Recruitment Privacy Policy

Introduction and Statement Scope

At Avalon Services Group, Inc. (“Avalon”) we are committed to protecting the personal information of all prospective Avalon personnel and handling information fairly, responsibly, and in accordance with applicable law.

This Recruitment Privacy Statement (“Privacy Statement”) describes how Avalon uses personal information in its recruitment practices.

In addition to this Privacy Statement, Avalon or authorized third parties may provide further supplementary transparency information to keep you informed (for example, during relevant touch points, or within emails, FAQs, briefings with you, or within the tools made available).

This Privacy Statement applies to all prospects or potential employees, applicants, or candidates, including in relation to any work, employee, engagement, contractor, intern, and other opportunities with Avalon. It also provides details on your personal information rights and how to exercise your Privacy Rights with us.

“Personal information” is information that relates to an identifiable individual processed by automatic means or potentially forming part of a structured manual filing system.

“Processing” or “Process” includes various personal information-based activities (for example, when Avalon collects, uses, discloses, deletes, transfers, and stores personal information).

Personal Information We Collect and Our Purposes.

Personal information we collect directly from you.

In connection with prospective personnel and our recruitment activities, Avalon may collect and process certain personal information. This may be collected directly from you when you apply for a role with Avalon or during in-person or online meetings.

You can apply for a role at Avalon using several third-party career sites, tools, or applications, such as Indeed and LinkedIn. Doing so will connect your profile from these systems with the Avalon job application(s).

Third-party sources.

We typically collect personal information directly from you (for example, when entering your personal information within any applications), but there may be situations where we collect personal information from other sources. Other personal information is generated during your application, for example, by our recruiting team and Avalon’s systems.

We may also collect the following information from third parties and information sources:

• Information provided by entities you have asked to support you in finding a job, including recruiting agencies, educational institutions, professional organizations, or alumni-sharing platforms.
• Information provided by Avalon personnel who have referred you for a job.
• Information provided by background-checking agencies, including (where permitted under applicable law) criminal background checks and security clearance checks (to the extent applicable to relevant government work), to verify the accuracy of the information you have provided.
• Information provided by referees in response to reference requests.
• Information collected from publicly available sources, including any business, professional, or social media platforms you use or other relevant information available online.
• Information provided in connection with potential target companies that may join the Avalon group through a merger, acquisition, or purchase of assets.

Sensitive Personal Information

The definition of sensitive personal information varies based on your jurisdiction but may include any information that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs; and data concerning your health, sexual orientation, trade union membership, biometric data, and criminal history; and the contents of your communications where Avalon is not an intended recipient, precise geolocation (“Sensitive Personal Information”). We do not collect or process any Sensitive Personal Information about you unless it’s to operate our business, for legitimate employment-related purposes, or where otherwise permitted by, or necessary to comply with, applicable laws.

For example, information about your racial or ethnic origin, gender (including gender identity), sexual orientation, and disabilities may be collected to assess, create, and cultivate a diverse and inclusive work environment or to comply with anti-discrimination laws and government or associated reporting obligations.

Aggregating and analyzing personal information.

Avalon may de-identify, aggregate, or anonymize your personal information for privacy and security purposes. This may include using information in de-identified reports, analyzing and presenting summaries for you in tools and/or for Avalon management in order to consider trends and people strategies for the workforce, or third-party learning opportunities. Aggregation may involve the de-identified information from other Avalon applicants or personnel and where relevant, comparing aggregated and pooled data with past or future personnel information, responses, industry benchmarks, and comparisons as well as relevant advice or research.

Successful applicants.

If you accept a role at Avalon, the information collected during the recruitment process may form part of your personnel file or profile to the fullest extent allowable and will be processed in accordance with our Employment Privacy Statement, which is available in our Employee Handbook.

Who we share your personal information with.

Avalon takes care to only access or disclose personal information to those teams or individuals internally and externally who require access to perform their legitimate tasks and duties in line with the purposes outlined above.

