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Relay Candidate and Employee Privacy Notice

Relay Candidate and Employee Privacy Notice

1. About Us and This Privacy Notice

Relay, Inc. (“Relay”, “We”, “Us”, or “Company”) is committed to protecting the privacy and security of your Personal Information. This Candidate and Employee Privacy Notice (this “Notice”) provides increased transparency around how We collect and process Personal Information from the time you apply for a job with Us through the termination of your employment with Us. As such, this Notice applies to candidates for employment as well as current and former employees of the Company. It is important to read this Notice to understand our data practices, and it supplements any other notices or policies that may apply.

2. Key Definitions

  • Personal Information: Any information about an identified or identifiable person, or any information that can directly or indirectly identify a person. This generally excludes anonymous or de-identified data where the identity has been removed.
  • Sensitive Personal Information: Categories of Personal Information that require greater safeguards due to their sensitive nature. This may include information about racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, data concerning sex life or sexual orientation, and information relating to criminal convictions and offenses.
  • Processing: Any activity involving the handling of Personal Information, such as access, collection, storage, transfer, use, disclosure, retention, or modification.

3. Change of Purpose

We will only Process your Personal Information in accordance with this Notice unless otherwise required by applicable law or reasonably needed for another compatible purpose. We take steps to ensure that the Personal Information We collect about you is adequate, relevant, not excessive, and Processed for limited purposes.

4. Personal Information We Collect and Its Sources

4.1. Categories of Personal Information Collected

In connection with your candidacy or employment, We may collect, store, and use the following categories of Personal Information:

  • Personal Contact Information and Identifiers: Such as your first and last name, title, physical address, phone number, email address, employee identification number, and emergency contact details.
  • Demographic Data: Including gender, date of birth, age, race, ethnicity, nationality, citizenship, marital status, and sexual orientation.
  • National Identifiers: Such as social security number, national ID/passport, driver’s license, or other government identification numbers.
  • Employment Details: Your job title/position, employment contract, offer letter, hire date, termination date, performance history, disciplinary records, hours worked, office location, and proof of work eligibility (e.g., passport, visa, work permit details).
  • Education and Training: Education history and qualifications, professional memberships, certifications, skills, and training course completions.
  • Financial Information: Bank account details, payroll information, salary/remuneration expectations, compensation history, tax information, and Company allowances.
  • Background Information: Including references, employment history, and results from background checks (financial and criminal, where legally permissible and applicable).
  • Workplace, Device, Usage, and Content Data: Information related to your use of Company systems, networks, applications, devices, and facilities (e.g., electronic log files, badge activity, video/voice/image data, device geolocation, monitoring information from CCTV, and data from communication tools like email or chat).

4.2. Sensitive Personal Information

To support our legal and business activities, and as permitted by law, we may collect Sensitive Personal Information as part of our employment relationship with you. Examples of Sensitive Personal Information that we may collect include: race, ethnicity, sexual orientation, gender identity, disability status, religious beliefs, and health information. We will use this information to help Us maintain equal opportunities best practice and identify barriers to workforce equality.

4.3. How Your Personal Information is Collected

We may collect Personal Information from you directly (e.g., through your resume, application form, cover letter, interviews, or self-service portals). We may also obtain it from various other sources, including:

  • Your named referees and former employers.
  • Third-party recruitment agencies.
  • Background check providers.

5. How and Why We Use Your Personal Information

We will only use your Personal Information in accordance with applicable data protection laws and this Notice. Most commonly, We will use your Personal Information for the following legitimate business purposes:

