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Applicant Privacy Policy

Version /legal/applicantprivacy/1.1.0/ of This Agreement was created on July 25, 2023 .

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Sentry is committed to protecting and respecting your privacy. This Applicant Privacy Policy (“Policy”) sets out how we collect and process personal information about you during the recruitment process for career opportunities at Sentry.

What information do we collect?

You may choose to disclose information to us directly, or we may obtain or produce information during the recruitment process. The information we collect can include the following:

  • Name and Contact Information. Your name, home address, email address, telephone number, and other contact information.
  • Professional and Education Information. Information related to your work experience, educational background, professional licenses, and certifications and other relevant experiences and qualifications, including any provided resume, CV, cover letter, or transcript.
  • Job Preferences. Details about your job preferences, including current or desired salary, preferred start date, type of work, work location, and other compensation and benefits.
  • Assessment Information. Information from phone-screenings, interviews, and skills assessments.
  • Government ID and Work Authorization. Government identification details, such as citizenship, immigration, and residency status and work authorization information (as permitted or required by law).
  • References and Background Checks. Information from employment and academic references and from background checks (as permitted or required by law).
  • Publicly Available Information. Information from publicly available sources such as professional networking sites.
  • Sensitive Information. Sensitive information that we request for legitimate recruitment-related purposes such as gender, citizenship, nationality, health information, and racial or ethnic origin.
  • Other Information You Provide. Other information that you choose to provide to us during the recruitment process.

We may obtain this information from third-party sources, including from recruiting partners, job websites (if you apply through such websites), referrers (if you are being referred), references that you provide, background check providers (when applicable), third-party data providers who have the rights to provide us with your information, and publicly available sources.

When you visit the careers section of our website at, we also collect certain information automatically by recording how you interact with our website through use of technologies like cookies. For more information, please see the privacy policy that applies to your use and interaction with our website at

What do we use your information for?

We use the information we collect to carry out our recruitment process, which includes:

  • Communicating with you. Responding to your inquiries, providing you with information on potential career opportunities and otherwise communicating with you to facilitate the recruitment process.
  • Assessing fit. Assessing your capabilities, qualifications, and interests against our career opportunities.
  • Processing your application. If you apply for a job with us, reviewing and processing your application.
  • Verifying your information. Verifying information that you or others provide and conducting reference and background checks (as permitted or required by law).
  • Improving our processes. Evaluating and making improvements to our recruitment processes.
  • Complying with laws. Complying with applicable laws, including reporting requirements, and responding to valid legal processes, judicial orders, or subpoenas.
  • Protecting interests of Sentry and others. Protecting the rights, interests, or property of Sentry or others as required or permitted by law.

Do we disclose any information to outside parties?

We disclose your information with your consent or as necessary for the purposes described in this Policy.

We will disclose your information to other Sentry group companies around the world to administer our recruitment processes and store data. We will also disclose your information to service providers and agents working on our behalf for the purposes described in this Policy. For example, background check providers, applicant tracking system providers, data storage providers, and other third parties that provide support and advice in relation to our legal obligations.

We will access, transfer, disclose, and preserve information when we have a good faith belief that it is required or permitted under applicable law, including to respond to valid legal processes, judicial orders or subpoenas, meet national security or law enforcement requirements, and protect the rights, interests, or property of Sentry and others. Finally, we may disclose your information in connection with the sale, assignment, or other transfer of all or part of our business.

How do you access and control your information?

In certain countries, you may be granted certain rights with respect to your personal information, including to receive a copy of your personal information, update your personal information or delete your personal information. The rights you have may depend on where you are based and applicable law (see Supplemental notice for EU or UK individuals and Supplemental notice for California residents).

To exercise your rights, please submit your request via the online form at and include an email address. We will verify your ability to access that email address and use reasonable efforts to respond to any requests in accordance with applicable law. Note there may be certain circumstances where we are required or permitted by law to deny your request. For example, we may be legally required to retain certain information for record-keeping purposes.

Where do we store and process your information?

Information collected by Sentry may be stored and processed in the United States and other countries where Sentry or its affiliates, subsidiaries, or service providers maintain facilities. Regardless of where your information is processed, we take steps to ensure that processing is in accordance with this Policy and the requirements of applicable law.

This means that we transfer information from the European Economic Area (EEA), the UK, and Switzerland to other countries, some of which may not provide an equivalent level of protection for personal information. When we engage in such transfers, we use a variety of legal mechanisms to help ensure your rights and protections travel with your information, including standard contractual clauses that have been approved by the European Commission.

How long do we retain information we collect?

We retain information we collect for the period necessary to carry out the purposes set out in this Policy unless a longer period is required by law.

If we hire you, we will incorporate the information we collect into your employment record. If your application is unsuccessful (or you withdraw or decline our offer), we will retain the information we have collected for a reasonable period after your application to consider you for other current or future roles at Sentry, to help us better assess and improve our recruitment processes, and for record keeping purposes. If you do not want us to retain your information, please let us know by following the process above (see How do you access and control your information?). Please note, however, that we may retain some information if required by law or as necessary to protect ourselves from legal claims.

Changes to this Policy

We may update this Policy from time to time. When we make changes to this Policy, we will revise the date at the top of this Policy. We encourage you to periodically review this Policy to learn how Sentry is protecting your information. Please note that this Policy will not form part of your employment contract and does not create any contractual rights or obligations.

