Applicant Privacy Notice

Last Updated: July 25, 2025

Introduction

When you apply to Lapel, Inc. ("Lapel," "we," "us," or "our"), you trust us with information about yourself. We take that seriously—and we want to be clear about what we collect, why we collect it, and how we use it.

This notice covers how we handle personal data—information that identifies, or could reasonably identify, you, your household, or your device—and explains your rights along the way.

If you have any questions, contact us at privacy@lapel.com.

Applicability

This Privacy Notice applies to individuals who apply for or are interviewed for jobs at Lapel, Inc. ("Lapel"). Employees and former employees should refer to our employee privacy notice.

This Privacy Notice does not apply to your use of Lapel’s software platform, website, or marketing and support channels (collectively, our “Business”), as defined in our Privacy Policy. For more information about how Lapel collects and processes Personal Information in those contexts, please refer to our Privacy Policy.

Personal Data We Collect

In connection with our application and recruitment processes, we collect Personal Data: (1) that you provide us directly; (2) that we collect automatically from our website; and (3) from third parties, including publicly available sources.

Personal Data You Provide Us

We collect the following types of Personal Data that you provide to us when you submit a job application to Lapel or are considered as a candidate in our recruitment process:

  • Contact information, including your name, email address, phone number, address, and other contact details

  • Employment, professional, and education information, including your current and past employer(s), job title, certifications, resume or CV, education history, transcripts, compensation expectations, benefits information, willingness to relocate, and other preferences shared during the process

  • Sensitive personal data, such as your citizenship or immigration status, and any voluntary demographic data you choose to provide (e.g., race, ethnicity, gender, or health info relevant to accommodation requests)

  • Publicly available information (e.g., LinkedIn profile, website, portfolio)

  • Audio or video recordings and transcripts of interviews

  • Information from assessments administered as part of your candidacy

  • Communications with us (e.g., email, SMS messages), including metadata

  • Additional information shared during interviews or phone screenings

  • Inferences drawn from the above data points

Personal Data We Collect Automatically

When you visit www.lapel.com, we use cookies and related technologies (e.g., log files, pixels, web beacons, SDKs) to collect and process certain information automatically. For more detail, including opt-out options, review your device settings or refer to the "Your Rights and Choices" section below.

Personal Data We Collect from Third Parties

We may collect information related to your application or candidacy from references you provide us or from former co-workers or employers. When you provide us with personal data of your references, you agree that you are authorized to provide that information to us.

Where applicable, we also collect personal data from third parties, such as our service provider(s) that conduct background checks and talent search or recruiting companies we may work with.

We collect personal data from publicly available sources and other online sources you make available to us (e.g., LinkedIn, GitHub, or personal websites or portfolios). By authorizing Lapel to have access to this information, you agree that Lapel may collect and use that information in accordance with this Privacy Notice.

How We Use Personal Data We Collect

We use Personal Data collected in connection with the application and recruitment processes to:

  • Assess your skills and fit for opportunities at Lapel

  • Conduct background checks and identity verification

  • Communicate with you about your application, the process, and future roles

  • Assist in immigration- or visa-related efforts if applicable

  • Refine our application and recruitment workflows

  • Comply with applicable legal obligations or respond to requests from government authorities

  • Protect or enforce our legal rights

  • Take steps at your request prior to entering into an agreement or offer of employment

  • Detect and prevent fraud or security incidents

  • Facilitate legitimate business functions, including consulting with investors

If you are offered and accept employment with Lapel, Personal Data collected through the application and recruitment process will become part of your employment record and will be subject to our Employee Privacy Notice.

Disclosure of Personal Data by Lapel

We may disclose your Personal Data to:

  • Our affiliates.

  • Our service providers, including those that host application information, conduct background checks, and assist us to detect, prevent, and respond to fraud and security incidents. These service providers may be located or host Personal Data outside the country in which you live or the country where the position you applied for is located.

  • Our Investors and advisors, for legitimate business reasons.

  • Courts and tribunals, regulatory bodies, or local labor authorities, where required.

  • With other third-parties, such as when we contact references you provide.

Your Rights and Choices

Access, Correction, Deletion, and Objection to or Restriction of Processing

Subject to limitations under applicable law, residents of certain jurisdictions have rights and choices with respect to your Personal Data. We will not discriminate against you for exercising these rights. Those rights may include the right to:

  • Access the Personal Data we maintain about you and receive an electronic copy

  • Correct inaccurate Personal Data

  • Request deletion of your Personal Data

  • Object to or request restriction of certain processing activities (e.g., marketing or profiling)

  • Withdraw consent where processing is based on consent

These rights may be limited, for example, if fulfilling your request would reveal Personal Data about another person, where they would infringe the rights of a third party (including our rights), or if you ask us to delete information which we are required by law to keep or have compelling legitimate interest to keep.

