Privacy Policy

This Privacy Policy for Recruitment Activities (hereinafter referred to as this “Policy”) sets out how Rakuten Group Companies using Rakuten’s standard recruitment platforms (“Rakuten”, “we”, or “us”) handle personal information of candidates for employment, including prospective job applicants, (each a “Candidate” or “you”) that is collected in the course of recruitment activities. “Personal Information” is any information about you or your household, as well as a combination of pieces of information that could reasonably allow you or your household to be identified.

The “Rakuten Group” is a global group of companies, with its parent company Rakuten Group Inc., a company headquartered at Rakuten Crimson House, 1-14-1 Tamagawa, Setagaya-ku, Tokyo, 158-0094 Japan. For more information about Rakuten Group, please visit: https://global.rakuten.com/corp/about/. Currently using this recruitment platform and in scope of this Policy are the Rakuten Group companies listed, with their contact information for inquiries, in the end of this Policy. More information about the particular group company advertising an open position on the recruiting platforms can be found in the ‘About Us’ section of the advertised position.

When you apply for a position in Rakuten or you join our database or mailing list for prospective job applicants interested in future Rakuten job postings (our “Talent Community”), you acknowledge that your Personal Information will be used and shared as described in this Policy. Please read this Policy carefully before submitting your application or joining our Talent Community.

1. Data Controller & Candidate Pool

The Rakuten Group company for whose open position you apply or from which you sign up to receive information on prospective job postings will be the controller of your Personal Information for processing. Rakuten jointly shares its recruitment platforms among the participating Rakuten Group companies for the purpose of Candidate pooling. This means you may apply to any advertised position to any of the above-mentioned companies using the same profile in our recruitment platforms. At the same time, we may contact you with an offer or prospective job opportunity from another Rakuten Group company in the event that your application for the original position is rejected, but we consider you to be potentially suitable for another open position. In such case, authorized individuals within the Rakuten Group companies may access and use the Personal Information submitted by Candidates applying for positions within other individual Rakuten Group companies for the purposes described in this Policy and such companies will also be data controllers of your Personal Information.

2. Types of Personal Information Collected

During the course of the recruitment process, we may collect different kinds of Personal Information about you. We may receive Personal Information either directly from you via your submission or from someone acting on your behalf, such as a recruitment agency, or by collecting it from publicly available sources that are job-related, such as business networking websites or job boards, where permitted by applicable laws. Furthermore, where permitted by applicable laws, we may collect information from additional sources, such as our service providers, for example during background checks. Unless not permitted by local laws, the Personal Information we collect relates to the following categories:

• • Information to create a 'Candidate Profile' in our recruitment platforms, such as username, password and e-mail address;
• • Basic profile information, such as name, age, gender, date of birth, telephone number, address, or other contact information;
• • Information necessary to evaluate your suitability for a position, such as educational records, work history, relevant skills, qualifications, or certifications, and, for any skills evaluation or screening test, the responses you provide and the results;
• • Information relevant to the position for which you apply or are considered, such as current annual salary, desired annual salary, employment interest area, type and level of position or job in which you are interested;
• • Information contained in any CV, resume, application, entry sheet, and any other documents you submit to us in order to support your candidacy, including any information you volunteer regarding your non-employment-related interests or activities;
• • Information relevant to the screening process that we may collect through background checks, reference checks, drug screening, and/or other confirmation procedures;
• • Contents of any form of communication conducted between us and you as the Candidate, including face-to-face conversations, telecommunications, emails, letters, phone inquiries and other forms of interviews;
• • Information about the Candidate’s usage of the recruiting platforms, such as login information, login date and time, pages navigated, browsing history; and
• • Past records and results of any prior application, interviews, and screening processes for a Candidate.

Where permitted by applicable law and/or where you have provided any consent required by applicable law, the Personal Information we collect may include information that falls into one or more of the following categories (referred to herein as 'Sensitive Personal Information'):

• • race or ethnic origin;
• • political opinion or membership in a political association;
• • religious beliefs, affiliations, or philosophical beliefs;
• • membership in a professional or trade association or membership in a trade union;
• • genetic or biometric data;
• • sexual preferences or practices;
• • criminal records; and/or
• • health, age and disability.

Where we are permitted to collect Sensitive Personal Information under local law or to the extent that a Candidate voluntarily provides information that includes Sensitive Personal Information, we will only use that information in accordance with applicable law and in line with this Policy. For example, in some countries we may be permitted or even required to conduct equal opportunities monitoring and request information from candidates regarding gender and ethnicity. As another example, if a Candidate requests accommodation related to any special needs or health conditions, we may be permitted or even required to collect and use such information to respond to such requests. In such cases the provision of the information will be optional, and we will only use the information for the specified purposes.

