سياسة خاصة
Your privacy is important to us.
To review the Applicant Global Privacy Notice, see below.
To review the Applicant Global Privacy Notice, see below.
INTRODUCTION
Align Group Members, as defined in the Binding Corporate Rules Policies (“Group Members”), are committed to protecting your personal information, as defined in the Binding Corporate Rules Policies. Align has issued this Privacy Notice ("Notice") on behalf of each of the Group Members to describe how we handle personal information we hold about job applicants, as mentioned in the Binding Corporate Rules Policies. For avoidance of doubt, the term "applicants" is used in this Notice to refer to anyone who applies for a job role, or who otherwise seeks to carry out work with or for us (whether on a permanent or non-permanent basis).
Please Note: Certain jurisdictions require us to include additional information to meet jurisdiction-specific requirements. Such jurisdiction-specific terms are contained in the following appendices and are incorporated by reference herein.
Appendix A (Russia): applies when a job applicant is located in Russia; Appendix B (China): applies when a job applicant is located in mainland China; Appendix C (Korea): applies when a job applicant is located in South Korea;
In the event of any conflict between the terms of this Notice and the terms of an Appendix regarding personal information subject to that Appendix, the terms of the Appendix shall prevail.
Where we refer to Align below, the reference is to the Align Group entity to which you have made an application (which will be the primary controller in relation to your personal information), e.g., For Australian applicants, the entity collecting your personal information is Invisalign Australia Pty Limited (ACN 098 357 736). If you are in any doubt, or have any comments or questions about this Notice, please contact us using the contact details set out below.
PERSONAL INFORMATION WE COLLECT
As a general rule, during the recruitment process, unless required by law in a specific country, we will not collect or process any of the following: information that reveals your racial or ethnic origin, religious, political or philosophical beliefs or trade union membership; genetic data; biometric data for the purposes of unique identification; or information concerning your health, sexual orientation or gender identity or expression or any other legally protected category (“Sensitive Personal Information”).
Align Group Members, as defined in the Binding Corporate Rules Policies (“Group Members”), are committed to protecting your personal information, as defined in the Binding Corporate Rules Policies. Align has issued this Privacy Notice ("Notice") on behalf of each of the Group Members to describe how we handle personal information we hold about job applicants, as mentioned in the Binding Corporate Rules Policies. For avoidance of doubt, the term "applicants" is used in this Notice to refer to anyone who applies for a job role, or who otherwise seeks to carry out work with or for us (whether on a permanent or non-permanent basis).
Please Note: Certain jurisdictions require us to include additional information to meet jurisdiction-specific requirements. Such jurisdiction-specific terms are contained in the following appendices and are incorporated by reference herein.
Appendix A (Russia): applies when a job applicant is located in Russia; Appendix B (China): applies when a job applicant is located in mainland China; Appendix C (Korea): applies when a job applicant is located in South Korea;
In the event of any conflict between the terms of this Notice and the terms of an Appendix regarding personal information subject to that Appendix, the terms of the Appendix shall prevail.
Where we refer to Align below, the reference is to the Align Group entity to which you have made an application (which will be the primary controller in relation to your personal information), e.g., For Australian applicants, the entity collecting your personal information is Invisalign Australia Pty Limited (ACN 098 357 736). If you are in any doubt, or have any comments or questions about this Notice, please contact us using the contact details set out below.
PERSONAL INFORMATION WE COLLECT
As a general rule, during the recruitment process, unless required by law in a specific country, we will not collect or process any of the following: information that reveals your racial or ethnic origin, religious, political or philosophical beliefs or trade union membership; genetic data; biometric data for the purposes of unique identification; or information concerning your health, sexual orientation or gender identity or expression or any other legally protected category (“Sensitive Personal Information”).
Also, in some circumstances, we may collect, or request on a voluntary disclosure basis, some Sensitive Personal Information for legitimate recruitment-related purposes: for example, information about your racial/ethnic origin, gender and disabilities for the purposes of equal opportunities monitoring, to comply with anti-discrimination laws and for government reporting obligations (generally individual personal information is not shared in such reports); information about your physical or mental condition to consider accommodations for the recruitment process and/or subsequent job role, etc.
We collect personal information about several different types of individuals; this notice covers applicants only. Consumers, customers, employees, nonemployee workers, and patients should consult the respective privacy notices. For applicants, we collect the personal information below about you to the extent you apply for employment at Align or related company.
In the last twelve (12) months, the personal information we collected for the application process and our reasons for doing so are demonstrated in the table below. Examples of personal information we collect and process when you apply for a role with Align can be found in the table below.
You can visit the recruitment section of our recruitment partner's website https://jobs.aligntech.com/ ("Website") and search for jobs without providing personal information. However, we do collect certain information automatically from your device when you visit our Website. For further information, please see the privacy notice that applies to the use of our Website http://www.aligntech.com/privacy_policy.
