Privacy policy

Adults/worker privacy notice Children privacy notice

Introduction

Espirita is committed to protecting your personal data and respecting your privacy. This Candidate Privacy Notice outlines our practices regarding the collection, use, and disclosure of personal information during the job or internship application process.

What information do we collect?

Espirita collects information that can identify an individual or relates to an identifiable individual (“Personal Information”) to provide services to you, our clients, and candidates and to operate our business. The type of Personal Information we collect depends on the situation. We collect Personal Information by different methods depending on whether the individual is a candidate, client, supplier, vendor, or website user.

The following provides examples of the type of information that we collect in a variety of context and how we use the information.

• Contact Information: Name, address, phone number, email.
• Application Materials: CV, cover letter.
• National Identifiers: Social security number, national ID.
• Experience and Education: Work experience, education details, certifications.
• Position of Interest: Roles and opportunities of interest.
• Skills and Competencies: Skills, languages, competencies.
• Reference Details: Information from references.
• Online Account Information: Username and password for our Careers Site.
• Device Information: IP address, geolocation data.
• Interview and Screening Information: Details from interviews and screenings.
• Demographic Information: Gender, disability status.
• Communication Preferences: Preferred communication method and language.
• Event Information: Travel and accommodation for recruitment events.
• Work Authorisation: Visa and work authorisation status.
• Dependent Information: Data on dependents for visa processing, including children’s information.
  Information Collected from Other Sources:
• Third-Party Sources: Background checks, references, recruitment agencies, and publicly accessible sources.
• Automated Technologies: Cookies and other tracking technologies.

 How do we use of your Information?

 Espirita uses the Personal Information it collects in several ways. We collect, process, or disclose your Personal Information for our legitimate business purposes, including:

• Review Applications:  Evaluate your suitability for roles.
• Process Applications:  Manage application submissions and processing.
• Communicate Updates:  Respond to inquiries and communicate about your application.
• Verify Information:  Conduct background checks and verify details.
• On-boarding:  Manage the hiring process if you are offered a position.
• Diversity and Inclusion:  Monitor equal opportunity in recruitment.
• Compliance:  Adhere to legal requirements.
• Improve Processes:  Enhance our recruitment processes through analytics.
• General Operations:  Conduct internal business activities and protect our legal rights.
• Future Opportunities:  Consider you for future roles with your consent.

Automated Decision-Making ?

We do not use automated decision-making processes that have a significant impact on you. This is subject to change with the utilisation of AI products.

Why might we share your information with Third parties?

 In addition to the specific situations discussed elsewhere in this Privacy Policy, we may disclose personal information in the following situations:

• Affiliates and Acquisitions. We may share your Personal Information with our affiliates in the Acacium Group for the purposes outlined in this Privacy Policy. If another company acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage.
•  Clients. We may share your Personal Information with a specific Client if you have requested that we do so in order to make an application.
• Service Providers. We may share your information with third-party service providers, including some service providers who are based in foreign countries. Among other things, service providers may help us to administer our website, conduct surveys, provide technical support, conduct research and analysis, and otherwise support our business operations. All our third-party service providers and other entities in the Acacium Group are required to take appropriate security measures to protect your personal information. We do not allow our third-party service providers to use your personal information for their own purposes. We only permit them to process your personal information for specified purposes and in accordance with our instructions.
• Other members of the Acacium Group in connection with similar job roles to those you have fulfilled previously;
• Legal Process. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, to comply with relevant laws, or to respond to requests from public and government authorities. We may also share your information in order to enforce our terms and conditions, to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, and to protect our operations or those of any of ours.

Our lawful bases for collecting or using personal information as part of staff recruitment, administration and management are:

Legal obligation

•  Background Checks: Verifying candidates’ credentials and suitability for roles to ensure the hiring of qualified and trustworthy individuals, including checking education, employment history, and criminal records.

Legitimate interest

• Direct Marketing: Promoting our services and job opportunities to potential candidates and clients to attract suitable candidates for available roles. Travel Planning: Arranging travel for candidates and employees for interviews, training, or assignments, including booking flights, accommodation, and other logistics.
• Market Research: Conducting research to understand market trends, improve services, and enhance our competitive positioning by gathering and analyzing data on industry practices and candidate preferences.
• Leads Qualification: Evaluating potential candidates and clients to determine their suitability for our services by assessing skills, experience, and needs.
• Sales Support: Supporting business development and client relationships by identifying opportunities, negotiating contracts, and maintaining ongoing client satisfaction.
• Benefits Administration: Administering employee benefits such as health insurance, and other perks to ensure employee well-being and retention.
• Customer Relationship Management: Maintaining relationships with candidates and clients by managing communications, resolving issues, and ensuring satisfaction with our services.
• Online Recruiting Activities: Facilitating digital recruitment efforts through job postings, online applications, and virtual interviews to streamline the hiring process.
• Customer Service: Providing support and assistance to candidates and clients, addressing inquiries, and resolving issues related to our services or employment.
• Internal Business Operations: Conducting internal business activities such as auditing, reporting, and compliance monitoring to ensure efficient and lawful operations.
• Consent: We may disclose your information to other third parties when we have your consent or direction to do so. 

