Pinterest Candidate Global Privacy Notice

Last Reviewed: April 15, 2024

Pinterest has prepared this Privacy Notice (“Notice”) for its Candidates. This Notice explains how and why we collect, use, store, disclose and otherwise process information about you, and your rights in relation to that information. This Notice also explains the limited extent to which Pinterest processes information where you have not yet submitted an application to Pinterest. We may update this Notice from time to time, for example if we start to use new systems or processes that use your personal data. You can find the current version on Pinterest’s Career Page (https://pinterestcareers.com/pinterest-candidate-global-privacy-notice/).

At Pinterest, our mission is to bring everyone the inspiration to create a life they love, including our Candidates. We are primarily headquartered in the United States and Ireland, with operations around the world. When we say “Pinterest,” “we,” “us” or “our” in this Notice, we are referring to the Pinterest company you are applying to, which will be the primary data controller responsible for the use of your personal data. 

More simply put: Because you are applying to work for Pinterest, we have to process some data about you. This Notice is intended to help you understand what data we process and why, and the rights you have. We might update this document now and then.

Our Collection and Use of Personal Data

"Personal data" means any information relating to an identified or identifiable natural person (like you!). We usually collect personal data directly from you, but sometimes we collect it automatically when you interact with our office, network and systems. We may also collect your personal data from other sources and third parties such as through a background check, where permitted by law. 

"Candidate Data" includes:

Candidate Data You Provide

Personal Data from Other Sources and Third Parties

We also obtain the above personal data from other sources, which we often combine with personal data we collect either automatically or directly from you. We receive personal data from our background check providers (results from pre-employment vetting can include criminal record checks where permitted by local law), our technology service providers, and, where permissible by local law, sometimes from social media and other publicly available sources. 

Sensitive Candidate Data

Some Candidate Data described here may be more sensitive than others, such as (where legally permitted) information about your health, certain identification numbers such as a Social Security Number, ethnic or racial origins,  trade union membership, physical or mental health data, or sexual orientation. We call this sort of data “Sensitive Candidate Data.”

Use of Candidate Data

We collect and process Candidate Data for a variety of reasons, most of which are needed to facilitate your application to Pinterest. We can only process your Candidate Data if we have a valid legal basis for doing so, and we are required to explain the various legal basis that we rely on to you. The table in Annex 1 sets out the purposes for why we use your data and, where required by applicable data protection law, the legal basis we rely on for each purpose. Pinterest does not “sell” or “share” your personal information or sensitive personal information as defined under U.S. and state laws.

Similarly, we collect and process Sensitive Candidate Data for a variety of reasons, and only if we have a valid justification for doing so, and we are required to explain the various justifications that we rely on to you. 

Annex 2 sets out the purposes and, where required by applicable data protection law, the legal justifications for which we process Sensitive Candidate Data.

Depending on where you live, certain laws require that you provide specific consent for the collection, use and disclosure of personal data. Under these circumstances the provision of your Candidate Data is voluntary and failure to provide such data does not affect the terms of your application to Pinterest.

If you grant consent for Pinterest to process your Candidate Data, you can withdraw your consent at any time by contacting us as set out below. Just note, withdrawing consent is forward-looking: it does not change the lawfulness of any processing that occurred before you withdrew your consent.

More simply put: There are lots of reasons why we need to process your data to progress your application with Pinterest. Typically, we won’t ask you for specific consent to process your data for these reasons. But where it’s legally required, we won’t process your Candidate Data unless you give us specific consent to do so. Those circumstances are laid out in the Annexes below.

Your Data Protection Rights

You have several rights in relation to your Candidate Data. These rights can differ by state or country, but can be summarized as follows: 

You may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, please note that if the exercise of these rights limits our ability to process personal information, we may no longer be able to engage with you in the same manner.

To exercise any of these rights, please contact us as stated below. We will respond to your request consistent with applicable law. To respond to some rights we may need to verify your request either by asking you to verify your identity by providing information about yourself or your application. Authorized agents can make a request on your behalf if you have given them legal power of attorney or we are provided proof of signed permission, verification of your identity, and, in some cases, confirmation that you provided the agent permission to submit the request. Under certain circumstances provided by local law, we may be delayed, limited or unable to exercise your rights.  In such a case, we will let you know why.

