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Personnel Privacy Policy

Updated 2 February 2021

This Privacy Policy describes how Open Technology Fund (“Open Technology Fund,” “we,” “us,” and/or “our”) handle personal data we collect from employees, contractors, consultants, and other individuals (collectively, “personnel”) who currently work or previously have worked for Open Technology Fund, as well as individuals who have applied to or been recruited by Open Technology Fund. This Policy explains the types of personal data we collect, how we may use and share the data, and the choices that are available to you with respect to our handling of your data.

Information We Collect

We collect different types of information depending on if you are current or former personnel or have applied for or are recruited for a job at Open Technology Fund. We collect information you provide directly to us as well as information on you that we obtain from third parties. The types of personal data we may collect include:

  • Contact information, such as your name, email address, mailing address, and phone number;
  • Government or national identification information, such as your driver’s license number, passport number, national insurance or social security number, and visas and work authorizations;
  • Recruitment information, such as your resume, cover letter, references, and employment application;
  • Payroll information, such as your banking and direct deposit forms, salary, tax forms, expense reimbursement records, and vacation and PTO balances;
  • Performance information, such as performance reviews and disciplinary reports;
  • Benefits information, such as your benefits elections, beneficiaries, spousal or partner information, and dependent information; and
  • Other information that supports our human resources or our business operations.

We may also collect information about your use of our organization’s technology and resources, including email, instant messaging, file share and employee collaboration platforms, IT help desk, and employee training tools.

How We Use Your Information

We use your personal data to support Open Technology Fund’s human resources and other business purposes, including:

  • Recruitment, such as evaluating an application for employment, conducting interviews, conducting background checks (when we have your consent), and deciding terms of an employment offer;
  • Personnel management, such as monitoring assignments, evaluating performance, training employees, communicating with you, and responding to your requests, inquiries, and comments;
  • Operational purposes, such as distributing payroll and benefits, updating personnel files, conducting audits, and providing IT support and other troubleshooting;
  • Legal and compliance purposes, such as implementing internal policies, responding to suspected fraud or other illegal activity, protecting Open Technology Fund’s and others’ rights and property, and complying with laws, legal processes, or governmental requests.

How We Share Your Information

We do not share your personal data except in the limited circumstances described below:

  • With Open Technology Fund personnel and affiliates to carry out human resources and other business operations, as well as external third parties that perform these operations on our behalf (e.g., health insurance and IT companies);
  • With legal or regulatory authorities to comply with our obligations, to protect the rights and property of Open Technology Fund, our customers, and the public, and to detect and respond to suspected illegal activity and threats to the safety of any person or of our systems or services;
  • With our funder, only to the extent necessary to comply with regulatory requirements and contractual commitments, and
  • With your consent and at your direction.

Data Retention

We keep your personnel records while you work at Open Technology Fund and thereafter as required by law or for as long as is reasonably required for our business purposes. We keep candidate records for two years.

How to Access, Correct, and Delete Your Data

You can contact Open Technology Fund’s General Counsel at [email protected] to request to access, correct, or delete certain personal data you have provided to us. Current personnel may also have internal tools to carry out these tasks. To access these tools, www.justworks.com

Rights Specific to Residents of the European Economic Area

If you are a resident of the European Economic Area (EEA), you have certain rights and protections under the law regarding the processing of your personal data.

Legal Basis for Processing

If you are a resident of the EEA, we will only process your personal data:

  • To perform our responsibilities under our contract with you (e.g., direct depositing payroll into your bank account);
  • When we have a legitimate interest in processing your personal data (e.g., to communicate with you or evaluate your performance); or
  • To comply with our legal or regulatory obligations.

Data subject requests

If you are a resident of the EEA, you have the right to access personal data we hold about you and to have certain personal data corrected or erased. You may also have the right to restrict certain processing of your data. In addition, Open Technology Fund will not use your data for automated decision-making that has legal or similarly significant effects.

To make any of these requests, current and former personnel and candidates should contact the general counsel at [email protected] We will respond as soon as practicable and no later than one month after receipt of your request. We may request proof of identification to verify your request.

We may deny or restrict fulfillment of your request in some cases, such as when your access to data places another individual’s privacy rights at risk, or the continued processing of your data is necessary to comply with a legal obligation. If so, we will notify you of the reason(s) for this denial.

Transfers of Personal Data Outside the EEA

Open Technology Fund is headquartered in the United States, and we have operations and service providers in the United States and other countries. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.

International transfers of data

Where we transfer your data outside of the European Union or the European Economic Area, we will ensure that your data is appropriately protected by requiring the recipient to respect and uphold your rights as a data subject under all applicable laws and by making the transfer subject to an international transfer safeguard, for example the Standard Contractual Clauses issued by the European Commission.

Questions or Complaints

If you are a resident of the EEA and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. Contact details for your Data Protection Authority can be found using the links below:

For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en

For individuals in the UK: https://ico.org.uk/global/contact-us/

For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

Changes to Our Privacy Policy

We may change this privacy policy from time to time. Each version of this policy is identified by its effective date.

Contacting Open Technology Fund

If you have questions or concerns regarding this Policy, please contact us using the information provided below.

Open Technology Fund
2101 L Street NW, Suite 300

Washington, DC 20037 USA

[email protected]

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