We do not knowingly collect information from minors under 16 years of age.

3. Purpose of Use

We will use the Personal Information for the following purposes, where such uses are permitted under applicable laws:

• • To assess Candidates' qualifications with regard to available positions;
• • To provide Candidates with information about employment opportunities;
• • To contact and correspond with Candidates regarding job applications or employment opportunities;
• • To check information held in relation to Candidates who have made previous applications;
• • To improve or simplify your experience in using our recruiting platforms;
• • If you were referred, to inform the referrer of the status and outcome of your application;
• • To contact you about a similar position in the future, in the event your initial application is rejected, according to local law or depending on your settings;
• • To conduct background checks on suitable Candidates;
• • In order to diagnose or remedy technical or operational problems with our recruiting platforms, websites, portals, or other recruiting activities;
• • To maintain and improve our recruiting processes and for internal planning and reporting purposes
• • To comply with applicable laws and regulations or exercise or defend our legal rights;
• • For security and fraud prevention purposes.

Candidates offered employment will be provided with a separate privacy policy addressing the way in which their Personal Information will be processed by Rakuten during the term of their employment.

4. Legal Basis

Where we collect, handle or process your Personal Information as part of our recruiting process, we may rely on certain legal bases to do so, depending on the region of the Candidate, the position you apply for, and the respective applicable law. These legal bases for processing your Personal Information may include, without limitation:

• • A Candidate’s consent;
• • As necessary to perform or fulfill a contractual obligation with a Candidate;
• • To comply with our legal or regulatory obligations;
• • As necessary for our legitimate interests, including our interest in considering a broad array of Candidates for current and future employment opportunities within the Rakuten Group and our interest in maintaining or improving our recruiting processes, provided that the interests or fundamental rights and freedoms of the Candidate, under applicable law, are not overridden.

5. Security

We acknowledge that special attention needs to be paid to the handling of Personal Information. In compliance with applicable law, the Rakuten Group Companies have implemented appropriate technical and organizational measures in order to prevent the unauthorized, accidental, or unlawful access, loss, alteration and leakage of Personal Information, to maintain the accuracy of such information and, when necessary, to ensure its proper deletion. When collecting or transferring your personal information, we employ data encryption technology, and restrict access only to those persons who require it to fulfil their job responsibilities. For more information, please refer to the website below.
Information Security at Rakuten

6. Retention

We will retain your Personal Information for as long as your application process is ongoing and/or for as long as you consent to remain part of the Candidate pool or Talent Community, in order to contact you about relevant job opportunities. We also retain your Personal Information as required for our legal or regulatory obligations and where necessary to protect or assert our legal rights, in accordance with applicable law. You can ask us to delete your Personal Information at any time by contacting us using the form in Section 11. “Inquiries About the Companies in Scope and Career Activities in Rakuten”. The Rakuten Group Companies retain de-identified statistical and anonymous information about Candidates to help improve recruitment activities and processes.

7. International Transfers & Disclosure of Personal Information to Third Parties

• a. Within the Rakuten Group
• The Rakuten Group relies on the Rakuten Group Binding Corporate Rules to safeguard international data transfers within the Group.
• The Rakuten Group Binding Corporate Rules can be found at https://corp.rakuten.co.jp/privacy/en/bcr.html. In addition, for more information about the countries outside of Japan that we may disclose your personal information and the data protection legal systems in such countries, please refer to this page.
• b. To Third Parties
• Personal Information collected by us in the recruiting process may be disclosed to:
• • Third-party Service Providers that we engage to process Candidates' Personal Information on our behalf or for our sole benefit, such as for the purpose of
  > facilitating interview-related travel booking and expenses;
  > hosting the recruitment platforms;
  > sending communications to Candidates;
  > facilitating relocation;
• • Third parties that we have hired in order to perform pre-employment checks (in accordance with applicable law);
• • Recruitment agencies selected by us to handle the recruitment process;
• • Immigration advisors, including lawyers and consultants;
• • Where permitted by applicable law, in connection with a transaction for the purposes of corporate restructuring, sale, or assignment of assets, merger, divestiture, or other changes of the financial status of the Rakuten Group Companies, to a party or prospective party of such transaction;
• • Any third party as necessary to comply with applicable law, legal or regulatory obligations or regulatory inquiries or requests.

The recipients of these disclosures may be located in countries where data protection laws may not provide an adequate level of protection in comparison to applicable data protection laws in your region. In such cases, we will implement appropriate safeguards (such as Standard Contractual Clauses) for any transfers in compliance with applicable data protection laws.