Sales, Sharing or Targeted Advertising 

Except as otherwise described in our Privacy Notice in connection with Candidates acting in their capacity as website visitors, we do not sell personal data about individuals acting in their capacity as Candidates, and we do not share or otherwise disclose personal data about individuals acting in their capacity as Candidates to third parties for the purpose of displaying advertisements that are selected based on personal data obtained or inferred over time from an individual’s activities across businesses or distinctly-branded websites, applications, or other services (otherwise known as “targeted advertising” or “cross-context behavioral advertising”).

Data Sharing and Transfers

We may transfer personal data to Pinterest subsidiaries or affiliates located outside of your country for processing, including to countries where data protection laws and regulations may differ from those in your jurisdiction. In particular, data may be transferred to Pinterest, Inc. in the United States and may be accessed elsewhere.  

Likewise, Pinterest may also share personal data with third parties outside Pinterest, including: 

• Governmental and regulatory bodies include labor authorities and law enforcement, which we will share data with when required by applicable laws, to prevent and detect crime or in connection with a corporate restructuring or transaction.
• Our service providers include those that provide products or services to Pinterest or a related entity, such as companies conducting background checks.
• Corporate business transactions may include transfers to potential purchasers of or investors in part or all of Pinterest, its business, or any or part of any affiliated entity.  
• We will also share Candidate Data when we contact your referees to confirm your references. 
• Also, when you use third-party apps, websites or other products integrated with our systems to apply for a role, these third parties may collect information about you subject to their own terms and privacy policies.

For a full list of the Pinterest entities and third parties that we may share your data with, please contact us as set out below.

More simply put: There are other entities we may need to share your data with to progress your application with Pinterest or for legal reasons. 

International Data Transfers

Information controlled by Pinterest will be transferred or transmitted to, or stored and processed in, the United States or other countries outside of where you live for the purposes as described in this Notice. 

Because Pinterest is a worldwide service, we may transfer the personal data to a country outside your home country, the European Economic Area (“EEA”), or the United Kingdom (“UK”). Where we transfer information from the EEA or the UK to a country that doesn't provide an adequate level of protection, we’ll only do so under appropriate safeguards to protect your information. In other instances where we transfer information outside of your home country, we will only do so under the protection of appropriate safeguards to protect your information. 

Safeguards which we rely on in ensuring your information benefits from an adequate level of protection includes the following:  

• Adequacy decisions. These are decisions issued from the European Commission under Article 45 GDPR (or equivalent decisions under other laws) where they recognise that a country offers an adequate level of data protection. We transfer your information as described in Annex 1 to some countries with such adequacy decisions; or
• Standard contractual clauses (“SCCs”). The European Commission has approved contractual clauses under Article 46 of the GDPR that allows companies in the EEA to transfer data outside the EEA. These (and their approved equivalent for the UK) are called standard contractual clauses. We rely on standard contractual clauses to transfer information as described in Annex 1 to certain entities in our family of companies and third parties in countries without an adequacy decision.
• Outside of the EEA & UK, we will ensure your information benefits from an adequate level of protection by implementing additional safeguards adapted to the specific nature of the data and the risks involved, in accordance with local laws. 

While transfers to countries that don’t have an adequacy decision typically take place on the basis of SCCs, in certain circumstances, transfers can also take place on the basis of exemptions provided under data protection law. For example, we may share information with law enforcement, in emergency situations where we learn that a person’s life is at risk. 

We also identify and use additional protections as appropriate for each data transfer. For example, we use:

• technical protections, such as encryption and pseudonymisation; and 
• policies and processes to challenge disproportionate or unlawful government authority requests.

For a copy of these adequacy decisions or SCCs, please make a request as set out below. 

More simply put: Pinterest has several different entities in different countries, and we might need to transfer your data outside of your home country in order to process it. Sometimes, we also need to share your data with third parties.  We’ve listed some of the circumstances where this could become necessary, but you can contact us for the full list. If you’re in the EU and we transfer your data out of the EEA, we will take the appropriate steps to make sure your data is protected during the transfer.  If you want to know what those steps are, just ask!

