Candidate Privacy Statement
Updated July 1, 2023
Effective Date: July 1, 2023
Thank you for your interest in joining the HOTELA Family. HOTELA, its subsidiaries and affiliates, as identified to you during your employment application process, (“HOTELA,” “we,” or “us”) respect your privacy and recognize the responsibility that we have to protect your Personal Information. This Job Candidate Privacy Notice (“Notice”) describes how HOTELA collects, uses, shares, or otherwise processes your Personal Information during the employment application and recruitment process. This Notice applies to job applicants only and covers all employment positions to which you apply.
For purposes of this Notice, the term “Personal Information” refers to any information, or a combination of pieces of information, that allows you to be identified, and that is subject to, or otherwise afforded protection under, an applicable data protection law, statute, or regulation.
All information is provided by you on a voluntary basis, and you determine the type of extent of information that you provide to HOTELA. However, if you do not provide us the Personal Information that is necessary for us to consider your application (e.g., evidence of qualifications or work history), then we will not be able to process your employment application.
Collection of Personal Information
When you apply for a job at HOTELA, we will ask you (i.e., the candidate) to provide us with Personal Information about yourself so we can evaluate your application. We may collect and process the following categories of Personal Information about you:
• Contact Information: such as your name, address, email address, telephone, other contact information.
• Employment details: information in your curriculum vitae (“CV”), resume, cover letter, or similar documentation, or during the course of your interview or other engagement with us.
• Background information: educational background including degrees, certificates, transcripts, credit history and/or criminal background screenings (where relevant to your application and permitted under applicable law).
• Financial data: salary, tax information, benefits, expenses, company allowances, stock and equity grants
• Other unique information in your application that you choose to share with us, such as personal preferences, hobbies, social preferences, etc.
• Sensitive Personal Information: HOTELA does not request or require sensitive Personal Information regarding your religion, sexual orientation, or political affiliation in connection with your application. If you have a disability and would like for us to consider an accommodation, you may provide that information during the recruitment process. For some countries, HOTELA may also ask for information such as race, ethnicity, or gender for the purposes of monitoring our equal opportunity program and compliance. However, for the purposes of your application this information is voluntary. If you provide us with this information, it will not be considered in the hiring or selection process.
Sources of Information
Most often, we collect your Personal Information directly from you, such as through the application form or interview process. We may also collect Personal Information about, or related to you, from our recruitment vendors, background and credit check providers, public agencies responsible for assisting in the employment eligibility and verification process, publicly available sources, and your identified references We may also obtain information about you from public sources or third parties. For example, you may also choose to provide us with access to certain Personal Information stored by third parties such as job-related social media sites (e.g., LinkedIn). We do not request, and please do not provide us with, any details that can be used to access or control any of your social media accounts.
Collection of Usage Data
How We Use Personal Information
We use your Personal Information, as applicable law permits, or requires, to satisfy our employment application and recruitment process, or for our other legitimate business interests. For example, 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 completing employment, background and reference checks, which may be subject to your consent where required by applicable law.
• Communicating with you about the recruitment process and your application.
• Complying with our legal, judicial, regulatory, administrative, or other corporate requirements, including, but not limited to, requirements mandating that we conduct criminal record, or other background checks.
• Analyzing and improving our application and recruitment process, including by executing satisfaction surveys.
• Accommodating individuals who may have specialized needs during the employment process.
• Protecting the rights, interests, and property of HOTELA, other job applicants, employees, or the public, as required, or permitted, by law.
We will only use your Personal Information in accordance with this Notice. If we need to use your Personal Information for an unrelated purpose, we will, to the extent practicable, provide notice to you and, if required by law, seek your consent. We may use your Personal Information without your consent, where permitted by applicable law or regulation.
We will disclose your Personal Information within HOTELA to appropriate officials who are involved in the employment application and recruitment process. We may also disclose your Personal Information to our designated agents, or third-party service providers, who require such information to assist us with administering our employment application and recruitment process, including, but not limited to, obtaining employment verification and background checks. We will share your Personal Information with third parties when required to do so by law, or by regulatory requirements to which you, or we, are subject. We may share Personal Information where it is necessary to administer our working relationship with you, or where we have another legitimate business interests in doing so, such as where it is necessary for the operation of our business or defend our business or legal interests.
We may also share your Personal Information with potential acquirers or investors of HOTELA, or the business area in which you work. We may share your Personal Information in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some, or all, of HOTELA’s practice or assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by HOTELA, in any form or format, is among the assets transferred.
We Do Not Sell Your Personal Information
We do not sell, rent, or lease Personal Information that we have collected or retain about you to any other third-party for any purpose. Accordingly, we do not offer individuals the ability to “opt-out” of the selling of Personal Information because we do not engage in those practices.
HOTELA is global company, with its headquarters in Japan. The information (including Personal Information) that HOTELA collects and processes is stored in Japan, the local office to which you applied for employment, and any other country in which HOTELA operates. Please be aware that Japan and these other countries may not provide the same level of protections as the laws in your country. By continuing to provide us such information you hereby consent to your Personal Information being transferred to, and stored in, Japan and any other country in which HOTELA operates.
HOTELA is committed to protecting the security of your Personal Information, and we use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. However, no information system can be fully secure, so we cannot guarantee the absolute security of your personal information. Moreover, we are not responsible for the security of information you transmit to HOTELA over networks that we do not control, including the Internet and wireless networks. You provide us with any information and data at your own risk. The safety and security of your Personal Information also depends on you. Where we have given you (or where you have chosen) a user ID and password to access a HOTELA platform, you are responsible for maintaining the security and confidentiality of those log-on credentials and not revealing them to others. You must contact us immediately if you have to reason to believe that your user ID or password to our online platforms have been compromised.
Disclaimer: Your Obligations to Us
With regard to any Personal Information that you provide HOTELA, regardless of whether that Personal Information relates to you or a third-party, you must ensure, on a continuing basis, that (i) such Personal Information is accurate, relevant, and complete, (ii) you have the lawful basis to provide HOTELA with such Personal Information, and (iii) you have provided this Notice to, and/or received, consent from, any third-party whose Personal Information you have provided HOTELA. If you choose not to provide us with the Personal Information identified herein, then HOTELA may not be able to satisfy our own contractual or legal obligations, and, in such circumstances, employment with HOTELA may not be permissible. You acknowledge and agree that HOTELA shall not be held liable for any consequence directly resulting from these circumstances.
Data Privacy Rights
Depending on the jurisdiction in which you reside or HOTELA operates, you may have certain data protection rights. To exercise any of these data privacy rights, please contact us, or have your authorized agent contact us, in accordance with the “Contact Us” section listed below. However, please note that the rights afforded under data protection laws are not absolute and often do not cover Personal Information collected or processed in accordance with the employment recruitment and application processes. Accordingly, HOTELA may be permitted to refrain from undertaking any action or changing its data processing activities, in response to a data request you submit to us.
We will only use your Personal Information in the manner described in this Notice. However, we reserve the right to change the terms of this Notice at any time by posting revisions to our website. If at any time, we decide to use your Personal Information in a manner that is different from that stated at the time it was collected, you will, to the extent required by law, be given notice of the same.
If you have questions, concerns, or comments related to how HOTELA processes your Personal Information, including whether you would like to exercise the rights and privileges described herein, please contact us at the following:
• In writing: ATTN: Office of Privacy Protection, Aoyama Center Building 2F, 2-8-40 Minami Aoyama, Minato-ku, Tokyo 107-0062 JAPAN
• Amendment Date: This Notice was last amended on July 31, 2023.