Privacy Policy for Recruitment Activities

  • This Privacy Policy for Recruitment Activities (hereinafter referred to as this “Policy”) sets out how Rakuten Group Companies using this recruitment platform (“Rakuten”, “we” or “us”) handle personal information of candidates for employment (“Candidate”) 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 Inc., a company headquartered at Rakuten Crimson House, 1-14-1 Tamagawa, Setagaya-ku, Tokyo, 158-0094 Japan. For more information about the Rakuten Group, please visit: https://global.rakuten.com/corp/about/. Currently using this recruitment platform and in scope of this Policy are the group companies listed with their contact information for inquiries in the end of this Policy. More information about the group company advertising an open position on the platform can be found in the ‘About Us’ section of the advertised position.

    When you apply for a position in Rakuten, you acknowledge that your information will be used and shared as described in this Privacy Policy. Please read this Policy carefully before submitting your application.

1. Data Controller & Candidate Pool

  • The group company for whose open position you apply for will be the controller of personal data processing. As members of the Rakuten Group, we are jointly sharing this recruitment platform with the other 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 on this website. At the same time, we may contact you with an offer from another group company in case that your application gets rejected, but we consider you to be 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 the individual Rakuten Group Companies for the purposes described in this Privacy Policy and such companies will also be data controllers.

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 via your submission or from someone acting on your behalf, such as a recruitment agency.
    Furthermore, we may collect information from additional sources, such as our service providers, for example during background checks. The information collected relates to the following categories:

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    Information provided by Candidates to create a 'Candidate Profile', such as username, password and e-mail address;
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    Basic profile information, such as name, age, sex, date of birth, telephone number;
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    Information necessary to evaluate your educational or work background, such as: educational records, work history, relevant qualifications;
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    Information relevant to the position you apply for, such as current annual salary, desired annual salary;
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    Information contained in any CV, resume, entry sheet and any other documents you submit to us in order to support your application;
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    Information relevant to the screening process that we may collect through background checks, reference checks and/or other confirmation procedures;
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    Contents of any form of communication conducted between us and the Candidate, including face-to-face conversations, telecommunications, phone inquiries and other forms of interviews;
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    Information about the usage of the platform, such as login information, login date and time; and
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    Past records and results of a Candidate’s prior application and screening processes.


    The collected Personal Information may include information that falls into one or more of the following categories (referred to as 'Sensitive Personal Information' depending on the applicable law):

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    race or ethnic origin;
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    political opinion;
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    membership of a political association or religious beliefs, affiliations or philosophical beliefs;
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    membership of a professional or trade association or membership of a trade union;
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    genetic or biometric
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    sexual preferences or practices;
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    criminal records; and/or
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    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 Privacy 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.

3. Purpose of Use

  • We will use the Personal Information for the following purposes:

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    To assess Candidates' qualifications with regard to available positions;
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    To provide Candidates with information about employment opportunities;
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    To contact and correspond with Candidates regarding job applications;
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    To check information held in relation to Candidates who have made previous applications;
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    If you were referred, to inform the referrer of the status and outcome of your application;
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    To contact you about a similar position in the future in case your initial application gets rejected, unless you object;
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    To conduct background checks on suitable candidates;
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    In order to diagnose technical problems;
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    To maintain and improve our recruiting process, for internal planning and reporting, and to comply with laws and regulations;
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    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 used during the term of their employment.

4. Legal Basis

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

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    A Candidate’s consent;
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    As necessary to perform a contractual obligation including with a Candidate;
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    To comply with our legal obligations;
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    As necessary for our legitimate interests, including in considering Candidates for current and future employment opportunities within the Rakuten Group and maintaining or improving our recruiting process, 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.

6. Retention

  • We will retain your information for as long as your application process is ongoing and as part of the candidate pool in order to contact you with relevant offers, in accordance with applicable law. You can ask us to delete your data any time by contacting us at the contact addresses below. The Rakuten Group Companies retain statistical and anonymous information about Candidates to help improve recruitment activities.
    Furthermore, we may retain your information were necessary to protect us from legal claims.

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.

    b. To Third Parties
    Personal Information submitted to us may be disclosed to:
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    Service Providers that we engage to process Candidates' Personal Information on our behalf, such as for the purpose of
    > facilitating interview-related travel booking and expenses;
    > hosting the recruitment platform;
    > facilitating relocation;
    •
    Third parties that the we have hired in order to perform pre-employment checks (in accordance with applicable law);
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    Recruitment agencies selected by us to handle the recruitment process;
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    Immigration advisors, including lawyers and consultants;
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    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;
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    Any third party 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 such cases, we will implement appropriate safeguards (such as Standard Contractual Clauses) for any transfers in compliance with applicable data protection laws.

8. Your Rights

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

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    access your personal information;
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    rectify the information we hold about you;
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    erase your personal information;
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    restrict our use of your personal information;
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    object to our use of your personal information;
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    receive your personal information in a usable electronic format and transmit it to an external party (right to data portability);
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    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;
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    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 applicant’s personal information for the purposes described herein, and none of these activities constitute a ‘sale of data’ under the California Consumer Privacy Act (“CCPA”));
    •
    exercise rights without fear of being denied goods or services;
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    lodge a complaint with your local data protection authority.


    Candidates may check, change and update the Personal Information they have provided to create their profile at any time by logging into the recruitment platform. For any specific application, the documents provided in the 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.

    If you would like to discuss or exercise such rights, please contact us at any of the addresses below. We will contact you if we need additional information from you in order to honor your requests.

9. Cookies

10. Companies in Scope and Contact



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