How will your personal data be used for marketing?

As an agency worker or someone who has shown an interest in working with us, we will occasionally send you information we feel would be of interest to you, to help secure you a new role and show you the benefits of working with us. This will include, in certain circumstances, sharing your details with our group companies so that they can contact you about job opportunities which are similar to those you have previously fulfilled with the Espirita.

The precise basis on which we will share your details for this specific purpose with another Acacium Group will depend on how recently you have fulfilled a role with Espirita.  If this has been within the last two years then we will write to you and ask whether you would like to opt-out of us sharing your details. 

You can also opt out of all marketing communications at any time by following the process set out below.   

We may also send you information about:

• Discounts that could be available to you while working for us
• Competitions, incentives and promotions
• Referral schemes
• Exclusive events and training
• Charities that we support

We appreciate you may not want to receive this information and whilst we’d hate for you to miss out, you can opt-out by:

• Clicking on the unsubscribe link at the bottom of any marketing emails we send you
• Emailing us at dpo@acaciumgroup.com.

Please note that legal and service updates relating to you working with us are not direct marketing and cannot be opted out of. We endeavour to respond to your request to stop marketing as soon as possible but this can take a few days to action. Whilst we work on your request, there is a small chance you may still receive some marketing communication.

International Data Transfers

  How do we safeguard your information?

As a global organisation, your data may be transferred to and processed in countries outside of your own.  We will ensure that adequate protection measures are in place such as contractual safeguards, full security over the transfer of your data, privacy and transfer risk assessments in order to safeguard your personal data for the purposes of a data transfer.

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way.

   How long do we keep your information for?

• We will retain your personal information for as long as required to provide services or complete the transaction also after you no longer wish to be registered with us, or if you have been appointed into a role with a client.

• We retain your personal information so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with our data retention policy or applicable laws and regulations that may apply in a particular jurisdiction. 

Cookies

• You can set your browser to refuse some or all cookies, or to indicate when a cookie is being sent to your computer. However, this may prevent our websites or services from working properly. You can also set your browser to delete cookies every time you finish browsing. For more information about how to manage browser cookies, please follow the instructions provided by your browser.

Communication Opt-Out

• We may periodically send you messages, including newsletters, notifications of your account statuses, and marketing communications. All such material will have information on how to opt out of receiving those messages. However, specific messages (such as a secure message
• Your Rights: Depending on your location, you may have rights under data protection laws, such as:

• Access:  Request access to your personal data.
• –  Correction:  Request correction of your personal data.
• –  Deletion:  Request deletion of your personal data.
• –  Restriction:  Request restriction of processing your personal data.
• –  Transfer:  Request transfer of your personal data.
• –  Objection:  Object to the processing of your personal data.
• – Objection: Object to your data being processed solely on automated processing (unless required by law)
• –  Withdraw Consent:  Withdraw your consent where we rely on it to process your data.
•  To exercise these rights, please email us Privacy.Team@acaciumgroup.com or call us at (866) 877-1514.

Additional Information for California Residents

If you are a California resident, the following privacy disclosures apply to you in addition to the rest of the Privacy Policy. For purposes of this section, “Personal Information” means information that identifies, relates to, describes, and is reasonably capable of being associated with, or could be linked, directly or indirectly, with a particular individual or household.

Categories of Information We Collect, Use, and Disclose

The chart below describes the categories of Personal Information we collect, disclose for a business purpose, and “share” for purposes of cross-context behavioral advertising (as those terms are defined by California law). Please note, in addition to the recipients identified below, we may disclose any of the categories of Personal Information we collect with government entities, as may be needed to comply with law or prevent illegal activity. We do not “sell” your Personal Information for money. As discussed elsewhere in the Privacy Policy, we use cookies and similar tracking technologies for purposes of targeted advertising.

