Global Applicant Privacy Policy

Lagom Kitchen Company, d/b/a Our Place, and its subsidiaries and affiliates (collectively, “Our Place”, “we,” and/or “our”) are committed to respecting your privacy and protecting your personal data. Global 

This Global Application Privacy Policy (“Policy”) is meant to promote transparency around the way we collect, use, disclose, transfer and store (collectively, “process”)  personal information about you as a job applicant in connection with our recruitment activities. 

While this Policy is intended to describe the broadest range of our global processing activities, those activities may be more limited in some jurisdictions based on local laws. For example, the laws of a particular country may limit the types of personal information we can collect or how we use that information. In those instances, we adjust our policies and practices to reflect the requirements of local law. The data controller in each case will be the Our Place entity to which the applicant submits his or her application, as specified below.

INFORMATION WE COLLECT

We collect information in connection with your application to work with us, which may include the following categories of personal information: 

 

Identifiers and Contact Details– such as your name, photograph, gender, pronoun(s), date of birth, address, telephone number, email address and references.

Education and employment history– such as your academic and professional qualifications, certifications, CV/resume, transcripts, previous employments,  employment references and information from publicly available sources such as professional networking sites (e.g. LinkedIn profile).

Job application information– such as the role you are applying for, your application and related documentation or communications, cover letters, information from assessments and interviews, travel details, compensation/benefits requests, relocation information and any other information you provide to us in support of and during the recruitment process.

National Identifiers– such as your passport, immigration status, work authorizations or visas.

Financial Information– such as your bank account information if needed to reimburse any travel expenses.
Reference information if you are offered a job, including information provided by third parties such as past employers, educational institutions and references.

Heath and safety information

Your decision to apply for a position and provide your personal information to us is voluntary. We will tell you if information is required to move forward with your application.

 

Sensitive Information: In certain countries such as the U.S., where permitted by law and on a voluntary basis, we may ask questions about race or ethnicity, veteran status and disabilities for specific purposes, such as to accommodate a disability or illness and to comply with legal obligations relating to diversity and anti-discrimination. You are entirely free to decide whether or not to provide such information and your application will not be affected either way. Except as specifically requested, we ask that you avoid submitting information which may qualify as sensitive information under applicable law, including race, religion, ethnicity, nationality, age, gender identity, sexual life or sexual orientation, medical or health information, genetic or biometric data, political opinions, political party or trade union membership and judicial data such as criminal records. 

Information About Others: If you provide us with personal information of a reference or any other individual as part of your application, it is your responsibility to obtain consent from that individual prior to providing such information to us.

HOW WE COLLECT YOUR INFORMATION

Most of the personal data we process is obtained directly from you, such as when you submit a job application or when we conduct a phone or in-person interview. We may also receive information about you from other sources, such as from your named references, persons who referred you for a position, recruiting agencies, third party recruitment sources and websites and publicly available sources such as your LinkedIn profile. Other individuals may give you your personal information when recommending you as a candidate for a specific position or our company in general. 

HOW WE USE YOUR INFORMATION

We use your personal information to evaluate a potential employment relationship with you and for other business purposes. This includes: 

• Assessment of your skills, qualifications, and suitability for the role; 

 

• Communication with you about the recruitment process; 

 

• Verification of your information and completion of reference checks if we offer you a position;

 

• Proactively researching your educational and professional background and skills and contacting you if we think you would be suitable for a role with us; 

 

• Managing and improving our recruitment process;

 

• Preparing an offer letter, if your application is successful;  

 

• Legal and compliance purposes, such as responding to suspected fraud, security incidents, or other illegal activity, exercising a legal claim, cooperating with law enforcement investigations and complying with applicable laws, regulations, legal processes or governmental requests; 

 

• Protecting the health, safety, property and rights of our employees and others, including in response to global pandemics;

 

• Other uses with your consent, which you may withdraw at any time; and

 

• Other legitimate interests, including our interests in considering candidates for current and future employment opportunities and creating an equitable and fair recruitment process. 

 

If we hire you, information we collect in connection with your application will become part of your employment record and used to manage the onboarding process and for other employment-related purposes in accordance with our internal employee privacy policy.