SOURCES AND BUSINESS PURPOSES OF PERSONAL INFORMATION
We process personal data, which we receive from you by post or email or which you transmit to us via personnel service and recruiting providers during the course of contacting you or submitting your application.
We collect and use this personal information primarily for recruitment purposes – in particular, to determine your qualifications for employment and to reach a hiring decision. This includes assessing your skills, qualifications, and background for a particular role, verifying your information, carrying out reference checks or background checks, confirming sanction and embargo compliance, general research to verify the information that you have provided, and to generally manage the hiring process and communicate with you and internal stakeholders about it.
If you are accepted for a role at Align, the information collected during the recruitment process will form part of your ongoing staff member record and will be processed in accordance with our Employee Privacy Notice.
| Personal Information Category | Data Details | Sources | Business Purposes | Service Provider Category Description | Identifiers |
Direct and indirect identifiers including name, addresses, and contact information, such as personal and work email addresses, alternative contact details for account recovery purposes, and government identification numbers, license, and passport. Sensitive personal data where required by law. | The applicant, our recruitment systems and platform. | Verify applicant information, including compliance investigations, confirming sanction and embargo compliance, to monitor and ensure a good candidate onboarding experience, SEC related party compliance, and generally manage the hiring process with applicant and internal hiring team. Align keeps logs for error and product improvement activities. When information is collected in system logs, it is possible that personal information is incidentally captured and used to resolve the error. | Third party and Align systems, including, data storage, shared services, recruitment platform providers, IT developers, HR support providers, providers of hosting services in relation to our careers websites, and third parties who provide support and advice including in relation to legal, financial/audit, and compliance investigations.
| Protected Classifications and Sensitive Personal Records | Birth date and place, marriage status, photo, information about family members including gender, birth date and certificate, gender/gender identity, national origin, religion, ethnicity, disabilities, health data, and social security numbers. | The applicant. | Verify applicant information, including in compliance investigations, generally manage the hiring process, to monitor and ensure a good candidate onboarding experience, confirming sanction and embargo compliance, SEC related party compliance, and communications with the applicant. | Third party and Align systems, including, data storage, shared services, recruitment platform providers, IT developers, HR support providers, providers of hosting services in relation to our careers websites, and third parties who provide support and advice including in relation to legal, financial/audit, and compliance investigations.
| Employment or Professional Records | Previous employers, previous job titles/positions, compensation expectations or history, academic/professional | The applicant, references provided by applicant, prior employers, academic institutions and training or certification providers, our recruitment platform and | To assess the applicant’s skills, qualifications, and background for a particular role, verify the applicant’s information, including | Third party and Align systems, including, data storage, shared services, recruitment platform providers, IT developers, HR support providers,
Direct and indirect identifiers including name, addresses, and contact information, such as personal and work email addresses, alternative contact details for account recovery purposes, and government identification numbers, license, and passport. Sensitive personal data where required by law. | The applicant, our recruitment systems and platform. | Verify applicant information, including compliance investigations, confirming sanction and embargo compliance, to monitor and ensure a good candidate onboarding experience, SEC related party compliance, and generally manage the hiring process with applicant and internal hiring team. Align keeps logs for error and product improvement activities. When information is collected in system logs, it is possible that personal information is incidentally captured and used to resolve the error. | Third party and Align systems, including, data storage, shared services, recruitment platform providers, IT developers, HR support providers, providers of hosting services in relation to our careers websites, and third parties who provide support and advice including in relation to legal, financial/audit, and compliance investigations.
| Protected Classifications and Sensitive Personal Records | Birth date and place, marriage status, photo, information about family members including gender, birth date and certificate, gender/gender identity, national origin, religion, ethnicity, disabilities, health data, and social security numbers. | The applicant. | Verify applicant information, including in compliance investigations, generally manage the hiring process, to monitor and ensure a good candidate onboarding experience, confirming sanction and embargo compliance, SEC related party compliance, and communications with the applicant. | Third party and Align systems, including, data storage, shared services, recruitment platform providers, IT developers, HR support providers, providers of hosting services in relation to our careers websites, and third parties who provide support and advice including in relation to legal, financial/audit, and compliance investigations.
| Employment or Professional Records | Previous employers, previous job titles/positions, compensation expectations or history, academic/professional | The applicant, references provided by applicant, prior employers, academic institutions and training or certification providers, our recruitment platform and | To assess the applicant’s skills, qualifications, and background for a particular role, verify the applicant’s information, including | Third party and Align systems, including, data storage, shared services, recruitment platform providers, IT developers, HR support providers,
| Personal Information Category | Data Details | Sources | Business Purposes | Service Provider Category Description
| | qualifications, and background information. | systems, publicly available sources like social media platforms, and third party background check providers and sources. Where permitted by local employment and/or data privacy legislation, Align may perform criminal background checks on candidates applying for positions where an individual’s criminal history and trustworthiness may be relevant. Where local employment and/or data privacy legislation prohibits Align from performing such checks, Align may request that the applicant provide Align with a copy. | in compliance investigations, carrying our reference checks or background checks, confirming sanction and embargo compliance, and to generally manage the hiring process and communicate with the applicant. | providers of hosting services in relation to our careers websites, and third parties who provide support and advice including in relation to legal, financial/audit, and compliance investigations.