Category

Category of Personal Information	Category of Recipients	Category of Recipients
Identifiers – this may include real name, alias, postal address, unique personal identifier, online identifier, email address, account name, or other similar identifiers.	Affiliates or subsidiaries Internet service providers Operating systems and platforms Other Service Providers Professional services organizations, this may include auditors and law firms	Advertising networks
Government Issued Identification – this may include social security number, driver’s license number, or state issued identification number, passport number.	Affiliates or subsidiaries Service Providers Professional services organizations, this may include auditors and law firms
Financial Information – this may include bank account number, credit card number, debit card number, and other financial information.	Affiliates or subsidiaries Service Providers Professional services organizations, this may include auditors and law firms
Health Related Information – this may include medical information, mental or physical condition or treatment, or health insurance information.	Affiliates or subsidiaries Service Providers Professional services organizations, this may include auditors and law firms
Characteristics of protected classifications – this may include age, sex, race, ethnicity, physical, or mental handicap, etc.	Affiliates or subsidiaries Service Providers Professional services organizations, this may include auditors and law firms
Commercial information – this may include information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Affiliates or subsidiaries Service Providers Professional services organizations, this may include auditors and law firms
Internet or other electronic network activity information – this may include browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.	Service Providers	Advertising networks
Geolocation data	Service Providers
Audio, electronic, visual, thermal, olfactory, or similar information	Service Providers
Professional or employment-related information	Affiliates or subsidiaries Service Providers Professional services organizations, this may include auditors and law firms
Inferences drawn from any of the information listed above	Affiliates or subsidiaries Service Providers Professional services organizations, this may include auditors and law firms	Advertising networks
Additional categories of personal information described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) – this may include signature, physical characteristics, or description, insurance policy number.	Affiliates or subsidiaries Service Providers Professional services organizations, this may include auditors and law firms
Agency Workers	Sharing your contact details (name, telephone number and email address) with other Acacium Group entities	To enable other Acacium Group entities to contact you in relation to similar job opportunities, as further described in section 8 of this privacy notice below

California Sensitive Information Disclosure

We may collect the following categories of sensitive Personal Information (as defined under California law): social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; health-related information; information concerning sex life or sexual orientation. his information is collected in order to assess your eligibility for employment, provide certain benefits, comply with applicable laws and regulations, for diversity and inclusion programs, manage our business, or provide you with services and for security purposes. Note that we do not use such information for any purposes that are not identified within the California Privacy Rights Act Section 1798.121. We do not “sell” or “share” sensitive Personal Information for purposes of cross-context behavioural advertising. 

Adults/worker privacy notice

Introduction

Espirita is committed to protecting your personal data and respecting your privacy. This Candidate Privacy Notice outlines our practices regarding the collection, use, and disclosure of personal information during the job or internship application process.

What information do we collect?

Espirita collects information that can identify an individual or relates to an identifiable individual (“Personal Information”) to provide services to you, our clients, and candidates and to operate our business. The type of Personal Information we collect depends on the situation. We collect Personal Information by different methods depending on whether the individual is a candidate, client, supplier, vendor, or website user.

The following provides examples of the type of information that we collect in a variety of context and how we use the information.

 –  Contact Information:  Name, address, phone number, email.

–  Application Materials:  CV, cover letter.

–  National Identifiers:  Social security number, national ID.

–  Experience and Education:  Work experience, education details, certifications.

–  Position of Interest:  Roles and opportunities of interest.

–  Skills and Competencies:  Skills, languages, competencies.

–  Reference Details:  Information from references.

–  Online Account Information:  Username and password for our Careers Site.

–  Device Information:  IP address, geolocation data.

–  Interview and Screening Information:  Details from interviews and screenings.

–  Demographic Information:  Gender, disability status.

–  Communication Preferences:  Preferred communication method and language.

–  Event Information:  Travel and accommodation for recruitment events.

–  Work Authorisation:  Visa and work authorisation status.

–  Dependent Information:  Data on dependents for visa processing, including children’s information.

  Information Collected from Other Sources:

–  Third-Party Sources:  Background checks, references, recruitment agencies, and publicly accessible sources.

–  Automated Technologies:  Cookies and other tracking technologies.

 How do we use of your Information?

 Espirita uses the Personal Information it collects in several ways. We

collect, process, or disclose your Personal Information for our legitimate business purposes, including:

–  Review Applications:  Evaluate your suitability for roles.

–  Process Applications:  Manage application submissions and processing.

–  Communicate Updates:  Respond to inquiries and communicate about your application.

–  Verify Information:  Conduct background checks and verify details.

–  On-boarding:  Manage the hiring process if you are offered a position.

–  Diversity and Inclusion:  Monitor equal opportunity in recruitment.

–  Compliance:  Adhere to legal requirements.

–  Improve Processes:  Enhance our recruitment processes through analytics.

–  General Operations:  Conduct internal business activities and protect our legal rights.

