Candidate Privacy Notice

Scope and Overview

The Bumble Group is committed to protecting the privacy and security of your personal data. This Privacy Notice describes how Bumble Holding Limited, Badoo Trading Limited and their subsidiaries, affiliates, and related entities (collectively, Bumble Group, we, or us) collect and process personal data about you during the application and recruitment process. This Privacy Notice applies to job applicants only.

This Privacy Notice describes the categories of personal data that we collect, how we use your personal data, how we secure your personal data, when we may disclose your personal data to third parties, and when we may transfer your personal data outside of your home jurisdiction. This Privacy Notice also describes your rights regarding the personal data that we hold about you including how you can access, correct, and request erasure of your personal data.

We will only process your personal data in accordance with this Privacy Notice unless otherwise required by applicable law. We take steps to ensure that the personal data that we collect about you is adequate, relevant, not excessive, and processed for limited purposes.

Collection of Personal Data

For the purposes of this Privacy Notice, personal data means any information about an identifiable individual collected in connection with the recruitment process. The Bumble Group may collect personal data directly from you, as a job applicant, or may receive personal data from third parties, for example, in connection with a background, employment, or reference check, subject to your consent where required by law.

Personal data excludes anonymous or de-identified data that is not associated with a particular individual. We may collect, store, and process the following categories of personal data in connection with our recruiting activities:

  • Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses (Contact Data).
  • Right to work information including nationality and visa status where applicable (Right to Work Data).
  • Work history and other relevant experience including information contained in a resume, CV, cover letter, or job application (Experience Data).
  • Education information including degrees awarded, transcripts, and other information provided in support of the job application (Education Data).
  • Information collected during phone screenings and interviews (Interview Data).
  • Information relating to your health where this is relevant to the position sought (Health Data).
  • Details regarding the type of employment sought, desired salary, willingness to relocate, job preferences, and other information related to compensation and benefits (Role Data).
  • Reference information and information received from background checks, where applicable, including information provided by third parties (Screening Data).
  • Information related to previous applications to the Bumble Group or previous employment history with the Bumble Group (Bumble Employment Data).

All of the personal data listed in this notice/identified above is mandatory in connection with our recruiting activities. If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.

Use of Personal Data

We only process your personal data where applicable law permits or requires it in connection with carrying out our application and recruitment process, to take steps necessary to enter into an employment contract with you, where the processing is necessary to comply with a legal obligation that applies to us, for our legitimate interests or the legitimate interests of third parties, or with your consent if applicable law requires consent.

The table below provides an overview of the legal bases that we rely on to process your personal data.

Purpose for which data is usedDataLegal basis
To determine whether you are suitable for the roleExperience Data, Education Data, Interview Data, Role Data, Screening Data and Badoo Employment DataLegitimate interests -“ it is in our legitimate interests to assess this information to ensure that you have the right qualifications and abilities to fulfil the relevant role
To communicate with you in relation to the recruitment process and your applicationContact DataLegitimate interests -“ it is in our legitimate interests to communicate with you to set up interviews and provide feedback during the recruitment process
To determine whether you are suitable for any other roles either at present or in the futureExperience Data, Education Data, Interview Data, Role Data, Screening Data and Badoo Employment DataConsent
To comply with our statutory obligations, including carrying out right to work checks and to enable us to determine appropriate workplace adjustments and fitness for a roleRight to Work Data, Health DataLegal obligation
Verifying the information that you have provided and carrying out employment, background and reference checksExperience Data, Education Data, Contact Data, Right to Work Data and Screening DataLegitimate interests -“ it is in our legitimate interests to check that the information that you have provided is accurate to help us prevent and detect fraud and to ensure that you are fit for the relevant roleFor some checks your consent may be required, in which case we will seek consent at the time when we require the check to be carried out
Keeping records in relation to our hiring processesTest scores, tasks and videos submittedLegitimate interests -“ it is in our legitimate interests to keep these records to defend legal claims and to help us to improve our recruitment processes in the future
To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distributionInformation about access to our systems, your location and device used to access our systems, login informationLegitimate interests -“ it is in our legitimate interests to keep our systems secure to prevent unauthorised access to or alteration of data

In addition to using your personal data for the position for which you have applied, with you consent, we may retain and use your personal data to inform you about and consider you for other positions that may be appropriate for you. You can choose whether you would like us to keep your data for this purpose when you submit an application through the Jobs section of our website and you can change your preferences at any time via the website.

We will only process your personal data for the purposes we collected it for or for compatible purposes. If we need to process your personal data for an incompatible purpose, we will provide notice to you and, if required by law, seek your consent. We may process your personal data without your knowledge or consent only where required by applicable law or regulation.

You will not be subject to hiring decisions based solely on automated data processing without your prior consent.

Collection and Use of Special Categories of Personal Data

The following special categories of personal data are considered sensitive under the laws of your jurisdiction and receive special protection:

  • Racial or ethnic origin.
  • Political opinions.
  • Religious or philosophical beliefs.
  • Trade union membership.
  • Genetic data.
  • Biometric data.
  • Data concerning health.
  • Data concerning sex life or sexual orientation.