We will disclose your personal information to the following categories of recipients:

• Avalon’s recruiting team that administer the recruitment processes, including internal and external hiring managers, administrators, etc.
• Background-checking or other screening providers and third parties that verify employment history, academic and professional achievements, and assist with the collection and preparation of applications for security clearances for relevant projects (when necessary).
• Third-party service providers that support the Avalon recruitment process.
• Third parties such as courts, regulators, tribunals, or professional advisers to comply with our legal and regulatory obligations or address legal matters, including where necessary to abide by law, regulation or contract, or to respond to a court order, administrative, or judicial process.
• Third parties as necessary to establish, exercise, or defend against potential, threatened, or actual litigation.
• Public authorities and their authorized agents in response to lawful requests.
• Third parties where you have consented or otherwise instructed Avalon to share your personal information.

Avalon personnel authorized to access or discuss personal information must comply with confidentiality, privacy and security policy requirements.

We will implement appropriate measures to provide assurance that third-party organizations that we use to process data on our behalf use information in a manner consistent with this Privacy Statement and with applicable law, and that the security and confidentiality of the information is maintained. This is in addition to the privacy and security obligations applicable to the third party in connection with their processing. Third-party recipients may have their own privacy statements outlining their approach, which you may wish to consult.

Avalon does not “sell” to third parties, or “share” with third parties for targeted advertising purposes, the personal information that it collects or processes as part of the recruitment, employment, or personnel management process or any related processes (including as those terms are defined under the California Privacy Rights Act).

Legal Basis for Processing

Our legal basis or grounds for collecting and using your personal information as described in this Privacy Statement falls into the following categories under applicable law. The ground will depend on the information concerned and the specific context and purposes for which we collect it.

• Legitimate Interest: We process certain data for recruitment, employment, and corporate legitimate interests of Avalon and third parties and consider individual privacy impacts. Legitimate interests for Avalon and third parties include administering an efficient recruitment process now, managing and assessing applicants effectively, and Avalon’s future interests to reconnect talented individuals with future opportunities. We will not rely on this ground where your interests and fundamental rights outbalance and override in our reasonable view.
• Other Legal Bases: In some cases, we may have a legal obligation to process your personal information, such as in response to a court or regulator order. We also may need to process your personal information to protect vital interests, or to exercise, establish, or defend legal claims.
• Consent: In some cases, we ask you for your consent to process your personal information for specific activities/initiatives. You can withdraw your consent at any time, which will not affect the lawfulness of the processing before your consent was withdrawn. If you would like to withdraw your consent, you can do so by contacting us as provided in the “How to contact us” section below.

In some cases, such as background checks, you may also advise the third-party service provider of a consent withdrawal.

When personal information is required.

Avalon will inform you if there is a legal or recruitment business requirement to provide personal information. Generally, we will ask for what is reasonably necessary. If you are unable to provide the requisite information, we will explain any consequences or delays in respect of your applications. Avalon considers the various lawful bases available and the most suitable under applicable law.

Where Avalon or a third party seeks consent for certain processing purposes in accordance with applicable law, you should not feel obliged to provide this information. Consent is a voluntary ground. You will have a choice regarding the specific processing initiative and whether to provide the information.

We may have additional lawful bases and grounds where Sensitive Personal Information is processed.

Data Retention

Avalon securely stores and retains your personal information as long as needed to fulfill legitimate business purposes, including those described in this Privacy Statement and in accordance with applicable laws. As a summary indication, we keep personal information for a reasonable period:

• Following a recruitment process and our hiring decision in order to respond to potential legal, compliance, or complaints involving Avalon operations; and
• To keep you informed of future vacancies and maintain accurate records of your preferences.

You can update your contact preference regarding future contact at any time, but please be aware that we may need to retain wider data for prevailing lawful purposes that apply at that point if you later enquire about the deletion.