How Long We Keep Personal Data

Your Candidate Data will not be kept in a form where you can be identified for any longer than is reasonably necessary to achieve the purposes described in Annexes 1 and 2, or longer than where we are permitted under local law to retain the data (including, for the purpose of meeting any legal, or other reporting requirements or obligations). 

If you are successful in your application, the information you provide during the application process will be retained by us as part of your employee file for the duration of your employment at Pinterest (and subject to our Employee Privacy Notice) and for an extended period of time to comply with our legal obligations, to resolve disputes and to enforce our agreements.

If you are unsuccessful at any stage of the process, the information you have provided until that point will be retained for a 4-year period, so we may reach out to you for future opportunities, comply with our legal obligations, and resolve disputes. 

More simply put: We delete candidate data after we no longer need it unless there’s a legal or practical reason why we can’t.

Information for when you have not submitted an application to Pinterest before

Even if you have not yet submitted an application to Pinterest, Pinterest may process limited information about you (e.g., name, email address, geographical location, gender, company, education history). This information is either obtained from publicly available sources (e.g., LinkedIn) or provided to us by someone who referred you for potential employment with Pinterest. Pinterest processes this information for the purpose of communicating with you and providing you with information regarding new roles and opportunities at Pinterest that may be of interest to you.

Pinterest processes this information as necessary to fulfill our legitimate interest of maintaining a talented workforce and your interest in learning of new roles and opportunities. You have the right to opt out of this processing at any time, please contact us. 

We will process your information in accordance with this Notice, which includes the Your Data Protection Rights, International Data Transfers, and Company Contact Information sections.  

Company Contact Information

To ask any questions related to this Notice or Pinterest’s candidate privacy practices, or if you would like to exercise your rights, please reach out through our Help Center. If you are applying for a position in the EU or UK, you can also submit an inquiry or complaint to Pinterest’s Data Protection Officer, available through the Data Protection Officer Contact Form. You also have the right to lodge a complaint with the competent data protection supervisory authority.  Please see below for a list of the local supervisory authorities. 

• UK: Information Commissioner’s Office (“ICO”)
• France: Commission Nationale de l'Informatique et des Libertés (“CNIL”)
• Germany: Berliner Beauftragte für Datenschutz und Informationsfreiheit (“Berlin BfDI”)
• Italy: Garante per la protezione dei dati personali ("Garante")
• Spain: Agencia Española de Protección de Datos (the "AEPD")
• Ireland: Data Protection Commission (“DPC”)

ANNEX 1 – USES AND LEGAL BASES FOR PROCESSING CANDIDATE DATA

We may use the Candidate Data we collect during the recruiting process and when an individual applies for a job with us for the purposes described below. In addition, under applicable data protection law in the European region (such as the GDPR), companies must have a legal justification (i.e., legal bases) to process your information for the various purposes described in this Notice.

Purpose	Tell Me More!	Legal Bases
		Contract Performance	Legal Requirements	Substantial Public Interest (as permitted by law)	Our Legitimate Interests	Your Vital Interests
Hiring a workforce	Processing your application, including any assessments and interviews, so as to hire suitable candidates; seeking assurances from previous employers and referees as to candidates’ work performance and reliability.
Future roles at Pinterest	Keeping your Candidate Data to consider whether you’d be suitable for another role at Pinterest.
Background checks	Carrying out background checks such as checks against exclusion and sanction lists as required and as permitted under the local law.
Legal & Regulatory Obligations	Complying with legal and other requirements, such as conducting audits, compliance with government inspections and other requests from government or other public or regulatory authorities, and complying with internal policies and procedures. In particular, Pinterest may process data concerning health (which are considered categories of Sensitive Personal Data) in order to comply with its legal obligations.
Compliance; Prevention & Detection of Crime	Monitoring compliance with contractual obligations, Pinterest policies and codes of practice; complying with management reporting requirements; facilitating internal investigations and preventing and detecting crime.
Corporate Finance	Complying with corporate financial responsibilities, including audit requirements (both internal and external) and cost/budgeting analysis and control.
Pinterest Company Administration	Communication of Candidate Data to other Pinterest companies for reasons related to your application to Pinterest.
Litigation and Investigations	Responding to data requests and other preparation in the context of potential or actual litigation or other investigation.