| Internet or Network Activity | Information collected from the applicant’s device when the applicant visits our websites. | The applicant’s devices. | Confirming sanction and embargo compliance, SEC related party compliance, and to monitor and ensure a good candidate onboarding experience. | Third party and Align systems, including, data storage, shared services, recruitment platform providers, IT developers, HR support providers, providers of hosting services in relation to our careers websites, and third parties who provide support and advice including in relation to legal, financial/audit, and compliance investigations.
| Inferences | Drawn from other categories, like a background check, professional reference, or selection assessment. | The applicant, references provided by referees, academic institutions and training or certification providers, our recruitment platform, and publicly available sources like social media. | To generally manage the hiring process and employment offer decisions, and to monitor and ensure a good candidate onboarding experience. | Third party and Align systems, including, auditors, advisors, legal representatives, and similar advisers acting for legitimate business purposes and under a contractual prohibition of using the personal information for any other purpose.
| | qualifications, and background information. | systems, publicly available sources like social media platforms, and third party background check providers and sources. Where permitted by local employment and/or data privacy legislation, Align may perform criminal background checks on candidates applying for positions where an individual’s criminal history and trustworthiness may be relevant. Where local employment and/or data privacy legislation prohibits Align from performing such checks, Align may request that the applicant provide Align with a copy. | in compliance investigations, carrying our reference checks or background checks, confirming sanction and embargo compliance, and to generally manage the hiring process and communicate with the applicant. | providers of hosting services in relation to our careers websites, and third parties who provide support and advice including in relation to legal, financial/audit, and compliance investigations.
| Internet or Network Activity | Information collected from the applicant’s device when the applicant visits our websites. | The applicant’s devices. | Confirming sanction and embargo compliance, SEC related party compliance, and to monitor and ensure a good candidate onboarding experience. | Third party and Align systems, including, data storage, shared services, recruitment platform providers, IT developers, HR support providers, providers of hosting services in relation to our careers websites, and third parties who provide support and advice including in relation to legal, financial/audit, and compliance investigations.
| Inferences | Drawn from other categories, like a background check, professional reference, or selection assessment. | The applicant, references provided by referees, academic institutions and training or certification providers, our recruitment platform, and publicly available sources like social media. | To generally manage the hiring process and employment offer decisions, and to monitor and ensure a good candidate onboarding experience. | Third party and Align systems, including, auditors, advisors, legal representatives, and similar advisers acting for legitimate business purposes and under a contractual prohibition of using the personal information for any other purpose.
WHO WE SHARE YOUR PERSONAL INFORMATION WITH
We share certain personal data with Group Members to help us achieve the purposes set out above. We also partner with other businesses who provide employment related services to us and may share information about you for these purposes. These partners are not allowed to use your information for any purpose other than doing business with Align.
In addition to the services providers above, any information we collect, including personal information, may be disclosed to related entities and/or certain third parties, for example, as part of any actual or potential merger, acquisition, debt financing, sale of company assets, or similar transaction, as well as in the event of insolvency, bankruptcy, or receivership in which personal information could be transferred to third parties as one of our business assets. We may also disclose personal information about you to any competent law enforcement body, regulatory, government agency, court or other third party if we believe that doing so is legally required or is necessary to protect our property or other legal rights (including but not limited to enforcement of our agreements or the rights of others).
We may make certain personal information available to third parties who provide services relating to the recruitment process to us, including:
- Data storage, shared services and recruitment platform providers, IT developers and support providers and providers of hosting services in relation to our careers’ website,
e.g. Workday, iCIMS and Amazon Web Services.
- Third parties who provide support and advice including in relation to legal, financial / audit, management consultancy, insurance and health and safety issues, e.g.
Tentoo.
We may also disclose personal information to third parties on other lawful grounds, including:
- Where you have provided your consent;
- To comply with our legal obligations, including where necessary to abide by law, regulation or contract, or to respond to a court order, administrative or judicial process, including, but not limited to, a subpoena, government audit or search warrant;
- In response to lawful requests by public authorities (including for tax, immigration, health and safety, national security or law enforcement purposes);
- As necessary to establish, exercise or defend against potential, threatened or actual legal claims;
- Where necessary to protect your vital interests or those of another person; and/or
- In connection with the sale, assignment or other transfer of all or part of our business.
Align does not sell the personal information of applicants or otherwise share it for online advertising purposes.
TRANSFER OF PERSONAL AND SENSITIVE PERSONAL INFORMATION ABROAD
Align operates globally and protects your information when we transfer it to other countries. Your personal data may be transferred internationally to achieve our business purposes mentioned above. That involves sharing personal and sensitive personal data with Group Members including those other than your country/region of residence. The full details of the entities in the Align Group Members and where they are located is available here: http://investor.aligntech.com/index.php/static-files/3edcedc9-4451-4bd0- a8ad-151a6a94bf87.