8. Your Privacy Rights

a. Privacy Rights

You have certain rights regarding your personal information, subject to local law. These include the following rights to:

• • access your personal information;
• • rectify the information we hold about you;
• • erase your personal information;
• • restrict our use of your personal information;
• • object to our use of your personal information;
• • receive your personal information in a usable electronic format and transmit it to an external party (right to data portability);
• • learn more about the sources from which we collect information, the purposes for which we collect and share information, the information we hold, and the categories of parties with whom we share your information;
• • for California residents, opt out of certain disclosures of personal information that California law defines as “sales” even if no money is exchanged (for the avoidance of doubt, we will only use the Candidate’s personal information for the purposes described herein, so we do not sell your Personal Information per the California Consumer Privacy Act (“CCPA”));
• • for California residents, request information annually about any disclosure of your Personal Information to third parties for the third parties’ direct marketing purposes (for clarity, our practice is not to disclose your Personal Information for the purposes of third-party direct marketing unless you explicitly consent);
• • exercise privacy rights without fear of being denied goods or services in a discriminatory fashion as a result;
• • lodge a complaint with your local data protection authority.

b. Exercising Your Privacy Rights

In order to exercise your Privacy Rights, depending on the applicable law in your location or jurisdiction, please contact us using the contact form at the bottom of this page.

In addition, job applicants may check, change, and update the Personal Information they have provided to create their profile and submit their application at any time by logging into the recruitment platform for job applicants. For any specific application, the documents provided during the application process cannot be changed once they have been submitted. However, a Candidate may at any time take back the application and request deletion of their information.

For those who join or consent to remain in our Talent Community separate from an application for a particular position, please contact us at the above address to exercise your privacy rights, including to correct any information in your profile or to withdraw your consent to our continued processing of your Personal Information.

If you signed up to receive communications from us by email about potential future job opportunities, you can contact us at the above address in order to stop receiving these communications, or you can also opt-out or withdraw your consent to receive these communications by following the instructions in any such email communication from us. We will contact you if we need additional information from you in order to honor your privacy rights requests.

9. Cookies

Information about cookies is available in our cookie policy.

10. Companies in Scope

Currently using this recruitment platform are the following Rakuten Group companies. For any inquiries, please refer to Section 11. “Inquiries About the Companies in Scope and Career Activities in Rakuten”.

[To GHRD: Please input list of companies that are in scope of this platform, which will be kept up to date on a rolling basis.]

Country	Company Name
Japan	Rakuten Group, Inc.
Japan	Rakuten Customer Service, Inc.
Japan	Rakuten Edy, Inc.
Japan	Rakuten Games, Inc.
Japan	Rakuten General Insurance Co., Ltd.
Japan	Rakuten Insight, Inc.
Japan	Rakuten Insurance Holdings Co., Ltd.
Japan	Rakuten Insurance Planning Co., Ltd.
Japan	Rakuten Life Insurance Co., Ltd.
Japan	Rakuten Mobile, Inc.
Japan	Rakuten Payment, Inc.
Japan	Rakuten SS Insurance Co., Ltd.
Japan	Rakuten Super Logistics, Inc.
Japan	Rakuten Symphony, Inc.
Japan	Rakuten Total Solutions, Inc.
Japan	LinkShare Japan K.K.
Ireland	Kobo Software Ireland Limited
USA	Rakuten Marketing LLC. dba Rakuten Advertising
USA	RAKUTEN MOBILE USA LLC
USA	Rakuten USA, Inc. dba Rakuten Americas
USA	CARTERA COMMERCE, INC.
USA	Ebates Performance Marketing Inc. dba Rakuten Rewards
USA	Kobo (US) inc.
USA	Konmari Media Inc.
USA	Viki, Inc.
USA	Webgistix Corporation
UK	Rakuten Marketing Europe Limited
Estonia	Rakuten Estonia OÜ
Australia	Rakuten Marketing AUSTRALIA PTY LIMITED
Canada	Rakuten Kobo Inc.
Canada	Ebates Canada, Inc.
Singapore	Rakuten Asia Pte, Ltd.
Singapore	Rakuten Symphony Singapore Pte. Ltd.
Spain	Rakuten TV Europe, S.L.U.
Germany	Rakuten Marketing Germany GmbH
Brazil	RAKUTEN MARKETING BRAZIL LTDA.
Brazil	Kobo Livros Do Brazil LTDA.
France	RAKUTEN MARKETING FRANCE SAS
France	Kobo France SAS
Luxembourg	Rakuten Europe Bank S.A.
Luxembourg	Rakuten Europe S.a.r.l

11. Inquiries About the Companies in Scope and Recruitment Activities in Rakuten

Please fill in the form below for any question about this Policy.

Last updated: March 31, 2022