Where required by applicable data protection law, when we rely on legitimate interests in processing Candidate Data, we only do so where those legitimate interests are not overridden by your rights and interests.  Our legitimate interests can include: 

• Hiring a workforce: Pinterest will collect and process Candidate Data in pursuing its legitimate business interests in hiring suitable candidates and seeking assurances from previous employers and referees as to candidates’ work performance and reliability. If you are successful in your application, Pinterest will process your Candidate Data in order to take steps at your request prior to entering a contract with you (which will be governed by our Employee Privacy Notice). 
• Future roles at Pinterest: Pinterest may rely on its legitimate business interests in maintaining a talented workforce and in your legitimate interests of ensuring that you are considered for future roles at Pinterest.
• Background checks: Pinterest may perform background checks as required by applicable laws or in other cases in our legitimate interest to protect Pinterest, our employees, customers and members; conducting checks against exclusion and sanction lists as required or permitted by applicable laws.
• Prevention and detection of crime (including health & safety): Pinterest may use your Candidate Data for safety and security purposes as is necessary to pursue Pinterest’s legitimate interests in protecting itself, its affiliates and Pinterest employees and guests against security risks of all types. Any such processing in this respect would also be in your legitimate interests. In certain limited cases, Pinterest may rely on your or a third party’s vital interests to process Candidate Data, such as where there is an imminent threat to life. 
• Legal & regulatory obligations (including litigations and investigations): Pinterest may use your Candidate Data when it is in Pinterest’s legitimate interest or where necessary to preserve or defend its rights in court, to respond to law enforcement or government agency requests or discovery procedures, or where required or permitted by applicable laws, court orders, government regulations, or government authorities (including tax and employment) which may include lawful access by courts or governmental authorities outside your country of residence (such processing may also be necessary for Pinterest to comply with its legal obligations).
• Pinterest company acquisition: Pinterest may transfer your Candidate Data when it is in Pinterest’s legitimate business interests to facilitate an acquisition.
• Sensitive personal data: Pinterest may process special categories of data (for example, if you voluntarily disclose data about any disability or health condition which you may have) where necessary for the establishment, exercise or defense of a legal claim by Pinterest or where necessary for the purpose of carrying out our obligations and for the exercising of Pinterest’s rights or your rights in the field of employment or social security law. Where permitted by local law, Pinterest may collect racial or ethnic data to comply with local laws or to promote diversity and inclusion objectives during the application process. 

ANNEX 2 – USES AND LEGAL BASES FOR PROCESSING SENSITIVE CANDIDATE DATA

We may use the Sensitive Candidate Data we collect during the recruiting process and when an individual applies for a job with us for the purposes described below. In addition, under applicable data protection law (such as the GDPR in the EU), companies must have a legal justification (i.e., legal bases) to process your information for the various purposes described in this Notice.

Purpose	Tell Me More!	Legal Bases
		Obligations Under Collective Agreement, Employment, Social Security, or Social Protection Law, or Another Applicable law	Your Explicit Consent	Substantial Public Interest (if permitted by law)	Defending Against Legal Claims
Health and Safety	Processing health and medical data, such as information on disability may be necessary for compliance with legal obligations, and providing accommodations during the application process in accordance with local law.
Right to Work & Visa Checks	We are required to conduct right to work checks or visa and immigration checks, which may involve us using race or ethnicity data such as information contained in your passport or other citizenship and right to work documentation where permitted by local law.
Pinterest Company Administration	We need to communicate health data and data related to trade union membership to other Pinterest companies, processors, benefits providers and trade unions for reasons related to the management of the candidate application.
Equity & Inclusion	Where permitted by local law, Pinterest may collect racial or ethnic data to comply with local laws or to promote diversity and inclusion objectives during the application process.