Align operates globally and protects your information when we transfer it to other countries. Your personal data may be transferred internationally to achieve our business purposes mentioned above. That involves sharing personal and sensitive personal data with Group Members including those other than your country/region of residence. The full details of the entities in the Align Group Members and where they are located is available here: http://investor.aligntech.com/index.php/static-files/3edcedc9-4451-4bd0- a8ad-151a6a94bf87.
We use standard contractual clauses or Align's Binding Corporate Rules, both of which are recognized by the appropriate government authorities.1 Our Binding Corporate Rules establish Align's approach to the protection and management of personal information globally.
In some cases, the sharing described above may result in your personal information being transferred to countries other than your country of residence. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).
Specifically, our third-party service providers operate around the world. This means that when we collect your personal information, we may process it in any of these countries.
However, where it is necessary to transfer your information outside of your country of residence to third party service providers and partners, we ensure that your information is protected by having in place appropriate safeguards, for example by our Binding Corporate Rules.
RETAINING AND DELETING YOUR PERSONAL INFORMATION
Align will retain your personal data only if it has an ongoing, legitimate need to achieve the purposes set out in this Notice, or otherwise communicated to you, or as required by law.
Align will retain your personal data only if it has an ongoing, legitimate need to achieve the purposes set out in this Notice, or otherwise communicated to you, or as required by law.
We store your personal data as long as this is necessary for the decision on your application. If you do not join Align as an employee or nonemployee worker and provided there is not a legal reason to retain your personal data, your personal data or application documents will be deleted a maximum of two years after completion of the hiring procedure (e.g., notification of the rejection decision), unless longer storage is requested, legally necessary or permissible. In addition, we only store your personal data to the extent required by law or in a specific case to assert, exercise or defend legal claims for the duration of a legal dispute.
If available, you may receive an invitation to join our talent pool following the application process. This allows us to consider you also in the future with suitable vacancies with our applicant selection. If we have received your corresponding consent, we will store your application data in our talent pool in accordance with your consent or future consent, as the case may be.
If the application procedure is followed by an employment or nonemployee worker relationship, an apprenticeship relationship or an internship relationship, your data will, as far as necessary and permissible, initially continue to be stored and then transferred to the personal file.
In the event that you have otherwise consented or agreed to your personal data being anonymized or being stored for a longer period of time, we will store it in accordance with your consent.
YOUR RIGHTS AND HOW TO EXERCISE THEM
Certain regions, states, and countries give their residents rights regarding their data privacy. You may therefore have some or all the following rights, or additional rights as provided under applicable law:
Certain regions, states, and countries give their residents rights regarding their data privacy. You may therefore have some or all the following rights, or additional rights as provided under applicable law:
- To request access to, copies of, correction of, updating of, or deletion of your personal information.
- To object to the processing of your personal information, ask us to cease or restrict processing of your personal information.
- To request data portability.
1 For example, when we transfer your information to some countries (such as Switzerland) from the European Economic Area (EEA) and the United Kingdom (UK), we can do so because relevant government authorities have identified that country as having adequate data protection laws. Transfers from the EEA or the UK to Switzerland will be carried out pursuant to the EU Commission decisions regarding these two countries' laws providing adequate level of protection.
If you have provided us consent to use or access your data as set out in this notice, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. Please also note that we may need to retain certain data for a period of time to comply with legal requirements.
Align, by law, will not discriminate in response to any privacy requests you make. To ensure that a request is genuine, we may need to take steps to verify your identity, or the identity of an agent making a request on your behalf. To exercise your data privacy rights, please submit a request here.
In addition, you have the right to appeal to a data protection supervisory authority if you are of the opinion that the processing of your personal data is not lawful. The right of appeal shall be without prejudice to any other administrative or judicial remedy.
SECURITY
The security of all personal information provided to Align is important to us and Align endeavors to take reasonable steps to implement adequate security measures designed to protect your personal information, which aim to protect against the destruction, loss, misuse and alteration, unauthorized disclosure, or access of the information under our control.
The security of all personal information provided to Align is important to us and Align endeavors to take reasonable steps to implement adequate security measures designed to protect your personal information, which aim to protect against the destruction, loss, misuse and alteration, unauthorized disclosure, or access of the information under our control.
Unfortunately, no data transmission over the Internet or storage of information can be guaranteed 100% secure. As a result, while Align strives to protect your personal information, we cannot ensure or warrant the security of any information you transmit to Align, and you do so at your own risk.
UPDATES
We may update this notice from time to time. When we do, we will list the last updated date at the beginning of the statement. Notice of such update and/or modification will be provided to your local Human Resources contact or to you directly if required by law. We encourage you to periodically review this notice to stay informed about how we collect, use, and share personal information.
