Recruitment Privacy Policy

Last Updated: November 25, 2022


Ginzamarkets, Inc (DemandSphere)., our subsidiaries, and affiliated companies (“DemandSphere”, “we”, “us”, and “our”) respect the privacy rights of individuals and are committed to collecting, maintaining, and using your personal information responsibly.

This Recruitment Privacy Policy (“Policy”) describes how DemandSphere collects, uses, stores, discloses, and otherwise processes the personal data we collect about Candidates in connection with job applications and/or our recruitment activities.

The term “Candidate” is used in this Policy to refer to anyone who applies for a job, or who otherwise seeks to work with or for us in any capacity (whether on a permanent or non-permanent basis or whether as an employee or individual independent contractor).

Please read this Policy carefully, together with any other privacy notices we may provide on specific occasions when we are collecting or processing your personal information.

This Policy does not create or form part of any contract for employment or otherwise.

Personal Information We Collect

When you apply for a job at or otherwise seek to work with DemandSphere, we will collect, use, and disclose personal information that we obtain directly from you as well as from third party sources.

Personal information provided directly by you

We will collect and process personal information that you provide us through the application and recruitment process, including when you visit the careers website we maintain at, or any other site where this Policy is posted (each, a “Careers Site”). Such personal information may include, but is not limited to:

  • Full name and other personal information, such as date of birth, place of residence, and contact information, such as telephone number and email address;
  • Employment history such as previous employers, job titles, positions, and references;
  • Academic, professional, and training information, including but not limited to academic degrees, certifications and professional qualifications;
  • CV/résumé (which may include details of any memberships, interests or other personal or sensitive information included therein);
  • National identifiers such as nationality/ies, national ID/passport information, social security/insurance numbers, immigration information, and visa status;
  • Information relating to previous applications made to DemandSphere and/or any previous employment history with DemandSphere;
  • Information concerning the Candidate’s application and our assessment of it; and
  • Any other information voluntarily provided during the recruitment process, including information that is provided online, through interviews, or other forms of assessment.

In certain cases we may ask you for additional information for the purpose of complying with applicable laws. We may also inquire about criminal records. We will do so only where permitted by applicable law.

If you fail to provide personal information which is necessary for us to consider your application (such as evidence of qualifications or work history) when requested, we may not be able to process your application further.

Information collected from other sources

  • References provided by your named referees;
  • Background information provided by academic institutions, background check agencies, and other outside database holders, such as credit reference agencies or professional registries;
  • Criminal records data obtained from criminal records checks;
  • Information provided by recruitment, executive search, and employment agencies; and
  • Information collected from publicly accessible sources, including any social media platforms you use, or other information available online.

Information collected here is only collected where permissible and in accordance with applicable law.

Information collected automatically

Like many other commercial websites, we use certain technologies, such as tools for collecting usage data, cookies, web beacons, pixels, and similar technologies, to automatically collect information that may contain personal information as you navigate our website, including the Careers Site. For more details, please see our Cookie Policy.

How We Use Your Personal Information

We use your personal information in our application and recruitment process for purposes including:

Recruitment management, such as:

  • Assessing your qualifications, skills, and interests against our career opportunities;
  • Verifying the information you or others provide and carrying out reference checks or conducting background checks (where applicable);
  • Facilitating the recruiting and interview process;
  • Preparing an offer letter, if your application is successful;
  • Managing and improving our recruitment processes;
  • Operating the Careers Site;
  • Producing management reports containing analyses related to recruiting metrics, such as length of the recruitment process;

Compliance, safety and fraud prevention, such as:

  • Complying with legal and other requirements, such as equal opportunities reporting and monitoring requirements, where applicable;
  • Complying with internal policies and procedures;
  • Complying with lawful requests and legal processes, such as responding to subpoenas or requests from government authorities;
  • Protecting our, your, or others’ rights, safety, and property;
  • Investigating and deterring against fraudulent, harmful, unauthorized, unethical, or illegal activity or conduct in violation of our policies or procedures; and
  • Sharing information with government authorities, law enforcement, courts, or private parties where we have a good-faith belief it is necessary for the foregoing purposes.

Analytics, such as creating anonymous, aggregated, or de-identified data that we use and share to analyze our application and recruitment activities, business, and for other lawful business purposes.

If you are offered and accept employment with DemandSphere, the information collected during the application and recruitment process will become part of your employment record.

If you are not successful, we may still keep information about your application for up to 5 years to allow us to consider you for other suitable openings within DemandSphere in the future. If you do not want us to retain your information for this purpose, please email us at privaс

How We Share Your Personal Information

To carry out the purposes outlined in the How We Use Your Personal Information above, your personal information may be shared internally with DemandSphere managers, HR and recruitment teams, systems administrators, and other members of the DemandSphere group of companies involved in your recruitment processes.

DemandSphere will not sell, rent, lease, or otherwise provide your personal information to unaffiliated third parties for their marketing purposes.

We take care to limit access to your personal information to only those who need access to perform their tasks and duties, and to third parties who have a legitimate purpose for accessing it. We may share personal information about you with third parties in the following circumstances:

  • Vendors, consultants, and other service providers: We may share your personal information internally and with service providers (in particular, hosting and other information technology services, background checking services, email communication, and analytics services), and other third parties (for example, recruiters, consultants, and attorneys), as necessary in connection with recruiting, employment, corporate governance, acquisitions, and legal or regulatory requirements.
  • Compliance with laws or law enforcement body, regulatory body, government agency, court, or third party: We may disclose information where we believe disclosure is necessary or required by law or regulation, to comply with legal process or government requests (including in response to public authorities to meet equal opportunity laws, national security, or law enforcement requirements); or to exercise, establish, or defend our legal rights.
  • Business transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, acquisition, dissolution, corporate reorganization, or similar event.
  • With your consent: We may disclose your personal information for any purpose with your consent.

