Effective Date: January 1, 2023
Thank you for your interest in Latch. Latch Systems, Inc. (“Latch”) values job applicants and is committed to protecting your privacy. This Applicant Privacy Notice (“Privacy Notice”) describes how Latch handles personal information obtained from and about job applicants during the application and recruitment process. It applies to personal information submitted directly by you, as well as by third-party agencies and recruiters on your behalf.
The terms “Latch,” “we,” “us”, and “our” include Latch and its affiliates and subsidiaries. The terms “applicant” or “you” include individuals who are interested in applying or who are actively applying for a job (as an employee) or a contract position (as a contractor). This Privacy Notice explains the categories of information we may collect, how we may use and share that information, and any rights you may have under local laws with respect to your personal information.
We will only process your personal information in accordance with this Privacy Notice unless required by applicable law. We take steps to ensure that the personal information we collect about you is relevant, accurate, proportional, and processed for specified purposes.
This Privacy Notice is a general guide on how Latch processes its job applicants’ personal information. Job applicants should be aware that data protection and privacy laws can vary in different jurisdictions where Latch conducts recruiting and hiring activities. Latch’s policy is to comply with applicable laws. Where applicable laws are stricter than the general practices described in this Privacy Notice, Latch has adopted privacy practices specific to those locations to satisfy those stricter requirements.
If you are a job applicant based in California, please see our Notice for California Job Applicants below.
If you are a job applicant based outside of the United States, please see our Notice for Non-U.S. Job Applicants below.
For purposes of this Privacy Notice, “personal information” means any information that identifies or is reasonably capable of being associated with an individual collected in connection with the recruitment process. Latch collects personal information directly from applicants and from third parties about applicants whose information is provided in connection with their application for employment. The types of personal information we collect will vary depending on the role you apply for, your location, the job location, and the conditions attached to the role (if any). Most of this information we collect directly from you. We also collect information about you from third parties, primarily background check providers, references you provided, and information contained in any widely distributed media (e.g., LinkedIn).
At the initial stages of recruitment, we may collect and further process the following types of personal information about you.
If you receive a conditional offer of employment or contract, we may collect and further process the following additional types of personal information about you:
If you accept your offer of employment or contract and begin your employment or contract with Latch, we will collect and further process additional personal information about you, including your date of birth, passport, driver’s license, Social Security number, and/or other government-issued identification number, emergency contact and beneficiary information, and other personal information, as described in “Latch’s Employee and Contractor Privacy Notice” that will be made available to you at the start of your employment or contract.
We process personal information identified in Section 3 above for the purposes listed below.
Latch takes care to allow your personal information to be accessed only by those who need to know to perform their tasks and duties, and by third parties who have a legitimate business purpose to access your personal information. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to keep that personal information confidential and not use it for any purpose except preforming the contract. We may share your personal information as described in this Privacy Notice to the following categories of third parties.
Latch retains applicant personal Information we receive as described in this Privacy Notice for as long as necessary to fulfill the purpose(s) for which it was collected, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes (including to consider you for future work if your application is unsuccessful), enforce our agreements, and comply with applicable laws.
Latch has implemented appropriate physical, technical, and organizational security measures designed to secure your personal information against accidental loss and unauthorized access, use, alteration, or disclosure. In addition, we limit access to personal information to those employees, agents, contractors, and other third parties that have a legitimate business need for such access.
California has created a common privacy framework for organizations that covers job applicants known as the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CPRA”). Latch is using that framework here to describe, for each category of personal information under the CPRA, whether Latch collects that personal information, or shares or discloses it for a business purposes related to your candidacy for employment at or provision of services to Latch. Latch does not sell your personal information. Any personal information that Latch holds may also be used to comply with applicable law.
|Category||Collected By Latch||Purpose||Disclosures to Third Parties|
This information is collected from you as part of your job application, except that Latch ID and other Latch-assigned identifiers are collected from Latch systems
|To administer and assess your candidacy for employment at or provision of services to Latch||Latch discloses this information to its service providers, including providers of interview and travel services|
|Protected classification characteristics under California or federal law||YES|
This information is collected from you as part of your job application or application to provide contractual services to Latch
|To comply with legal requirements; to evaluate and improve Latch’s diversity and inclusion efforts||Latch may disclose this information to service providers engaged for the purposes of advising on legal compliance|
This information is collected from you when you request reimbursement
|To provide you the expense reimbursements you have requested||Latch discloses this information to its service providers (e.g., TripActions)|
|Internet or other similar network activity||YES|
This information is collected from your device when connected to Latch’s system or network
|To administer access to Latch’s systems and to detect and prevent network vulnerabilities||N/A|
|Professional or employment- related information||YES|
This data is collected directly from you and from others (e.g., your references)
|To evaluate your eligibility for employment or contract||N/A|
|Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))||NO||N/A||N/A|
|Inferences drawn from other personal information||YES|
This information is collected from you and from others, including Latch employees and contractors who participate in your interviews and evaluation of your candidacy
|To evaluate your candidacy for employment or contract||N/A|
CPRA provides California residents with specific rights regarding their personal information. Below we describe your CPRA privacy rights and explain how to exercise those rights.
To exercise any of the rights described above, please submit a written verifiable consumer request to us by using the contact details under the Contact Us heading below. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must (1) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, and (2) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
Once we verify your identity through our identity-verification process, we will deliver our written response to the email address from which you sent us a request.
Unless you specify otherwise in your request, any disclosures we provide will only cover the period from January 1, 2022 forward, as required by the CPRA. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We value privacy rights of all our job applicants, including those who live and work outside of the United States. We process data of our non-U.S. job applicants as is described in this Privacy Notice. Additionally, certain jurisdictions outside of the United States may provide you with specific privacy rights under applicable data protection or privacy law with respect your personal data. We are committed to complying with applicable local laws. Depending on your local law you may have the right to:
These rights may be limited, for example, if fulfilling your request would reveal personal data about another individual, or if you ask us to delete personal data which we are required by law to keep or which we need to defend claims against us.
To exercise any of these rights, please contact us by using the contact details under the Contact Us heading below.
We will respond to such requests in accordance with the requirements of applicable data protection and privacy laws. Please note that in order to fulfil your request, we may need you to provide certain personal data to verify your identity. Depending upon applicable data protection and privacy law, you may also designate an authorized agent to exercise these rights on your behalf.
This Privacy Notice will be updated at least once every twelve (12) months to reflect any changes in our business, legal, or regulatory obligations. We will publish any updates to this Privacy Notice on www.latch.com prior to or at the time of the change becoming effective. We ask that you review the Applicant Privacy Notice periodically to stay informed about any updates or changes that we may have made. You can see when this Privacy Notice was last updated by checking the “Effective Date” displayed at the top of this Privacy Notice.
If you have any questions about our privacy practices or this Privacy Notice, please contact Latch by email at email@example.com