WHO MAY HAVE ACCESS TO YOUR INFORMATION 

Within Our Place: We may disclose your personal data to Our Place affiliates and its and their personnel who need to know the information, including personnel in the recruiting, human resources, legal and information technology departments, and in the department responsible for the position for which you are applying. 

Third-Party Service Providers: We may use third party service providers acting on Our Place’s behalf to perform some of the services described above. For example, we share certain information with service providers who facilitate our applicant tracking system, video interviews, travel booking and expenses, and reporting and analytics services. We also may share information about you with recruitment agencies working with us in relation to your recruitment as well as with our professional advisors, including accountants, auditors, lawyers, insurers and bankers. These service providers may change over time, but we will always use trusted service providers who we require to take appropriate security measures to protect your personal information in line with our policies. We only permit them to process your personal information for specified purposes and, as appropriate, in accordance with our instructions and the provisions of this Policy and applicable law.

Other Third Parties: In certain limited circumstance, we share and/or are obligated to share your personal information with other third parties, including (a) to comply with our obligations, to protect the rights and property of Our Place, our customers and the public, to cooperate with law enforcement investigations, and to detect and respond to suspected illegal activity and threats to the health or safety of any person or of our systems or services; (b) in connection with, or during negotiations of, any merger, joint venture, sale of company assets, financing, or acquisition of all or a portion of our business, assets or stock by another company (including in connection with any bankruptcy or similar proceedings); and/or (c) with your consent and at your direction.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

DATA RETENTION

If your application for employment is unsuccessful (or you withdraw from the process or decline our offer), we will retain your information for as long as reasonably required for the purposes described above, including complying with our legal obligations, resolving disputes and as necessary for our legitimate interests, such as to consider you for other current and future employment opportunities at Our Place. If you do not want us to contact you regarding other roles, please contact removeme@fromourplace.com. After this period, we will securely destroy your personal information in accordance with applicable laws and regulations. If your application for employment is successful, personal information gathered during the recruitment process will be retained during your employment in accordance with our internal employee privacy policy and retention policies. 

 

YOUR RIGHTS

You may have certain rights under U.S. and international privacy laws in relation to your personal information. This may include the right to access, rectify, port or erase certain personal information we have about you.  You may also have the right to object to and restrict certain processing of your data. Certain information may be exempt from such requests pursuant to applicable data protection laws. You can contact hello@fromourplace.com to exercise your rights in relation to your personal information. We will respond to your request consistent with applicable law. 

CALIFORNIA RESIDENTS 

The California Consumer Privacy Act (Cal. Civ. Code § 1798.100 et seq.), as amended, including by the California Privacy Rights Act of 2020 and its implementing regulations (the “CCPA”), provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of personal information, as well as rights to access and control personal information. The CCPA defines “personal information” to mean “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular” California resident. Certain information we collect may be exempt from the CCPA because it is considered public information (because it is made available by a government entity) or covered by a federal privacy law, such as the Gramm–Leach–Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act. To the extent that we collect personal information about you that is subject to the CCPA, that information, our practices, and your rights are described in the disclosures provided in this Policy.

Categories of Personal Information Collected: Over the preceding 12 months, we have collected the following categories of personal information: (1) identifiers, (2) characteristics of protected classifications under California or U.S. law, (3) internet or other electronic activity information, (4) audio, electronic, visual, thermal, olfactory, or similar information, (5) professional or employment-related information, (6) education information, (7) inferences, and (8) other information that identifies, relates, to, describes, or is otherwise reasonably capable of being associated with you. For examples of the precise data points we collect, please see “Information We Collect” above. 

Business Purposes for Collecting and Disclosing Information: We collect each category of personal information for the business purposes in the “How We Use Your Information” section above. 

Categories of Third Parties To Whom We Disclosed Information. We have disclosed each category of personal information to the categories of third parties listed in the “Who May Have Access To Your Information” section above.

Right to Request Access, Correction, and Deletion of Information. California residents have the right to (1) request to know more about the specific pieces and categories of personal information we collect, use, sell and disclose, (2) request deletion of their personal information, (3) request to correct inaccurate personal information we have collected about them and (3)  not be discriminated against for exercising their rights. California residents also have the right to limit our use of their sensitive personal information if we use such information to infer characteristics about them. We do not use any sensitive personal information for this purpose. You may make a request to know, delete  or correct your personal information, by emailing us at legal@fromourplace.com or calling us at 877-564-6404. Please note that we may retain certain information as required or permitted by applicable law.