We may collect and process these special categories of personal data when you voluntarily provide them or we receive them from a third party with your consent, when relevant for a particular position to carry out our obligations under employment law, or as applicable law otherwise permits. In particular:

  • we will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview.
  • we use information about your physical or mental health condition or disability status to determine appropriate workplace accommodations and evaluate fitness for a particular position.
  • we may use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting. If we do this we will explain at the point of data collection how this data will be used and the legal basis upon which we are using it.

Where we have a legitimate need to process special categories of personal data about you for purposes not identified above, we will only do so after providing you with notice and, if required by law, obtaining your prior, express consent.

Information about criminal convictions

For some roles, we will collect information about your criminal convictions history if we would like to offer you the role. We only do this where we are entitled to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. In particular, certain roles in our finance, legal and engineering teams require a high degree of trust and integrity since it involves dealing with payment card details or access to highly sensitive and confidential material and so for these roles we carry out searches to obtain basic disclosure of your criminal records history.

We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.

Data Sharing

We will only disclose your personal data to third parties where required by law or to our employees, contractors, designated agents, or third-party service providers who require such information to assist us with administering the recruitment process, including third-party service providers who provide services to us or on our behalf. We may use third-party service providers for various purposes, including, but not limited to, obtaining employment verification and background checks, and data storage or hosting. These third-party service providers may be located outside of the country in which you live or the country where the position you have applied for is located.

We require all our third-party service providers, by written contract, to implement appropriate security measures to protect your personal data consistent with our policies and any data security obligations applicable to us. We do not permit our third-party service providers to process your personal data for their own purposes. We only permit them to process your personal data for specified purposes in accordance with our instructions.

We may also disclose your personal data for the following additional purposes where permitted or required by applicable law:

  • to other members of our group of companies (including outside of your home jurisdiction) for the purposes set out in this Privacy Notice and as necessary to administer the application and recruitment process;
  • as part of our regular reporting activities to other members of our group of companies;
  • to comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders. When we disclose your personal data to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum personal data necessary for the specific purpose and circumstances;
  • to protect the rights and property of the Bumble Group;
  • during emergency situations or where necessary to protect the safety of persons;
  • if a business transfer or change in ownership occurs and the disclosure is necessary to complete the transaction. In these circumstances, we will limit data sharing to what is absolutely necessary and we will anonymise the data where possible;
  • for additional purposes with your consent where such consent is required by law.

Cross-Border Data Transfers

We use a third party recruitment platform, which is provided by Lever Inc. Lever is based in the US and the information that you provide to us via the Lever platform will be stored in the US. Lever is certified under the Privacy Shield. You can find out more about the Privacy Shield here:https://www.privacyshield.gov/welcome.

Depending on the position that you apply for, your personal data may also be shared with the Bumble Group HR and recruitment teams in the US. We have put in place model controller to controller contract clauses approved by the European Commission to safeguard this data. You can find out more about the model contract clauses here:https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

Data Security

We have implemented appropriate physical, technical, and organisational security measures designed to secure your personal data against accidental loss and unauthorised access, use, alteration, or disclosure. In addition, we limit access to personal data to those employees, agents, contractors, and other third parties that have a legitimate business need for such access.

Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, as required to satisfy any legal, accounting, or reporting requirements, or as necessary to resolve disputes. To determine the appropriate retention period for personal data, we consider our statutory obligations, the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes we process your personal data for, and whether we can achieve those purposes through other means.

For all applicants we need to retain some information in case you apply to us again in the future, including your name, email address, phone number, CV, test results and interview feedback. We also need this information if you have asked us to get in touch with you about future opportunities.

If you do not want us to keep in touch with you about future opportunities, we will still retain your information so that we can check this in case of future applications.

For applicants who are unsuccessful or who decide not to take up a job role at the Bumble Group, we keep recruitment data for a period of three years.

If you are offered and accept employment with the Bumble Group, the personal data we collected during the application and recruitment process will become part of your employment record, and we may use it in connection with your employment consistent with our employee personal data policies.

Under some circumstances we may anonymise your personal data so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

Your rights in relation to your personal data

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during the recruitment process.

Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact talentdata@team.bumble.com.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal data that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal data that we hold about you, or we may have destroyed, erased, or made your personal data anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal data, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

Pursuant to Article 27 of the General Data Protection Regulation (GDPR), the Bumble Group has appointed Borlux Ltd as its GDPR representative in the EU. You can contact Borlux Ltd regarding matters pertaining to the GDPR via the online request form at https://services.nathantrust.com/privacycontact or by post to 1st Floor, 6 Lapps Quay, Cork, Ireland

Right to Withdraw Consent

Where you have provided your consent to the collection, processing, and transfer of your personal data, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at talentdata@team.bumble.com.

Data Protection Officer

We have appointed a data protection officer. If you have any questions about this Privacy Notice or how we handle your personal data, please contact the data protection officer at: dpo@team.bumble.com. If you are unsatisfied with our response to any issues that you raise with the data protection officer, you may have the right to make a complaint with the data protection authority in your jurisdiction by contacting the data protection authority.

Changes to This Privacy Notice

We reserve the right to update this Privacy Notice at any time, and we will provide you with a new Privacy Notice when we make any updates. If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose. We may process your personal data without your knowledge or consent only where required by applicable law or regulation.

Effective Date: 24 October 2018