Last Updated: December 28, 2023

Pilot.com, Inc. Job Candidate Privacy Policy

We are excited that you are interested in Pilot.com, Inc. (“Pilot,” “we,” “us,” “our”)! We collect and process a variety of personal information from and about you as a job candidate in order to administer our recruiting and hiring function. This Job Candidate Privacy Policy (“Policy”) describes how we collect, process, use, disclose, and retain personal information that we obtain about you in the course of our recruiting efforts.

This Policy applies to personal information of individuals who Pilot’s recruiting function interacts with or sources as potential candidates (“you”), including through identification by Pilot’s recruiting function, job application submission, and the interviewing process. Our Privacy Policy describes the personal information that we collect regarding visitors to our corporate website (www.pilot.com) and applies to web pages containing a link to it.

This Policy contains the following sections:

1. What Personal Information Do We Collect?

We collect personal information that you voluntarily provide to us when you apply for a job or otherwise contact us in the recruiting context. This includes, for example, when you submit a job application to us through our careers website, you complete a form containing your personal information, or you include employment information like the content of your resume in communications with us.

We may also obtain personal information from sources other than you. We obtain information about potential job candidates from third parties. For example, recruiters may send us job application information that includes your personal information for an employment position that may interest you. Other third parties may refer you to our recruiting team and provide us with your contact information and relevant information about your experience or skills. We source candidates using LinkedIn and sourcing tools to find names, contact information, and qualifications (for example, employment and educational history) of potential candidates. We may also receive personal information about you from prior employers and professional references, educational institutions, credentialing and licensing organizations, consumer reporting agencies for employment background checks (as applicable and in accordance with applicable law), and other sources as may be directed by an applicant. In the course of the application and interview process, we generate additional personal information about you. For example, if you interview with us, our personnel who meet with you will ask you questions about your experience and skills in order to evaluate your ability to meet the business needs of the role that you are applying for. Interviewers then discuss their assessment of your ability to meet the business needs of the role to arrive at a final employment decision. For many roles, we administer assessments of applicant skills, the results of which we factor into our evaluation of your ability to meet the business needs of the role you have applied for.

The subsections below describe the categories of personal information you provide to us and categories of personal information that we obtain from other sources — in each case which we have obtained in the last twelve months. The section titled “How Do We Use Personal Information?” describes the purposes for which we use job candidate personal information.

Personal Information You Provide to Us

Category	Examples
Identifying Information	Legal name, preferred name, previous last name, date of birth, postal address or location, email address, phone number, last four digits of Social Security number, driver’s license number (which you provide to our background check provider)
Educational and Professional Background	Work history, academic, and professional qualifications and other information you include in your resume, responses to interview questions and assessment results, as applicable, and cover letter; whether you would seek to work for another employer while working at Pilot
Third Party Identifying Information	Name and contact information of references that you provide
Criminal history	With your consent, background check results
Employment eligibility	Whether you would need Pilot to sponsor visa now or in the future
Health information	If you request a reasonable accommodation, we collect disability information in accordance with applicable law and to the extent needed to evaluate and, as applicable, provide reasonable accommodation

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Personal Information We Obtain from Other Sources

Category	Examples
Identifying Information	Legal name, preferred name, email address, phone number
Educational and Professional Background	Work history, academic, and professional qualifications and other information you include in your resume or professional social media network profile
Recruitment information	Job interview notes, responses to screening questions, test scores and other assessment results, as applicable, information from reference checks, and any other information we gather from third parties in connection with the recruitment process
Inferences drawn from personal information	A profile reflecting your preferences, characteristics, predispositions, behavior, attitudes, abilities, and aptitudes

The above tables describe categories of personal information that we collect and process in the course of our recruiting efforts. It is possible that you may share other personal information that comes to our attention, for example, through social media or the news. We may also use this information for the purposes described below.

2. How Do We Use Personal Information?

We use your personal information for the following categories and subcategories of business purposes.

General Recruiting Purposes

Recruitment of Employees and Processing and Managing Job Applications: We use your personal information to process your job application. For example, we use your personal information to create an applicant profile in our application tracking system, evaluate your qualifications and skills against the requirements of the position for which you are applying, schedule and conduct interviews, and communicate with you.
Conducting Pre-Employment Screening and Background Checks. In accordance with applicable law, we use your personal information to conduct employment screening and background checks via third party service providers, as well as to conduct reference checks.
Operate and Improve our Recruiting Efforts.We use our recruiting experience to analyze and improve our recruiting efforts, which may include analyzing a particular candidate’s experience in the process. We analyze our recruiting pipeline, processes, and operations to assess, audit, and improve our recruiting program’s effectiveness.

Compliance

Recordkeeping.We keep records of your personal information as required by law and in accordance with our record retention policies.
Preventing Fraud or Illegal Activities. We process applicant personal information to detect, prevent, and respond to fraud, misuse of our recruiting process, and potentially illegal activities.
Compliance with Legal Requirements.We use your personal information to comply with applicable laws, regulations, and legal processes (such as responding to subpoenas or court orders), and to respond to legal claims, resolve disputes, and enforce our legal rights.