We may update this notice from time to time. When we do, we will list the last updated date at the beginning of the statement. Notice of such update and/or modification will be provided to your local Human Resources contact or to you directly if required by law. We encourage you to periodically review this notice to stay informed about how we collect, use, and share personal information.
CONTACT US
If you believe we have made a mistake or inappropriately used your personal information, we want to know about it so we can make it right. You may also have the ability to contact local data authorities to raise your concern about our privacy practices. To complain to a data protection authority about our collection and use of your personal information in the circumstances prescribed by local data protection laws, include where we are in breach. For more information, please contact your local data protection authority. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
If you believe we have made a mistake or inappropriately used your personal information, we want to know about it so we can make it right. You may also have the ability to contact local data authorities to raise your concern about our privacy practices. To complain to a data protection authority about our collection and use of your personal information in the circumstances prescribed by local data protection laws, include where we are in breach. For more information, please contact your local data protection authority. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
If you have any questions about this privacy statement, your personal information, or your rights please contact:
Privacy Office: privacy@aligntech.com
Support: 1-888-822-5446
Align Technology Switzerland GmbH, Suurstoffi 22, 6343 Rotkreuz, Switzerland
Data Protection Officer: Align has a Data Protection Officer where required by law. Applicants may reach out with questions for the DPO at privacy@aligntech.com.
APPENDIX A (Russia):
The personal data processing policy (hereinafter referred to as the "Policy ") was developed in accordance with Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" This Policy defines the procedure for processing personal data and measures to ensure the security of the personal data of users of websites owned, administered, or used by Align. This Policy applies to all transactions performed in the Company with Personal Data using automation tools or without their use, as well as through mixed processing.
The personal data processing policy (hereinafter referred to as the "Policy ") was developed in accordance with Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" This Policy defines the procedure for processing personal data and measures to ensure the security of the personal data of users of websites owned, administered, or used by Align. This Policy applies to all transactions performed in the Company with Personal Data using automation tools or without their use, as well as through mixed processing.
Legal Basis
1. The legal basis for processing Personal Data of candidates are:
1. The legal basis for processing Personal Data of candidates are:
- Execution of a contract with a contractor ensuring that there is a legal basis for the processing of Personal Data
- Consent of the subject of Personal Data to the processing of Personal Data in the cases provided for by the Law "On Personal Data"
2. The need for processing to conclude an employment contract at the initiative of the Personal Data subject. The legal basis for the processing of Personal Data of Personal Data subjects - counterparties and their representatives are:
- Compliance with legal requirements (including the Civil Code of the Russian Federation and the Tax Code of the Russian Federation)
- Execution of an agreement with a counterparty
- Ensuring the rights and legitimate interests of the Company
3. The legal basis for the processing of Personal Data of applicants - clients and their representatives are:
- Compliance with legal requirements (including the Civil Code of the Russian Federation and the Tax Code of the Russian Federation)
- Conclusion and execution of the contract with the client
- Ensuring the rights and legitimate interests of the Company
4. The legal basis for the processing of Personal Data of applicants - medical workers are:
- Consent of the subject to receive advertising mailings
- Execution of a contract with a client
- Consent of the Personal Data subject to the processing of Personal Data in the cases provided for by the Law "On Personal Data", including signed by a simple electronic signature
5. The legal basis for the processing of Personal Data of applicants - representatives of authorized bodies of state power and local self-government are:
- Compliance with the requirements of the legislation of the Russian Federation
- Compliance with the requirements of the legislation of the Russian Federation
6. The legal basis for the processing of Personal Data of applicants - users of the Sites:
- Execution of an agreement with a Personal Data subject (User Agreement in the form of a public offer published on the Website on the Internet)
- Consent of the subject to the processing of Personal Data (as part of the completed web forms on the Site, if applicable)
- Consent of the subject to receive promotional mailings (as part of the completed web forms on the Site, if applicable)
- Consent of the Personal Data subject to the cross-border transfer of Personal Data (as part of the completed forms on the Site, if applicable), signed with a simple electronic signature.
The Company processes Personal Data if at least one of the following conditions exists:
- Personal Data processing is carried out with the consent of the Personal Data subject to the processing of this Personal Data;
- Personal Data processing is necessary to achieve the goals stipulated by an international treaty of the Russian Federation or the law, to exercise and fulfill the functions, powers and duties assigned to the Company by the legislation of the Russian Federation;
- Personal Data processing is necessary for the administration of justice, the execution of a judicial act, an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings;
- Personal Data processing is necessary for the execution of an agreement to which the Personal Data subject is a party or a beneficiary or guarantor, as well as to conclude an agreement on the initiative of the Personal Data subject or an agreement under which the Personal Data subject will be the beneficiary or guarantor;
- Personal Data processing is necessary to exercise the rights and legitimate interests of the Company or third parties or to achieve socially significant goals, provided that the rights and freedoms of the PD subject are not violated;
- processing of Personal Data allowed by the Personal Data subject for distribution;
- processing of Personal Data subject to publication or mandatory disclosure in accordance with federal law;
- in other cases provided for by the Law on Personal Data.