Your Rights Over Your Personal Information

Depending where you are located, you may have certain legal rights over personal information we hold about you. These include the right to:

• Obtain access to your personal information that is being processed by us, have inaccurate personal information corrected, and request the deletion of some of your personal information.
• Object to the processing of your personal information carried out on the basis of our legitimate interests.
• Ask us to restrict the processing of your personal information.
• Request the portability of your personal information in a structured, commonly used and machine-readable format if the processing is carried out on the basis of consent or a personal contract.
• Withdraw your consent at any time, if we have collected and processed your personal information for a specific activity with your consent. 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.
• Lodge a complaint with a data protection supervisory authority. As a rule, you can contact the supervisory authority of your usual place of residence, your place of work, or the registered office of the controller. You may also request the details of your competent supervisory authority by using the contact details below in the “How to Contact Us” section.

We may require you to provide information from which we can satisfy ourselves as to your identity.

Avalon will not discriminate against you for exercising your Privacy Rights. We will explain how the rights mentioned above operate in a given situation, including:

• If the right and its availability differ in your location or because of the legal basis for the processing activity or Avalon’s prevailing processing needs.
• How the rights of others interact with a specific request.

Avalon does not make decisions based solely on automated processing that produce legal or similarly significant effects as part of the recruitment processing activities covered by this Privacy Statement.

You, or an authorized individual who we can verify is acting on your behalf, can exercise the applicable rights by contacting us using the contact details at the bottom of this Privacy Statement. If you are able to provide details of your concern, this may assist Avalon expedite the response. In any event, we will respond without undue delay and keep you updated. In Europe, this is usually within one month of your request.

Additional Information for California Residents

For California residents, if you are submitting a request to access, please specify whether you would like to access personal information categories or specific pieces of personal information. In addition to many of the rights described above, California residents have the right to opt out of a business’s sale of your personal information or sharing of your personal information to third parties for targeted advertising. Avalon does not sell your personal information or share your personal information with third parties for targeted advertising. Avalon also does not use your Sensitive Personal Information for any purpose other than to operate our business, for legitimate recruitment-related purposes, or where otherwise permitted by, or necessary to comply with, applicable laws, and therefore does not provide a right to limit the use of Sensitive Personal Information.

When you submit a request, we will first acknowledge receipt of your request within 10 business days after receipt of your request. We will provide a substantive response to your request within 45 calendar days after its receipt. If we require more time (up to 90 days or the permitted time frame), we will inform you of the reason and extension period in writing.

Only you or an authorized agent (as described below) may make a verifiable consumer request related to your personal information.

• How to Authorize an Agent. You may designate an authorized agent to submit your verifiable consumer request on your behalf only if the authorized agent has your written permission to do so and you have taken steps to verify your identity directly with us.
• How We Verify Your Request. To respond to your request, we must verify your identity and/or the authority of your authorized agent. We will only use the personal information provided to us in that context to verify your identity or the authority of your authorized agent to make the request. Making a verifiable consumer request does not require you to create an account with us. To allow us to verify your request, we may require that you provide at least two pieces of personal information that we already have in our possession, if we cannot already verify you. We will verify your consumer request by comparing the information you provide to information already in our possession, and take additional steps to minimize the risk of fraud.

Security

Please note security of information transmitted through the internet can never be guaranteed. You are responsible for maintaining the security of your password or other form of authentication involved in accessing password-protected or secured areas of any Avalon recruitment web page. Access to and use of password-protected and/or secure areas of any ​Avalon recruitment web pages​ is restricted to authorized users only.

U.S. Data Privacy Framework

Avalon adheres to the principles of the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and relies on the EU-U.S. DPF as a legal basis for transfers of personal information.

How to Contact Us

If you have any questions about this Privacy Statement or wish to exercise your rights, please contact us at one of the mailing addresses below:

Avalon Services Group, Inc.
4080 McGinnis Ferry Rd, Ste 1103

Alpharetta, GA 30005
USA