collect personal information directly from you, from references or from background check providers where applicable and permitted by law, from publicly available professional sources, and from service providers that support our recruitment systems. 

How We Use the Personal Information We Collect 

We use your personal information where applicable law permits or requires it in connection with carrying out our application and recruitment process. As such, we may use your personal information for the following purposes: 

• Identifying and evaluating job applicants, including assessing skills, qualifications, and interests. 

• Verifying your information and carrying out employment, background, and reference checks, where applicable, in accordance with applicable law. 

• Communicating with you about the recruitment process and your application(s), including in appropriate cases, informing you of other potential career opportunities at the Company. 

• Keeping records related to our hiring processes. 

• Fostering diversity and inclusion programs and practices. 

• Creating and submitting reports as required by applicable laws or regulations. 

• Complying with our legal, regulatory, or other corporate governance requirements. 

• Analyzing and improving our application and recruitment process. 

• Complying with applicable laws, regulations, legal processes, or lawful government and law enforcement requests. 

• Protecting the rights and property of the Company, other job applicants, employees, or the public, as required or permitted by law. 

Use of Artificial Intelligence and Automated Tools 

We may use artificial intelligence, machine learning systems, or other automated technologies to support aspects of our recruitment process. These tools may assist with resume screening, candidate matching, scheduling, and administrative processing. Automated tools are designed to support human review and decision making. Employment decisions are not made solely by automated processing. 

You may have the right, depending on the jurisdiction in which you reside, to not be subject to decisions made using automated decision-making technology that replaces or substantially replaces human decision-making, including profiling, where such decisions produce legal or similarly significant effects concerning you. Where required by applicable law, you may request human intervention, opt-out of such processing, or request a manual review of a decision made using such automated decision-making technology.  

If these rights apply to you, you may exercise them by contacting us at [email protected]. These rights are not absolute and may not apply in all jurisdictions. We may decline your request where permitted by applicable law.  

Interview Recording and Transcriptions 

When you participate in an interview, we may use third-party tools to help streamline the interview process. This may include automated interview recording, transcription, and note-taking technologies, including tools that incorporate artificial intelligence. We will provide you with advance notice and obtain your consent or an opportunity to opt out before any such recording or transcription occurs. 

Data Sharing and Categories of Third Parties 

We will disclose your personal information to the following recipients: 

• Employees, hiring managers, recruitment agencies, and other authorized personnel involved in the recruitment process 

• Affiliates 

• Service providers and contractors 

• Legal and regulatory authorities, if required  

• Parties involved in a business transaction, such as a merger or acquisition, if applicable 

We may use third-party service providers, including providers of recruitment and interview tools, for various purposes, including, but not limited to, obtaining employment verification and background checks where permitted by applicable law.  

We do not permit our third-party service providers to use your personal information for their own purposes and require them to use personal information only to provide services to us and in accordance with our contractual requirements.  

We may also disclose your personal information for the following additional purposes where permitted or required by applicable law: 

• As part of our regular reporting activities to other members of our group of companies. 

• To comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders. We will disclose personal information only as necessary in such circumstances.  

• During emergency situations or where necessary to protect the safety of persons. 

• If a business transfer or change in ownership occurs. 

• For other purposes with your consent (where required by applicable law). 

Cross-Border Data Transfers 

Where applicable law permits, TextNow may transfer the personal information collected about you to other jurisdictions outside of Canada and the United States, as may be necessary for the purposes set out in this Privacy Policy (e.g. transfer of information to service provider operating in another jurisdiction). Any personal information transferred outside of the United States and Canada is subject to the laws of those jurisdictions, and may be accessed by the courts, law enforcement and national security authorities of those jurisdictions.  

Data Retention 

If you are offered and accept employment with the Company, the personal information we collect during the application and recruitment process will become part of your employment record, and we may use it in connection with your employment consistent with our employee personal information policies.  

If you are not hired, we generally retain your application materials and related recruitment records for a period determined based on the nature of the information and applicable legal and operational requirements unless a longer retention period is required by law.  

Retention periods are determined based on the nature of the information, the purposes for which it was collected, applicable legal requirements, and business and operational needs. 

Your Privacy Rights  

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the recruitment process.  Depending on where you reside, you may have certain rights regarding your personal information, subject to applicable law. These rights may include the ability to request access to the personal information we hold about you, request correction of inaccurate information, request deletion of your information, or object to or restrict certain processing activities. If you are entitled to such rights, and want to review, verify, correct, or request deletion of your personal information, please contact us at [email protected]. Any such communication must be in writing. 

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information or cannot delete your information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.