To exercise any of your rights, you can contact us at privacy@lapel.com. We will confirm receipt of your request and respond to your request within the time limits prescribed by law. We may require additional information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your request.

In certain jurisdictions, you have the right to appeal to us a decision we’ve made to refuse to take action in response to your exercise of one of the rights above. In order to submit an appeal to us, you can contact us at privacy@lapel.com with the subject line “Privacy Request Appeal” and information relevant to the appeal in the email.

Residents of the E.U., Switzerland, and the U.K. also have the right to lodge a complaint with the data protection regulator in your jurisdiction. You can lodge the complaint in the country where you reside, where you work, or where any alleged infringement of data protection law occurred.

Communication Preferences

Lapel uses Ashby to manage the application process and may contact you via email or SMS. Message frequency may vary. You may opt out at any time by replying “STOP.” Standard carrier rates may apply. We do not share or sell SMS opt-in data for marketing purposes. Carriers are not liable for delayed or undelivered messages. If you have any questions about your text plan or data plan, it is best to contact your wireless provider.

You can opt out of text or SMS messages at any time by texting back "STOP". After you send the SMS message "STOP" to us, we will send you an SMS message to confirm that you have been unsubscribed. After that, you will no longer receive SMS messages from us. Text messaging originator opt-in data and consent will not be shared, sold, rented, or otherwise disclosed by us for marketing purposes. If you are experiencing issues with the messaging program, please contact us by emailing support@lapel.com.

International Data Transfers

Although Lapel operates from the U.S., applicants may apply globally. Your Personal Data may be transferred to and stored in the U.S., which may not offer the same level of protection as your home country.

We take measures to comply with applicable data protection laws when we transfer Personal Data internationally. In certain situations, regulators, courts, and law enforcement agencies might be entitled to access your Personal Data (for more information, see the section "Disclosure of Personal Data by Lapel" above).

If you reside in the E.U., U.K., or Switzerland, we will apply appropriate safeguards such as:

  • Transfers to countries with adequacy decisions

  • Standard Contractual Clauses (SCCs) and appropriate addenda

  • Confirming vendor compliance with relevant Data Privacy Frameworks

Where required, we use technical measures (e.g., encryption, access controls) and internal processes to assess and, if needed, challenge government data access requests.

Lawful Basis for Processing

Certain jurisdictions, such as the E.E.A., Switzerland, and the U.K. require a "lawful basis" to collect, process, and disclose Personal Data. Where we are the Controller of your Personal Data, we rely on the following lawful bases:

  • Compliance with our legal obligations or to preserve or enforce our legal rights.

  • Consent that you provide us at the time of collection of your Personal Data or subsequently.

  • To take steps at your request prior to—or as necessary for—entering into a contract.

  • To further the legitimate interests of Lapel or a third party, for example, to: (1) administer and conduct our business; and (2) detect, prevent, and respond to fraud and security incidents.

  • To protect or preserve your vital interests, where applicable, such as for health or safety reasons.

Security

We use various technical, organizational, administrative, and physical measures designed to protect your Personal Data from loss, theft, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no information security program or use or transfer of electronic information is entirely secure, so we cannot guarantee the security of your Personal Data. Access to personal data is limited to personnel who require it to perform their job duties and who are bound by confidentiality obligations. If you have questions about our security measures, email us at security@lapel.com.

Retention

If you apply for a job at Lapel and your application is unsuccessful, we will retain your application and interview information for two years (or longer if required by law) in accordance with our record retention policies, to consider you for future roles and to comply with legal obligations.

If you are offered and accept employment with Lapel, information collected during the applications and recruitment process will become part of your employment record and will be retained as permitted by applicable law and in accordance with our record retention policies for employee information.

If you have questions about record retention policies in connection with our application or recruitment processes, you can email us at privacy@lapel.com.

Changes to this Privacy Notice

We may update this Privacy Notice periodically to reflect changes in legal, regulatory, or operational requirements, our practices, or other factors. Please check this Privacy Notice periodically for updates. When required under applicable law, we will notify you in advance of any changes to this Privacy Notice by posting a notice on this page prior to any changes taking effect (and updating the "Last Updated" date at the beginning of this Privacy Notice) or in another appropriate manner.