Obligations of the Company when a Personal Data subject applies to it
The Company is obliged to inform the Personal Data subject or his representative of information about the availability of Personal Data related to the relevant Personal Data subject, as well as to provide an opportunity to familiarize the applicant with these Personal Data when applying to the Personal Data subject or applicant’s representative or within 10 (ten) business days from the date of receipt of the request of the Personal Data subject or its representative, or within the same period give a reasoned response in writing containing a reference to the provision of part 8 of Article 14 of the Law "On Personal Data" or other federal law, which is the basis for such a refusal to provide information about the existence of Personal Data of applicant. The period may be extended by the Company by no more than 5 (five) business days if the Company sends a notice to the Personal Data subject indicating the reasons.
The Company is obliged to inform the Personal Data subject or his representative of information about the availability of Personal Data related to the relevant Personal Data subject, as well as to provide an opportunity to familiarize the applicant with these Personal Data when applying to the Personal Data subject or applicant’s representative or within 10 (ten) business days from the date of receipt of the request of the Personal Data subject or its representative, or within the same period give a reasoned response in writing containing a reference to the provision of part 8 of Article 14 of the Law "On Personal Data" or other federal law, which is the basis for such a refusal to provide information about the existence of Personal Data of applicant. The period may be extended by the Company by no more than 5 (five) business days if the Company sends a notice to the Personal Data subject indicating the reasons.
The Company is obliged to provide free of charge to the Personal Data subject or his representative the opportunity to familiarize himself with the Personal Data related to this Personal Data subject. Within a period not exceeding 7 (seven) business days from the date the Personal Data subject or his representative provides information confirming that the Personal Data is incomplete, inaccurate or out of date, the Company is obliged to make the necessary changes. Within a period not exceeding 7 (seven) working days from the date of submission by the Personal Data subject or applicant’s representative of information confirming that such Personal Data are illegally obtained or are not necessary for the stated purpose of processing, the Company is obliged to destroy such Personal Data. The Company is obliged to notify the Personal Data subject or applicant’s representative of the changes made and the measures taken and take reasonable measures to notify third parties to whom the Personal Data of this subject was transferred.
Obligations of the Company to clarify, block and destroy Personal Data
In the event that inaccurate Personal Data is detected when the Personal Data subject or representative applies, or at their request or at the request of the authorized body for the protection of the rights of Personal Data subjects, the Company is obliged to block the Personal Data related to this Personal Data subject, or ensure blocking (if the Personal Data processing is carried out by another person, acting on behalf of the Company) from the moment of such application or receipt of the specified request for the period of verification, if the blocking of Personal Data does not violate the rights and legitimate interests of the Personal Data subject or third parties.
In the event that inaccurate Personal Data is detected when the Personal Data subject or representative applies, or at their request or at the request of the authorized body for the protection of the rights of Personal Data subjects, the Company is obliged to block the Personal Data related to this Personal Data subject, or ensure blocking (if the Personal Data processing is carried out by another person, acting on behalf of the Company) from the moment of such application or receipt of the specified request for the period of verification, if the blocking of Personal Data does not violate the rights and legitimate interests of the Personal Data subject or third parties.
If the fact of Personal Data inaccuracy is confirmed, the Company, based on the information provided by the Personal Data subject or his representative or the authorized body for the protection of the rights of P Personal Data subjects, or other necessary documents, is obliged to clarify the Personal Data or ensure their clarification (if Personal Data processing is carried out by another person acting on behalf of the Company) within 7 (seven) working days from the date of submission of such information and remove the blocking of Personal Data.
In case of detection of illegal processing of Personal Data carried out by the Company or a person acting on behalf of the Company, the Company, within a period not exceeding 3 (three) business days from the date of this discovery, is obliged to stop illegal processing of Personal Data or ensure the termination of illegal processing of Personal Data by a person acting on behalf of Company. If it is impossible to ensure the legality of Personal Data processing, the Company, within a period not exceeding 10 (ten) business days from the date of detection of illegal Personal Data processing, is obliged to destroy such Personal Data or ensure their destruction.
If the goal of Personal Data processing is achieved, the Company is obliged to stop processing Personal Data or ensure its termination (if Personal Data processing is carried out by another person acting on behalf of the Company) and destroy Personal Data or ensure their destruction (if Personal Data processing is carried out by another person acting on behalf of the Company) within the time limit , not exceeding 30 (thirty) days from the date of achieving the goal of Personal Data processing, unless otherwise provided by the agreement to which the Personal Data subject is a party, beneficiary or guarantor, another agreement between the Company and the Personal Data subject, or if the Company is not entitled to process Personal Data without consent subject of Personal Data on the grounds provided for by the Law "On Personal Data" or other federal laws.