Contact us

If you have any questions or concerns about this Policy, please contact us as provided below. Additionally, if you are unable to access this Policy due to a disability or any physical or mental impairment, please contact us and we will arrange to supply you with the information you need in an alternative format that you can access.


Mailing Address:
45 Fremont Street, 8th Floor
San Francisco, CA 94105
Attention: Legal

Supplemental notice for EU or UK individuals

Who this notice applies to. This supplemental notice supplements the information above in our Policy, and except as provided herein, applies solely if you are based in the European Union (EU) or United Kingdom (UK),

Who is the controller of your information. The primary data controller in relation to your information will typically be the Sentry entity to which you are applying, although other Sentry group companies may access and process your information for the purposes set out in this Policy.

There are various legal bases that we can rely on to collect and process your information. We usually only collect and process your information on the following bases:

  • Contract. It is necessary to take steps at your request prior to potentially entering into an employment contract with you, such as to assess your application, check your right to work, and verify the information you provide.
  • Consent. You provide consent for a specific purpose, such as when we obtain a reference or seek to monitor diversity.
  • Legal Obligation. It is necessary to comply with a legal obligation or in connection with a legal claim, such as to comply with our reporting requirements and respond to judicial orders or subpoenas.
  • Legitimate Interests. It satisfies our legitimate interests, such as to evaluate and improve our recruitment processes, which are not overridden by your own interests, rights, and freedoms.

The legal bases depend on the type of information and the purpose for our processing. In some contexts, more than one legal basis applies.

Your privacy rights. You have the right to access your information and you may have a right to have your information rectified or erased, to object to its processing, or to have its processing restricted. If you have provided us with information, you may have the right to be given the personal information in machine readable format for transmitting to another controller. Finally, if we have relied on consent as our legal basis for processing, you may withdraw consent at any time – though if you do so that will not affect the lawfulness of what we have done before you withdraw consent.

Exercising your rights. To exercise your rights, please submit your request via the online form at We will use reasonable efforts to respond to any requests in accordance with applicable law.

Supplemental notice for California residents

Who this notice applies to. This supplemental notice supplements the information above in our Policy, and except as provided herein, applies solely to California residents.

What the CCPA requires us to tell you. If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and disclose your “personal information” and “sensitive personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).

What’s included in our Policy. Throughout our Policy, we describe the specific pieces of personal information and sensitive personal information we collect, the sources of that information, and how we disclose it.

Categories of personal information we collect. Under the CCPA, we are also required to provide you with the “categories” of personal information we collect. Those categories of personal information are as set forth in the table below. We collect and disclose those categories of personal information for the purposes described in our Policy, including for the business or commercial purposes (as those terms are defined in applicable law) set forth in the table below.

Category of Personal InformationBusiness or Commercial Purpose
Identifiers (such as name, address, email address, phone number, social security number, and driver’s license number)
  • Operate our recruitment process
  • Analyze interaction with, or improve, our recruitment process
  • Prevent fraud and enhance security
  • Comply with laws; defend our legal rights
  • Other uses about which we notify you
Geolocation data
Inference data about you
Sensory information (such as audio or video recordings of you)
Professional and employment-related data
Education data about you
Legally protected classifications (such as gender, race, and ethnicity)
Health information
Other information that identifies or can be reasonably associated with you
Sensitive personal information (such as government ID numbers, legally protected classifications, biometric information, and health information)

Our sources of personal information. We collect the categories of personal information identified above from the sources described in our Policy, including from the following sources: (1) directly from you; (2) through your engagement with the recruitment process; (3) affiliates; (4) third parties such as recruiting partners, job websites (if you apply through such websites), referrers (if you are being referred), references that you provide, background check providers (when applicable) and third-party data providers; (5) social media and other content platforms; and (6) public databases.

Aggregation and de-identification. We may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any particular individual.

Our information disclosure practices. We describe our information disclosure practices in our Policy above. We may disclose certain categories of personal information with third parties (as defined by the CCPA) for the business purposes described above. For example, we may disclose identifiers such as name and email address with our background check providers.

Do not sell or share. We do not sell or share (as such terms are defined in the CCPA) your personal information to third parties.

Your rights under California law. If you are a California resident, you may have certain rights. California law may permit you to request that we:

  • Provide you the categories of personal information we have collected or disclosed about you; the categories of sources of such information; the business or commercial purpose for collecting, “selling,” or “sharing” your personal information; the categories of third parties to whom we disclose or “sell,” or with whom we “share,” personal information; and the categories of personal information we “sell.”
  • Provide access to and/or a copy of certain information we hold about you.
  • Delete certain information we have about you.
  • Correct inaccurate personal information that we maintain about you.

You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law.

How to exercise your rights. If you would like to exercise any of these rights, you can submit a request at You will be required to verify your identity before we fulfill your request. To do so, you will need to provide information to match with our existing records to verify your identity depending on the nature of the request and the sensitivity of the information sought (e.g., provide your email address and verify your ability to access that email address). You can also designate an authorized agent to make a request on your behalf. However, we may require you to provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You may still need to verify your identity directly with us.

Sensitive personal information. The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA) if your sensitive personal information is used for certain purposes. Please note that we do not use or disclose sensitive personal information other than for purposes for which you cannot opt out under the CCPA.

Data retention. Please see the “Data retention” section of our Policy above for information about our data retention practices.

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of Functional Software, Inc.