3. To Whom is Job Candidate Personal Information Disclosed?

We may disclose your personal information for the business purposes described above with the following parties:

Service Providers. We may disclose your personal information to service providers, such as recruiters, pre-employment screening services like a technical interviewing service, background check providers, and consultants who perform recruiting tasks. Note that many of our service providers provide software that enables the service providers to monitor usage of their software. For example, if you submit an application through our applicant tracking system on our website, the applicant tracking system provider may track your use of the provider’s software while you are using it and retain records of your interaction with the service. This usage data may include information that identifies you. Service providers’ use of this data is subject to the applicable service provider’s privacy policy.

Affiliates and Subsidiaries. We may disclose your personal information to our affiliates and subsidiaries.

Governmental Authorities and in Legal Matters. As required by law or legal process, we may disclose your personal information to federal or state regulatory agencies, law enforcement, courts, and other governmental authorities. In addition, we may be required to disclose your information in the context of civil litigation. When possible, we will endeavor to take steps to preserve the confidentiality of your personal information.

Professional Advisors. We may disclose your personal information to our professional advisors, such as auditors and law firms.

Parties Involved in Business Transfers. If we sell, merge, or transfer any part of our business, we may transfer to the acquirer information in our possession or control, including personal information.

Third Parties as Directed by You. If you request us to provide your personal information to a third party, we may provide personal information to the requested third party.

4. How Long Do We Keep Personal Information?

We retain your personal information as long as we have a business purpose to do so or as long as required by law. This generally means that we will retain your personal information for purposes of complying with legal requirements (by law we are required to retain certain information for a certain period), recruitment, processing and managing employment applications, and keeping a record of our relationship, and until the earlier of: (a) these purposes are fulfilled, which is currently indefinitely, or (b) your request that we delete your information (in which case, subject to any legal requirements or reasons to retain your information, we will take reasonable steps to remove or de-identify your personal information in our systems). Exceptions include retention periods that are set in our systems related to content (for example, some messaging systems normally have a retention period in place for certain messages after which they are deleted) or retention periods required by law or our internal recordkeeping policies.

5. How Can You Access Your Personal Information?

We encourage you to contact us to update or correct your information if it changes or if the personal information we have about you is incorrect. Please contact the Pilot representative that you are working with or privacy[at]pilot.com.

You may have certain rights regarding your personal information. For example, if you are a California resident and wish to exercise your rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA), and if you submit a verifiable consumer request, you have the right, subject to the CCPA, if and as applicable:

To receive disclosure of:

The categories of personal information that we have collected about you;
the categories of sources of the personal information we have collected about you;
the business or commercial purpose for our collecting, selling or sharing of personal information about you;
the categories of third parties to whom we disclose your personal information (please note that this Policy provides the information that we would provide upon verifiable request for this data category and the above three data categories);
the categories of personal information that we have sold or shared;
the categories of third parties to whom personal information was sold or shared;
the categories of third parties to whom personal information was disclosed for a business purpose; and
the specific pieces of personal information that we have collected about you (subject to applicable legal limitations);

To request deletion of your personal information by us, subject to applicable legal limitations;
To request correction of inaccurate personal information; and
To be free of discrimination on the basis of having exercised your rights under the CCPA.

In the past twelve months we have not “sold” or “shared” candidate information within the meaning of the CCPA in the context of our recruiting efforts described in this Policy. As is common, we use service providers for a variety of purposes from data storage to managing interview scheduling, and must disclose candidate personal information to these service providers for them to provide their services. We have not disclosed candidate personal information to third parties (as defined under the CCPA) in the past twelve months. The tables and sections above contain additional disclosures under CCPA Section 1798.110(c) and Section 1798.115(c)(2).

To our knowledge, we have not sold or shared personal information of consumers (as defined in the CCPA) under 16 years of age. For California residents: Pilot does not use or disclose sensitive personal information for purposes other than those specified in Section 7027(m) of the California Consumer Privacy Act Regulations. The purposes described in Section 7027(m) include performing services reasonably expected by an average California resident who requests the services; preventing, detecting, and investigating security incidents; resisting malicious, deceptive, fraudulent, or illegal actions directed at us; ensuring the physical safety of natural persons; short-term, transient use; performing services on our behalf; verifying or maintaining the quality of our Services; and/or other collecting or processing of sensitive personal information where the collection or processing is not for the purpose of inferring characteristics about a California resident.

6. Changes to This Policy

We may update, amend, or otherwise change this Policy from time to time at our discretion. Please refer to our posted Policy for our most current personal information processing practices.

7. How Can You Contact Us?

If you have any questions about the ways in which Pilot collects and uses your personal information described above, your choices regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: privacy[at]pilot.com. For rights exercise requests, we will generally verify your identity using information in your inquiry and data in our possession. We may ask you for additional information to verify your request.

The prior version of our Policy is available here.

A copy of this Policy marked over the prior version is available here.