If the Personal Data subject withdraws consent to the processing of his Personal Data, the Company is obliged to stop their processing or ensure the termination of such processing (if the Personal Data processing is carried out by another person acting on behalf of the Company) and if the Personal Data is no longer required for the purposes of Personal Data processing, destroy the Personal Data or ensure their destruction (if the processing of Personal Data is carried out by another person acting on behalf of the Company) within a period not exceeding 30 (thirty) days from the date of receipt of the said withdrawal, unless otherwise provided by the agreement to which the Personal Data subject is a party, beneficiary or guarantor , another agreement between the Company and the Personal Data subject, or if the Company is not entitled to process Personal Data without the consent of the Personal Data subject on the grounds, provided for by the Law "On Personal Data" or other federal laws.
If it is not possible to destroy the Personal Data within the period specified above, the Company blocks such Personal Data or ensures their blocking (if the Personal Data is processed by another person acting on behalf of the
Company) and ensures the destruction of the Personal Data within no more than 6 (six) months, unless a different period is established by federal laws.
The Company is also obliged to comply with the requirements to inform the authorized body for the protection of the rights of Personal Data subjects about incidents with Personal Data in the manner prescribed by part 3.1. Art. 21 of the Law "On Personal Data".
KEEPING THE SECURITY OF PERSONAL DATA
The security of Personal Data processed by the Company is ensured by the implementation of legal, organizational, and technical measures necessary to meet the requirements of federal legislation in the field of Personal Data protection.
To prevent unauthorized access to Personal Data the Company applies the following organizational and technical measures:
- appointment of officials responsible for organizing the processing of Personal Data;
- limiting the composition of persons admitted to the processing of Personal Data;
- familiarization of subjects with the requirements of federal legislation and regulatory documents of the Company for the processing and protection of personal data;
- organization of accounting, storage and circulation of media containing information with Personal Data;
- identification of threats to the security of personal data during their processing, the formation of threat models on their basis;
- development of a Personal Data protection system based on the threat model;
- verification of the readiness and effectiveness of the use of information security tools;
- differentiation of user access to information resources and software and hardware for information processing;
- registration and accounting of actions of users of Personal Data information systems;
- use of anti-virus tools and means of restoring the Personal Data protection system;
- the use, if necessary, of firewalls, intrusion detection, security analysis and cryptographic information protection;
- organization of access control to the territory of the Company, protection of premises with technical means of processing Personal Data. The right of the Personal Data subject to access their Personal Data may be limited in accordance with federal laws, including if:
- processing of Personal Data is carried out in accordance with the legislation on combating the legalization (laundering) of proceeds from crime and the financing of terrorism;
- access of the Personal Data subject to his Personal Data violates the rights and legitimate interests of third parties. The Personal Data subject has the right to require the Company to clarify his Personal Data, block or destroy it if the Personal Data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights. Requests/applications of Personal Data subjects and their representatives, authorized bodies regarding the inaccuracy of Personal Data, the illegality of their processing, withdrawal of consent and access of the Personal Data subject to their Personal Data must be sent in writing to the legal address of the Company or to the email address personal.data.russia@aligntech.com indicating:
- Full name of the Personal Data subject;
- essence of the request/appeal of the Personal Data subject;
- categories of Personal Data in respect of which the request/appeal is sent;
- contact details (addresses or e-mail addresses) to respond to a request/appeal;
- number of the main identity document of the Personal Data subject or his representative, information about the date of issue of the document and the issuing authority, information confirming the participation of the Personal Data subject in relations with the Company (for requests for access to Personal Data).
APPENDIX B (China):
Introduction
Introduction
Align Technology (Shanghai) Trading Co., Ltd. has issued this Privacy Notice (this "Notice") on behalf of each of the Align China Entities. Where this Notice refers to “we”, “us” or “Align China” below, the reference is to that Align China entity to which you have made an application (which is the primary controller in relation to your personal information), as identified in the table below. Should you have any doubt, or have any comments or questions about this Notice, please contact us using the contact details set out below.
| Align Technology (Chengdu) Healthcare Management Co., Ltd.
| Align Technology (Shanghai) Trading Co., Ltd.
| Align Technology (Chengdu) Co., Ltd.
| Align Technology (Sichuan) Medical Equipment Co., Ltd.
| Other legal entities established by Align Technology Inc. or its affiliates in the Peoples Republic of China, subject to the entity to which you have made an application
| Align Technology (Shanghai) Trading Co., Ltd.
| Align Technology (Chengdu) Co., Ltd.
| Align Technology (Sichuan) Medical Equipment Co., Ltd.
| Other legal entities established by Align Technology Inc. or its affiliates in the Peoples Republic of China, subject to the entity to which you have made an application
This Notice describes your personal information when you apply for a job or other role with us and the rights you have in connection with that information. The term "applicant"
is defined in the “Introduction” section of the Align Global Applicant Privacy Notice.