–  Future Opportunities:  Consider you for future roles with your consent.

  Automated Decision-Making

 We do not use automated decision-making processes that have a significant impact on you. This is subject to change with the utilisation of AI products.

 Why might we share your Information with Third parties?

 In addition to the specific situations discussed elsewhere in this Privacy Policy, we may disclose personal information in the following situations:

• Affiliates and Acquisitions. We may share your Personal Information with our affiliates in the Acacium Group for the purposes outlined in this Privacy Policy. If another company acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage.

•  Clients. We may share your Personal Information with a specific Client if you have requested that we do so in order to make an application.

• Service Providers. We may share your information with third-party service providers, including some service providers who are based in foreign countries. Among other things, service providers may help us to administer our website, conduct surveys, provide technical support, conduct research and analysis, and otherwise support our business operations. All our third-party service providers and other entities in the Acacium Group are required to take appropriate security measures to protect your personal information. We do not allow our third-party service providers to use your personal information for their own purposes. We only permit them to process your personal information for specified purposes and in accordance with our instructions.
• Other members of the Acacium Group in connection with similar job roles to those you have fulfilled previously;

• Legal Process. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, to comply with relevant laws, or to respond to requests from public and government authorities. We may also share your information in order to enforce our terms and conditions, to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, and to protect our operations or those of any of ours.

Our lawful bases for collecting or using personal information as part of staff recruitment, administration and management are:

• Legal obligation

•  Background Checks: Verifying candidates’ credentials and suitability for roles to ensure the hiring of qualified and trustworthy individuals, including checking education, employment history, and criminal records.

• Legitimate interest:

• Direct Marketing: Promoting our services and job opportunities to potential candidates and clients to attract suitable candidates for available roles. Travel Planning: Arranging travel for candidates and employees for interviews, training, or assignments, including booking flights, accommodation, and other logistics.

• Market Research: Conducting research to understand market trends, improve services, and enhance our competitive positioning by gathering and analyzing data on industry practices and candidate preferences.

• Leads Qualification: Evaluating potential candidates and clients to determine their suitability for our services by assessing skills, experience, and needs.

• Sales Support: Supporting business development and client relationships by

identifying opportunities, negotiating contracts, and maintaining ongoing client satisfaction.

• Benefits Administration: Administering employee benefits such as health insurance, and other perks to ensure employee well-being and retention.

• Customer Relationship Management: Maintaining relationships with candidates and clients by managing communications, resolving issues, and ensuring satisfaction with our services.

• Online Recruiting Activities: Facilitating digital recruitment efforts through job postings, online applications, and virtual interviews to streamline the hiring process.

• Customer Service: Providing support and assistance to candidates and clients, addressing inquiries, and resolving issues related to our services or employment.

• Internal Business Operations: Conducting internal business activities such as auditing, reporting, and compliance monitoring to ensure efficient and lawful operations.

• Consent: We may disclose your information to other third parties when we have your consent or direction to do so.

How will your personal data be used for marketing?

As an agency worker or someone who has shown an interest in working with us, we will occasionally send you information we feel would be of interest to you, to help secure you a new role and show you the benefits of working with us. This will include, in certain circumstances, sharing your details with our group companies so that they can contact you about job opportunities which are similar to those you have previously fulfilled with the Espirita.

The precise basis on which we will share your details for this specific purpose with another Acacium Group will depend on how recently you have fulfilled a role with Espirita.  If this has been within the last two years then we will write to you and ask whether you would like to opt-out of us sharing your details. 

You can also opt out of all marketing communications at any time by following the process set out below.   

We may also send you information about:

• Discounts that could be available to you while working for us
• Competitions, incentives and promotions
• Referral schemes
• Exclusive events and training
• Charities that we support

We appreciate you may not want to receive this information and whilst we’d hate for you to miss out, you can opt-out by:

• Clicking on the unsubscribe link at the bottom of any marketing emails we send you
• Emailing us at dpo@acaciumgroup.com.

Please note that legal and service updates relating to you working with us are not direct marketing and cannot be opted out of. We endeavour to respond to your request to stop marketing as soon as possible but this can take a few days to action. Whilst we work on your request, there is a small chance you may still receive some marketing communication.

  International Data Transfers

As a global organisation, your data may be transferred to and processed in countries outside of your own.  We will ensure that adequate protection measures are in place such as contractual safeguards, full security over the transfer of your data, privacy and transfer risk assessments in order to safeguard your personal data for the purposes of a data transfer.

  How do we safeguard your information?

•  We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way.

 How long do we keep your information for?

• We will retain your personal information for as long as required to provide services or complete the transaction also after you no longer wish to be registered with us, or if you have been appointed into a role with a client.