Right to Opt Out of Sale or Sharing of Personal Information to Third Parties. The CCPA requires that we provide transparency about the personal information we "sell" or “share” to third parties. The CCPA defines “selling” personal information as disclosing it to a third party for valuable consideration. “Sharing” is defined as the disclosure of personal information to a third party for “cross context behavioral advertising,” whether or not for monetary or other valuable consideration. We currently do not sell applicant personal information to any third parties nor share applicant personal information for cross context behavioral advertising. Please note that the right to opt out does not apply to our sharing of data with service providers, who are parties we engage to perform a function on our behalf and are legally and contractually obligated to use the data only for that function or as otherwise permitted by law.

EUROPEAN (INCLUDING UK) RESIDENTS

If European privacy laws apply to you, our processing of personal information for the purposes mentioned above is based on the following legal grounds:

• As necessary to evaluate and potentially enter into an employment relationship with you; 
• With your consent, which you may withdraw at any time;
• To comply with our legal obligations;
• Where necessary to protect your vital interests or those of others; and
• For our (or others’) legitimate interests, including our interests in considering candidates for current and future employment opportunities and in managing and improving our recruitment and hiring process, unless those interests are overridden by your interests or fundamental rights and freedoms. 

 

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use personal information for an unrelated purpose, we will notify the relevant individual and we will explain the legal basis which allows us to do so. Where the collection or processing of personal information is based on your consent, you may withdraw your consent at any time to the extent permitted by applicable law.

INTERNATIONAL DATA TRANSFERS

Due to the global nature of our business, Our Place may transfer your personal information across international borders, consistent with applicable data protection laws, including to the U.S., UK and European Economic Area (“EEA”).  Where EEA personal information is transferred within Our Place to countries outside of the EEA that are not recognized as providing an adequate level of protection under European privacy laws, we do so through a series of intercompany agreements that implement the Standard Contractual Clauses authorized under European privacy laws. We also use a variety of safeguards to ensure that your personal information is adequately protected when processed by our third-party service providers operating in the U.S. or another country outside of the EEA including by signing EU standard contractual clauses. You may request additional information concerning such safeguards by contacting hello@fromourplace.com.

SECURITY

Our Place is committed to protecting the security of your personal information and ensuring a level of security appropriate to the risk our data processing presents. Taking into account the costs of implementation, the sensitivity of the data and nature of the data processing, Our Place has implemented organizational, technical and administrative measures to prevent the unauthorized access, destruction, loss, alteration or misuse of personal information. 

DATA CONTROLLER

If you apply to a position in the U.S., Lagom Kitchen Company will be the data controller of your personal information. If you reside in the United Kingdom or EEA, or apply to a position in the EEA, Our Place U.K. Ltd. will be the data controller. 

APPLICABILITY OF OTHER POLICIES

This Policy does not cover our processing of information collected from you as an Our Place customer or as a visitor to Our Place-affiliated websites. To learn more about Our Place’s data collection practices in these cases, please see our website privacy policy.

CONTACTING OUR PLACE

If you have questions or concerns regarding this Policy, please contact us using the information provided below. 

Lagom Kitchen Company Our Place U.K. Ltd.

3924 Tuller Avenue 6th Floor, One London Wall

Culver City, CA 90230 London EC2Y 5EB

United States United Kingdom

Attn: Legal Attn: Legal
hello@fromourplace.com hello@fromourplace.com 

If European privacy laws apply to you and you have a concern about our processing of personal information that we are not able to resolve, you have the right to lodge a complaint with the relevant data privacy authority (this may be linked to where you reside, work or the place of any alleged infringement). For contact details of the relevant Data Protection Authority, please see  http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

POLICY UPDATES

We may change this Policy from time to time. The effective date of this Policy is noted in the header at the top of this page. If we make changes to this Policy that have a material impact on your rights with respect to how we process your personal information, we will post the revised version here and use other methods, as appropriate, to notify you. By continuing the recruitment process after those changes become effective, you agree to be bound by the revised Policy

Last Updated: January 12, 2023