Legal basis and purposes for processing
Under applicable data protection law, our legal basis for processing your personal information as part of the recruitment process include:
Under applicable data protection law, our legal basis for processing your personal information as part of the recruitment process include:
- To comply with applicable immigration and/or employment laws and regulations;
- To take steps prior to entering an employment contract with you, where you are considered for employment;
- In circumstances where you have made the personal information public;
- Where we have your consent to do so, however where we have requested your consent to process your personal data, you have the right to withdraw your consent at any time; and
- To protect the rights and interests of Align's Group, our employees, applicants, and others, as required and permitted by applicable law.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
For the detailed purposes, please refer to the main body of the Align Global Applicant Privacy Notice.
Transfer of personal information abroad
As mentioned in the Align Global Applicant Privacy Notice, we operate at a global level to achieve the purposes referred to above. That involves sharing personal and sensitive personal data with other members of the Align Group, including those outside China. For details, please refer to Align’s website (available at: https://investor.aligntech.com/static-files/3edcedc9-4451-4bd0-a8ad-151a6a94bf87). When we share personal information with third-party service providers (as described in "Who we share your personal information with" in the Align Global Applicant Privacy Notice), that may also involve transferring information outside China.
As mentioned in the Align Global Applicant Privacy Notice, we operate at a global level to achieve the purposes referred to above. That involves sharing personal and sensitive personal data with other members of the Align Group, including those outside China. For details, please refer to Align’s website (available at: https://investor.aligntech.com/static-files/3edcedc9-4451-4bd0-a8ad-151a6a94bf87). When we share personal information with third-party service providers (as described in "Who we share your personal information with" in the Align Global Applicant Privacy Notice), that may also involve transferring information outside China.
However, we will transfer your information outside of China to our group companies and service providers and partners only when necessary and only for the purposes indicated in the Align Global Applicant Privacy Notice in order to comply with requirements of Chinese laws and regulation. By providing us your Personal Information, you agree to such transfers, processing and/or storage anywhere in the world, including the United States.
The measures we rely on to provide an adequate level of data protection are available on request by using the contact details below.
Your rights
Except as otherwise provided by applicable law, regulations, or policies, you have the following rights:
Except as otherwise provided by applicable law, regulations, or policies, you have the following rights:
- To request access to, correction of, updating of, or deletion of your personal information.
- To object to the processing of your personal information, ask us to restrict the processing of your personal information.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
CONTACT US
If you have any questions about this Notice, please contact us through:
If you have any questions about this Notice, please contact us through:
Name: Align Technology (Shanghai) Trading Co., Ltd.
Address: 25F, Ascendas Plaza No. 333, Tian Yao Qiao Road, Xuhui District, Shanghai
Email address: privacy@aligntech.com
APPENDIX C (Korea):
WE SHARE YOUR PERSONAL INFORMATION WITH GOVERNMENT
In some circumstances, we may need to share certain personal information with the government for emergency, public health, or other legitimate purposes. Please see the PIPC page for details.
In some circumstances, we may need to share certain personal information with the government for emergency, public health, or other legitimate purposes. Please see the PIPC page for details.
TRANSFER OF PERSONAL INFORMATION ABROAD
If you are a resident in South Korea, please note that we may transfer your information outside of South Korea to entrust/share our affiliates worldwide and third-party service providers (see details below) to process the personal data in accordance with the purpose, methods and retention period listed in this Notice.
If you are a resident in South Korea, please note that we may transfer your information outside of South Korea to entrust/share our affiliates worldwide and third-party service providers (see details below) to process the personal data in accordance with the purpose, methods and retention period listed in this Notice.
Recipient of personal data: All affiliates of Invisalign Korea Yuhan Hoesa (see details as shown the section “Who we share your personal information with”). For details, please refer to Align’s website. And third-party service providers with whom we share personal information (as described in "Who we share your personal information with").
Purpose of use of personal data provided by the recipient: subject to the section “sources and business purposes of personal information?”
Categories of personal data transferred: Each item of personal data collected by Align. Recipient’s retention and use period: When the purpose of consignment/provision is achieved. Data transfer date and method: online at any time
CONTACT US
If you have any questions about this Notice, please contact: privacy@aligntech.com; or Invisalign Korea Yuhan Hoesa, Attention: Privacy Officer, 8th Floor, Parnas Tower ,521 Teheran-ro, Gangnam-gu, Seoul.
If you have any questions about this Notice, please contact: privacy@aligntech.com; or Invisalign Korea Yuhan Hoesa, Attention: Privacy Officer, 8th Floor, Parnas Tower ,521 Teheran-ro, Gangnam-gu, Seoul.
If you need to report or consult on other privacy infringements, please contact the following institutions:
- Privacy Infringement Report Center (privacy.kisa.or.kr / Phone no. 118)
- Cyber Crime Investigation Unit, Supreme Prosecutor’s Office (www.spo.go.kr / Phone no. 1301)
- Cyber Bureau of Investigation, National Police Agency (police.go.kr / Phone no. 182)