Last updated: 5 November 2020
1. Introduction
This Privacy Notice describes how and why Peloton Interactive UK Limited and Peloton Interactive Deutschland GmbH ("Peloton", "we" or "us") processes your personal information when you apply for a job or other role with us and the rights you have in connection with that information. When we refer in this Notice to "you" or "applicant(s)" we mean anyone who applies for a job role, or who otherwise seeks to carry out work with or for us (whether on a permanent or non-permanent basis).
If you are in any doubt, or have any comments or questions about this Notice, please contact us using the contact details set out at Section 9 below.
2. Types of personal information we collect when you apply for a role with us
(i) Information that we collect automatically
You can visit the careers/recruitment section of our site https://www.onepeloton.co.uk/careers ("Site") and search for jobs without providing personal information. However, we do collect certain information automatically from your device when you visit our Site. For further information, please see the Peloton Privacy Policy that applies to our Site.
(ii) Personal Information collected from you
The types of personal information we collect from you when you apply for a role with Peloton includes:
- Identification data and contact details – including your name, address, email address, phone number and other contact information, gender, date of birth, nationality/ies, national identifiers (such as national ID/passport, social security number(s)).
- Employment history – such as previous employers and job titles/positions.
- Background information – such as academic/professional qualifications, job qualifications, education, details included in your CV/résumé (which might include details of any memberships or interests constituting sensitive personal information), transcripts and employment references.
- Nominated referees - including their name, contact details, employer and job role.
- Immigration/visa status.
- Previous applications/roles – including information relating to previous applications you have made to Peloton and/or any previous employment history with Peloton.
- Other information you voluntarily provide throughout the process - including through assessment centres / exercises and interviews.
As a general rule, during the recruitment process, we try not to collect or process any of the following: information that reveals your racial or ethnic origin, religious, political or philosophical beliefs or trade union membership; genetic data; biometric data for the purposes of unique identification; or information concerning your health/sex life ("Sensitive Personal Information"), unless authorised by law or where necessary to comply with applicable laws.
However, in some circumstances, we may need to collect, or request on a voluntary disclosure basis, some Sensitive Personal Information for legitimate recruitment-related purposes: for example, information about your racial/ethnic origin, gender and disabilities for the purposes of equal opportunities monitoring, to comply with anti-discrimination laws and for government reporting obligations; or information about your physical or mental condition to consider accommodations for the recruitment process and/or subsequent job role. For example, for jobs which require manual lifting we may also need to carry out a physical health assessment for your own safety and well-being to ensure that such a role would be suitable. You may provide, on a voluntary basis, other Sensitive Personal Information during the recruitment process.
(iii) Personal information collected from other sources
The types of personal information we may collect from other sources when you apply for a role with Peloton includes (in each case, where permissible and in accordance with applicable law):
- References provided by referees.
- Other background information provided or confirmed by academic institutions and training or certification providers.
- Information provided by background checking agencies (including, for certain Peloton roles, criminal records checks), at the point of offer, but only where permitted in accordance with applicable law.
- Information provided by recruitment or executive search agencies.
- Information collected from publically available sources, including any social media platforms you use or other information available online.
3. Purposes for processing personal information
We collect and use this personal information primarily for recruitment purposes – in particular, to determine your qualifications for employment and to reach a hiring decision. This includes assessing your skills, qualifications and background for a particular role, verifying your information, carrying our reference checks or background checks (where applicable) and to generally manage the hiring process and communicate with you about it.
If you are accepted for a role at Peloton, the information collected during the recruitment process will form part of your ongoing staff member record and will be processed in accordance with our Staff Privacy Notice which will be made available to you during the onboarding process.
If you are unsuccessful, we may still keep your application for no more than a maximum of 12 months after the notification of refusal or longer with your prior consent to allow us to consider you for other suitable openings within Peloton in the future unless you request that we delete your application.
4. Who we share your personal information with
We take care to allow access to personal information only to those who require such access to perform their tasks and duties, and to third parties who have a legitimate purpose for accessing it. Whenever we permit a third party to access personal information, we will implement appropriate measures to ensure the information is used in a manner consistent with this Notice and that the security and confidentiality of the information is maintained.
(i) Transfers to other group companies
We may share your personal information with other members of the Peloton group around the world in order to assist with and administer our recruitment processes, help reach hiring decisions and store data.
(ii) Transfers to third party service providers
We may make certain personal information available to third parties who provide services relating to the recruitment process to us, including:
- Recruitment or executive search agencies involved in your recruitment;
- Background checking or other screening providers and relevant local criminal records checking agencies;
- Data storage, shared services and recruitment platform providers, IT developers and support providers and providers of hosting services in relation to our careers website;
- Third parties who provide support and advice including in relation to legal, financial / audit, management consultancy, insurance, health and safety, security and intel and whistleblowing / reporting issues.
(iii) Transfers to other third parties
We may also disclose personal information to third parties on other lawful grounds, including:
- To comply with our legal obligations, including where necessary to abide by law, regulation or contract, or to respond to a court order, administrative or judicial process, including, but not limited to, a subpoena, government audit or search warrant;
- In response to lawful requests by public authorities (including for tax, immigration, health and safety, national security or law enforcement purposes);
- As necessary to establish, exercise or defend against potential, threatened or actual legal claims;
- Where necessary to protect your vital interests or those of another person;
- In connection with the sale, assignment or other transfer of all or part of our business; and/or
- Where you have provided your consent;
5. Legal basis for processing personal information
Our legal basis for processing your personal information as part of the recruitment process will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you:
- where is it is in our legitimate interests (which are not overridden by your data protection interests or fundamental rights and freedoms);
- to comply with applicable immigration and/or employment laws and regulations;
- for employment-related purposes where necessary for hiring decisions;
- to take steps prior to entering an employment contract with you, where you are considered for employment;
- in circumstances where you have made the data public;
- where we have your consent to do so; and/or
- to protect the rights and interests of the Peloton group, our employees, applicants and others, as required and permitted by applicable law.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided in Section 9 below.
6. Transfer of personal information abroad
As we operate at a global level, we may need to transfer personal information to countries other than the ones in which the information was originally collected. When we export your personal information to a different country, we will take steps to ensure that such data exports comply with applicable laws. For example, if we transfer personal information from the European Economic Area or the UK to a third country which is not deemed adequate by EU or UK law (as appropriate), such as to group companies in the United States, we will implement an appropriate data export solution such as entering into EU Standard Contractual Clauses with the data importer, or taking other measures to provide an adequate level of data protection under EU law.
We have taken appropriate safeguards to require that your personal information will remain protected through entry into the EU Standard Contractual Clauses. Our Standard Contractual Clauses can be provided on request.
7. Data retention periods
Personal information will be stored in accordance with applicable laws and kept as long as needed to carry out the purposes described in this Notice or as otherwise required by applicable law. Generally this means your personal information will be retained:
- if you are successful in our application with us, in accordance with the retention periods specified in our Staff Privacy Notice; or
- for a maximum of 12 months after confirmation that your application was unsuccessful.
8. Your data privacy rights
You may exercise the rights available to you under applicable data protection laws as follows:
- If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided below.
- You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided below.
- If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. 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.
- You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
9. Contact details
You can contact our DPO or address any questions or requests relating to this Notice at privacy@onepeloton.com.
The Data Controller of your information will be the entity to whom you are submitting your application:
- Germany: Peloton Interactive Deutschland GmbH
- UK: Peloton Interactive UK Limited