• We retain your personal information so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with our data retention policy or applicable laws and regulations that may apply in a particular jurisdiction. 

Cookies

• You can set your browser to refuse some or all cookies, or to indicate when a cookie is being sent to your computer. However, this may prevent our websites or services from working properly. You can also set your browser to delete cookies every time you finish browsing. For more information about how to manage browser cookies, please follow the instructions provided by your browser.

Communications Opt-Out

• We may periodically send you messages, including newsletters, notifications of your account statuses, and marketing communications. All such material will have information on how to opt out of receiving those messages. However, specific messages (such as a secure message

Your Rights: Depending on your location, you may have rights under data protection laws, such as:

–  Access:  Request access to your personal data.

–  Correction:  Request correction of your personal data.

–  Deletion:  Request deletion of your personal data.

–  Restriction:  Request restriction of processing your personal data.

–  Transfer:  Request transfer of your personal data.

–  Objection:  Object to the processing of your personal data.

– Objection: Object to your data being processed solely on automated processing (unless required by law)

–  Withdraw Consent:  Withdraw your consent where we rely on it to process your data.

 To exercise these rights, please email us Privacy.Team@acaciumgroup.com or call us at (866) 877-1514.

 Additional Information for California Residents

• If you are a California resident, the following privacy disclosures apply to you in addition to the rest of the Privacy Policy. For purposes of this section, “Personal Information” means information that identifies, relates to, describes, and is reasonably capable of being associated with, or could be linked, directly or indirectly, with a particular individual or household.

Categories of Information We Collect, Use, and Disclose

• The chart below describes the categories of Personal Information we collect, disclose for a business purpose, and “share” for purposes of cross-context behavioral advertising (as those terms are defined by California law). Please note, in addition to the recipients identified below, we may disclose any of the categories of Personal Information we collect with government entities, as may be needed to comply with law or prevent illegal activity. We do not “sell” your Personal Information for money. As discussed elsewhere in the Privacy Policy, we use cookies and similar tracking technologies for purposes of targeted advertising.

Category of Personal Information	Category of Recipients	Category of Recipients
Identifiers – this may include real name, alias, postal address, unique personal identifier, online identifier, email address, account name, or other similar identifiers.	Affiliates or subsidiaries Internet service providers Operating systems and platforms Other Service Providers Professional services organizations, this may include auditors and law firms	Advertising networks
Government Issued Identification – this may include social security number, driver’s license number, or state issued identification number, passport number.	Affiliates or subsidiaries Service Providers Professional services organizations, this may include auditors and law firms
Financial Information – this may include bank account number, credit card number, debit card number, and other financial information.	Affiliates or subsidiaries Service Providers Professional services organizations, this may include auditors and law firms
Health Related Information – this may include medical information, mental or physical condition or treatment, or health insurance information.	Affiliates or subsidiaries Service Providers Professional services organizations, this may include auditors and law firms
Characteristics of protected classifications – this may include age, sex, race, ethnicity, physical, or mental handicap, etc.	Affiliates or subsidiaries Service Providers Professional services organizations, this may include auditors and law firms
Commercial information – this may include information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Affiliates or subsidiaries Service Providers Professional services organizations, this may include auditors and law firms
Internet or other electronic network activity information – this may include browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.	Service Providers	Advertising networks
Geolocation data	Service Providers
Audio, electronic, visual, thermal, olfactory, or similar information	Service Providers
Professional or employment-related information	Affiliates or subsidiaries Service Providers Professional services organizations, this may include auditors and law firms
Inferences drawn from any of the information listed above	Affiliates or subsidiaries Service Providers Professional services organizations, this may include auditors and law firms	Advertising networks
Additional categories of personal information described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) – this may include signature, physical characteristics, or description, insurance policy number.	Affiliates or subsidiaries Service Providers Professional services organizations, this may include auditors and law firms
Agency Workers	Sharing your contact details (name, telephone number and email address) with other Acacium Group entities	To enable other Acacium Group entities to contact you in relation to similar job opportunities, as further described in section 8 of this privacy notice below

California Sensitive Information Disclosure

We may collect the following categories of sensitive Personal Information (as defined under California law): social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; health-related information; information concerning sex life or sexual orientation. his information is collected in order to assess your eligibility for employment, provide certain benefits, comply with applicable laws and regulations, for diversity and inclusion programs, manage our business, or provide you with services and for security purposes. Note that we do not use such information for any purposes that are not identified within the California Privacy Rights Act Section 1798.121. We do not “sell” or “share” sensitive Personal Information for purposes of cross-context behavioural advertising.