Contact Us; Data Controller

If you have questions about this Privacy Notice or our practices with respect to your Personal Data, or if you have difficulty accessing the information in this Privacy Notice, please contact us:

By email: privacy@lapel.com

By mail: Lapel, Inc., Attn: Privacy, 2261 Market Street #22368, San Francisco, CA 94114

Unless otherwise stated, Lapel, Inc. is the data controller of the Personal Data described in this Privacy Notice.

California Notice at Collection

This section applies only to California residents. Under California law, you have the right to know what categories of Personal Information and Sensitive Personal Information (as defined under California law) we collect (see "Personal Data We Collect"), the purposes (see "How We Use Personal Data We Collect"), whether we "sell" or "share" it, and how long we retain it (see "Retention").

Categories Collected

The categories of Personal Information and Sensitive Personal Information that we collect in connection with our application and recruitment processes, include:

  • Identifiers, including your name, phone number, address, email address, and unique identifiers connected with the browser, application, or device you use.

  • Employment, professional, and education information, including your current and past employer(s), job title, professional certifications, resume or CV, education, transcripts, desired salary or compensation, information relating to benefits terms and packages, willingness to relocate, job preferences, and other information you provide us in support of your application or during the recruitment process.

  • Demographic information, including your race or ethnicity, citizenship or immigration status.

  • Financial information, such as your current or desired salary and other information relating to compensation and benefits.

  • Internet, network and other activity information.

  • Geolocation data, such as your IP address.

  • Audio, electronic, visual, and similar information, including those transmitted, recorded, or transcribed during interviews or phone screenings.

  • Communications, such as emails, or text or SMS messages if you opt into receiving text or SMS messages, along with associated metadata.

  • Health or medical information you provide in connection with the application or recruitment processes, such as accommodations requests.

  • Criminal background, where applicable, solely for the purpose of completing a background check in connection with an offer of employment.

  • Other information you provide in connection with the application and recruitment processes, such as assessments you take.

  • Inferences drawn from the information above.

Business Purposes for Which We Disclose Personal Information

We disclose Personal Information to parties listed in "Disclosure of Personal Data by Lapel" for the reasons detailed in "How We Use Personal Data We Collect", which include the following business purposes (as defined under California law):

  • For operational and administrative purposes, including the purposes notified in this Privacy Notice.

  • Helping to ensure security and integrity.

  • Undertaking internal research and analytics.

  • Undertaking activities to verify or maintain the quality or safety of or improve or enhance Lapel's recruitment processes.

California Privacy Rights

You have the right to know certain details about our Personal Information practices and the rights you have under California law. You have a right to know the categories of Personal Information we have collected about you; the categories of sources from which the Personal Information was collected; the categories of Personal Information we have disclosed for a business purpose or "sold" or "shared;" the categories of persons to whom the Personal Information was disclosed, "sold," or "shared;" the business or commercial purpose for collecting, "selling," or "sharing" the Personal Information; and the specific Personal Information we have collected about you. We have provided much of that information throughout this Privacy Notice, and to the extent it is not addressed elsewhere, it is addressed in this section. In addition, subject to certain exceptions, you have the right to request that we correct inaccurate Personal Information or that we delete the Personal Information we have collected from you. To exercise your privacy rights, please email us at privacy@lapel.com. We will confirm receipt of and respond to your request within the time limits prescribed by law. We may require additional information from you to help us verify your identity and to process your request. If we are unable to verify your identity, we may deny your request.

You have the right not to receive discriminatory treatment by us for the exercise of any of your privacy rights. We retain records of privacy rights requests in accordance with applicable law.

We do not "sell" or "share" Personal Information we collect about you as part of the application or recruitment processes. However, while visiting www.lapel.com, information related to your site visit may be shared for targeted or behavioral advertising. You can manage these preferences via your browser or device settings.

Authorized Agents

You can designate an authorized agent to submit requests on your behalf, and the authorization must be a signed document or power of attorney from you. In order to do that, please provide the agent with written permission, signed by you, authorizing the agent to submit the request on your behalf. The agent must provide us with that written permission as part of the request. We may contact you to verify your identity directly, as well as the authorized agent’s permission, before we send a response to the request.

Requests from an authorized agent to exercise rights under data protection law on your behalf must be submitted through the designated methods listed above.

Opt-Out of Sharing/Sale

We do not "sell" or "share" applicant Personal Information for advertising purposes. When visiting www.lapel.com, certain data may be used for analytics. You can manage these preferences via your browser or device settings.

Copyright © 2025 Lapel, Inc. All rights reserved.

Copyright © 2025 Lapel, Inc. All rights reserved.