Third Parties

This Policy does not address, and we are not responsible for, the practices of any third parties, which have their own rules for how they collect and use your personal information.

Data Security

We have implemented physical, technical, and administrative security measures designed to protect the confidentiality of the personal information we process. The Internet, however, cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any personal information you provide to us. It is your responsibility to protect the security of your login credentials for any account on our Career Site.

If you know or suspect that your personal data have been lost, stolen, misappropriated, or otherwise compromised, or in case of any actual or suspected unauthorized use of your DemandSphere account, please immediately contact us by email at


The Careers Site is not intended for minors under the age of 18.

Your Obligations

Among other obligations, including without limitation the obligation to provide complete and accurate information in the recruiting documents and information you provide, it is your responsibility to ensure that information you submit does not violate any third party’s rights.

Notice for European Candidates

We are providing this supplementary privacy notice to European Candidates, pursuant to European data protection laws, including the General Data Protection Regulation.

References to personal data in this Policy shall have the same meaning as “personal data” under European data protection laws.

Controller. DemandSphere is the controller of your personal data under the GDPR. In most cases, the controller for your personal data will be the DemandSphere entity to which you apply for work. You can find our contact information in the “How to Contact Us” section below.

Justification for Data Processing. European data protection law sets out a list of justifications on which companies may rely to process personal data, and requires companies to explain to data subjects the specific justifications for a company’s data processing activities with respect to the personal data it processes. DemandSphere generally relies on one of the following justifications to process your personal data:

  • Contractual Necessity: Where it is necessary to prepare and enter into an employment contract with you.
  • Legal Obligation: Where it is necessary to comply with our legal and regulatory obligations. For example, depending on applicable law, providing a safe place of work, avoiding unlawful discrimination, , fulfilling our obligations of tax and social declarations, and responding to relevant regulators, immigration authorities, and other government departments or public bodies.
  • Legitimate Interests: Where it is necessary for our legitimate business purposes, your interest, or the interests of a third party, unless those interests are overridden by your interests or fundamental rights and freedoms.. This includes our interests in considering candidates for current and future employment opportunities, and in managing and improving our recruitment and hiring processes.

There are circumstances in which we are required or permitted by local law to process special categories of personal data. For example, DemandSphere may be required to collect information about your racial/ethnic origin, gender, and disabilities for the purposes of equal opportunities monitoring, to comply with anti-discrimination laws, or for government reporting obligations. Similarly, information about your physical or mental condition may be collected in order to consider accommodations we need to make for the recruitment process and/or subsequent job role. You may also provide, on a voluntary basis, other special categories of personal data during the recruitment process. Our justification for processing this type of data is where it is necessary for exercising our obligations or your rights in the context of employment or social security law, for the establishment, exercise, or defense of a legal claim, or your explicit consent.

International Transfers of Your Personal Data: We may transfer your personal data to countries outside Europe, in particular to the United States and Japan. Those countries may have data protection laws less stringent than or otherwise different from the laws in effect in Europe. We have taken measures to protect your personal data in relation to these transfers, including executing Standard Contractual Clauses. For more information, please contact us at

How Long We Retain Your Personal Data: We retain your personal data for as long as needed to carry out the purposes described in this Policy or as otherwise required by applicable law. If you are offered and accept employment with DemandSphere, the information collected during the application and recruitment process will become part of your employment record. If you are not successful, we may still keep information about your application for up to 5 years to allow us to consider you for other suitable openings within DemandSphere in the future. If you do not want us to retain your information for this purpose, please email us at privaс

Your Rights: You have the:

  1. Right of access: You may request access to your personal data order to verify that your personal data is processed in accordance with law.
  2. Right to rectification: You may request the rectification of any inaccurate or incomplete data that we hold about you.
  3. Right to erasure: You may request that we erase personal data we hold about you.
  4. Right to restriction of processing: You may request that we restrict the processing of personal data we hold about you.
  5. Right to data portability: If required to do so, we will give you your personal data in a structured, commonly used and machine-readable format.
  6. Right to object: You may have the right to object to how we use your personal data.
  7. Right not to be subject to automated individual decision-making: You may request not to be subject to a decision based solely on automated processing, including profiling, which produces a legal effect concerning you or similarly significantly affects you.
  8. Right to lodge a complaint with a data protection authority: You have the right to complain to a data protection authority in your country about our processing of your personal data.

To exercise these rights, please contact us at


This Policy may be updated periodically to reflect changes in our privacy practices and applicable laws. In the event of significant changes, we will notify you by posting a prominent notice on our Career Site indicating the date of the most recent update at the top of the updated Policy. Any changes will become effective when we post the revised notice on our Career Site.

How to Contact Us

If you have any questions or concerns regarding this Policy or our use of your personal information, if you want to exercise your rights regarding your personal information, or to request an alternative format of this policy, please contact us at or by regular mail to:

Ginzamarkets, Inc. (DemandSphere)
100 E. Campus View Boulevard
Suite #250
Columbus, OH 43235
Attention: General Counsel

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