  • Recruitment and Hiring: To assess your skills, qualifications, and suitability for roles, communicate with you about the recruitment process and future opportunities, manage interviews, and prepare offer letters.
  • Employment Administration: For onboarding new workers, general HR administration, maintaining employment records, and managing your interactions with workplace facilities and information systems.
  • Payroll, Compensation, and Benefits: To administer payroll, compensation, tax reporting, expense reimbursement, and manage benefits (including health insurance, pension, and other entitlements for you and your dependents/beneficiaries).
  • Performance Management, and Development: To conduct performance reviews, assess qualifications, administer training and coaching, identify career and growth opportunities, and support talent management.
  • Legal and Regulatory Compliance: To comply with applicable laws, regulations, legal obligations (e.g., health and safety, anti-discrimination, government reporting), internal policies, and to respond to legal processes (e.g., court orders, subpoenas) or lawful requests from public authorities.
  • Security and Fraud Prevention: To protect the security and integrity of our systems, processes, and business; and to prevent unauthorized access, prevent fraud, investigate alleged misconduct or policy violations, and monitor physical security systems (e.g., CCTV, badge scans).
  • Emergency Notifications: To communicate with you or your designated emergency contact in case of life/safety emergencies or natural disasters.
  • Equal Opportunity Monitoring and Accommodations: To ensure meaningful equal opportunity monitoring and reporting (where permissible), identify barriers to workforce equality, and provide appropriate adjustments or accommodations during the recruitment process or employment.
  • Corporate Transactions: In connection with mergers, acquisitions, sales, or other transfers of business assets.
  • General Business Operations: For overall business management, internal administration, communication, and collaboration.

6. Disclosure

We only share your Personal Information with those who have a legitimate business need for it. Whenever We disclose your Personal Information, We will ensure the Personal Information is used in a manner consistent with this Notice (and any applicable internal guidelines consistent with the handling of Personal Information). Your Personal Information may be disclosed to our affiliates and other third parties for the following legitimate purposes:

  • To enable third parties to provide services on behalf of Relay. Third party data recipients include, for example, recruitment agencies, IT service providers, payroll processors, benefits administrators, background check providers, data storage/hosting providers, and customer support. These providers are contractually required to protect your information.
  • To seek professional advice from external legal counsel or from external accountants and management consultants.
  • To comply with our legal obligations, regulations, respond to data subject rights, a court order, or administrative or judicial process.
  • In response to lawful requests by public authorities (such as regulatory bodies, law enforcement authorities, and national security organizations).
  • In connection with a corporate transaction or proceeding, including the sale, assignment or other transfer of all or part of our business.
  • Otherwise in accordance with your consent.

7. Data Security

We implement appropriate administrative, technical, personnel, and physical security measures to protect your Personal Information from accidental loss, unauthorized access, use, alteration, or disclosure. Access to your Personal Information is limited to employees, agents, contractors, and other third parties who have a business need to know and are subject to a duty of confidentiality. We have procedures in place to deal with suspected data breaches and will notify you and any applicable regulator where legally required.

8. Data Retention

We retain your Personal Information for no longer than is necessary to fulfill the purposes for which it was collected, and in accordance with our records retention policy and applicable laws and regulations. Once no longer needed, your Personal Information will be securely destroyed, erased, or anonymized. If We wish to retain your Personal Information for future opportunities, We will seek your explicit consent.

9. Your Privacy Rights

If you are a California resident, you can make certain requests regarding your Personal Information, and We will fulfill each request to the extent required by law. If We are unable to comply with your request in whole or in part, We will notify you with reasons for the denial.

Subject to applicable law, California residents have the following rights regarding your Personal Information:

  • Right to Know/Access: You can request to know what Personal Information We collect about you and access a copy of it.
  • Right to Rectification/Correction: You have the right to request the correction of inaccurate Personal Information We hold about you.
  • Right to Delete: You can request the deletion of your Personal Information, subject to exceptions provided under applicable law (e.g., if We have a legitimate reason for keeping it for legal compliance).
  • Right to Restrict Processing/Object: You may have the right to restrict or object to the Processing of your Personal Information in certain circumstances.
  • Right to Data Portability: If applicable, you may request your Personal Information be provided to you or a third party in a structured, commonly used, and machine-readable format.
  • Right to Withdraw Consent: Where Processing is based on your consent, you have the right to withdraw it at any time.
  • Non-Discrimination: We will not unlawfully discriminate or retaliate against you for exercising your privacy rights.

Please note that these rights are not absolute and may be subject to legal limitations and exceptions. We will verify your identity before processing your request.

10. Automated Decision-Making

We generally do not subject your Personal Information to decisions that would have a significant impact on you based solely on automated decision-making. Tools used to assist recruiters (e.g., AI-based screening) typically serve as a guide and do not supplant human judgment in final employment decisions.

11. Changes to This Privacy Notice

If We materially change the way We handle your Personal Information, We will update this notice. We reserve the right to make changes to this Notice and our practices at any time.

12. Contact Us

If you have any questions about this Notice, please contact Us at: legal@relaypro.com.

Effective: April 15, 2026