Recruitment Privacy Policy and Notice
Last updated: January 29, 2026.
1. About this Notice
1.1 This Recruitment Privacy Notice (“Notice“) explains how we (as defined below) collect, share and use any information that, alone or in combination with other information, relates to individuals (“Personal Data“) who apply for a job on one of our Websites (“Applicants“, “you” and “your“).
1.2 Oregon Tool Inc. and where relevant its affiliates and subsidiaries (“Oregon Tool“, “we” or “us“) has issued this Notice to describe how we handle Personal Data we hold about Applicants. This Notice also sets out the rights that you have in relation to the Personal Data that we process about you and how you can exercise them.
1.3 The Oregon Tool entity you make your application to is primarily responsible for determining the purposes and means of the processing of your Personal Data as a controller.
1.4 For the purposes of this Notice, the “Oregon Tool entity” refers to one of the following companies within the Oregon Tool group, depending on the country in which you apply or are employed:
Oregon Tool, Inc.
Woods Equipment Company
Oregon Tool (Shanghai) Company Ltd.
Oregon Tool (Fuzhou) Company Lotd.
Oregon Tool Europe, S.A.
Oregon Tool Canada Ltd.
KOX Forstversand GmbH
Oregon Tool Industrial Ltda.
Oregon Tool U.K. Limited
Oregon Tool Sweden AB
KOX S.A.R.L.
Oregon Tool Civray
Oregon Tool, Inc. Singapore Branch
Oregon Tool France Branch
1.5 If you are accepted for a role at Oregon Tool, the information collected during the recruitment process will form part of your ongoing staff member record and will be processed in accordance with our Employee Privacy Notice.
1.6 Please take the time to read this Notice carefully. If you have any questions or comments, please contact us via email at [email protected].
2. What Personal Data does Oregon Tool collect and why?
2.1 The types of Personal Data that we may collect about you, and the reasons why we process it, include:
Purposes for which we collect it |
Personal Data we collect |
Legal grounds for processing |
| Management of applications and recruitment. | – Identification data – Electronic identification data – Information included in your CV – Information contained in your cover letter – Information about whether you are legally authorised to work – Interview and selection notes |
Our legitimate interest to carry out recruitment and to manage the hiring process. |
| To put in place necessary arrangements for future employment. | – Identification data – Electronic identification data – Information about whether you are legally authorised to work – National ID – Economic and financial data – Household data |
Contractual necessity Legal obligation as an employer. |
| To evaluate and select job applicant including for example setting up and conducting interviews. | – Identification data – Electronic identification data – Information included in your CV – Information contained in your cover letter – Information about whether you are legally authorised to work – Interview and selection notes |
Our legitimate interest to improve our hiring process. |
| Protect our legal rights (including where necessary, to share information with law enforcement and others), for example to defend claims against us and to conduct litigation to defend our interests. | – Identification data – Electronic identification data – Information included in your CV – Information contained in your cover letter – Information about whether you are legally authorised to work – Interview and selection notes |
Our legitimate interests to protect our business interests. |
2.2 If we ask you to provide any other Personal Data not described above, then the Personal Data we will ask you to provide, and the reasons why we ask you to provide it, will be made clear to you at the point we collect that Personal Data.
3. Who does Oregon Tool share your Personal Data with?
3.1 We may disclose your Personal Data to the following categories of recipients:
(a) to our group companies for purposes consistent with this Notice. We take precautions to allow access to your Personal Data only to those of our employees who have a legitimate business need for access and with a contractual prohibition of using the Personal Data for any other purpose.
(b) to our third party vendors, services providers and partners who provide data processing services to us, or who otherwise process Personal Data for purposes that are described in this Notice or notified to you when we collect your Personal Data. This may include disclosures to third party vendors and other service providers we use in connection with the services they provide to us, including to support us in areas such as managing resume/CV information, IT platform management or support services, infrastructure and application services, and data analytics.
(c) to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
(d) to our auditors, advisors, legal representatives and similar agents in connection with the advisory services they provide to us for legitimate business purposes and under contractual prohibition of using the Personal Data for any other purpose;
(e) to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your Personal Data only for the purposes disclosed in this Notice;
(f) to any other person if you have provided your prior consent to the disclosure.
4. How we protect your privacy
4.1 We will process Personal Data in accordance with the following principles:
(a) Fairness: We will process Personal Data fairly. This means that we are transparent about how we process Personal Data and that we will process it in accordance with applicable law.
(b) Lawfulness: We will process Personal Data only on lawful grounds;
(c) Purpose limitation: We will process Personal Data for specified explicit and legitimate purposes, and will not process it in a manner that is incompatible with those purposes, unless permitted by applicable data protection laws.
(d) Data minimization: We will process Personal Data that is adequate, relevant and limited to what is necessary to achieve the purposes for which the data are processed.
(e) Data accuracy: We take appropriate measures to ensure that the Personal Data that we hold about you is accurate, complete and, where necessary, kept up to date. However, it is also your responsibility to ensure that your Personal Data is kept as accurate, complete and current as possible by informing us promptly of any changes or errors. You should notify us of any changes to the Personal Data that we hold about you (e.g. a change of address).
(f) Data security: We use appropriate technical and organisational measures to protect the Personal Data that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Data.
For further information on the steps that we take to keep Personal Data secure and your responsibilities in this regard, please reach out to [email protected].
(g) Data processors: We may engage third parties to process Personal Data for and on behalf of Oregon Tool. We require such data processors to process Personal Data and act strictly on our instructions and to take appropriate steps to ensure that Personal Data remains protected.
5. Data storage, retention and deletion
5.1 The Personal Data we collect from you is stored in our servers located in the European Union and the US.
5.2 We retain Personal Data we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
5.3 If you are not successful, Oregon Tool will keep your application form on file for future job openings no longer than one year. If you are successful and offered a job at Oregon Tool, your Personal Data will be used to complete your hiring process by our HR department.
5.4 When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymise it or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.
5.5 When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymise it or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.
5.6 For more details about the periods of retention of your Personal Data, please refer to the table above.
6. International transfers of data
6.1 Your Personal Data may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).
6.2 Specifically, our servers are located in the US and the EU, and our group companies and third-party service providers and partners operate around the world. This means that when we collect your Personal Data we may process it in any of these countries.
6.3 However, we have taken appropriate safeguards to require that your Personal Data will remain protected in accordance with this Notice. These include implementing Binding Corporate Rules for transfers of Personal Data between our group companies, which require all group companies to protect Personal Data they process from the EEA in accordance with European Union data protection law. Our Binding Corporate Rules are available here.
6.4 When transferring personal data to our third-party vendors, suppliers, service providers and other third parties located outside the EU/EEA, we rely on the EU’s Standard Contractual Clause. Our Standard Contractual Clauses can be provided on request.
7. Your data protection rights
7.1 You have the following data protection rights:
(a) If you wish to access, correct, update or request deletion of your Personal Data, you can do so at any time by contacting us via email at [email protected].
(b) In addition, in certain circumstances, as stipulated in the applicable data protection legislation, you can object to processing of your Personal Data, ask us to restrict processing of your Personal Data or request portability of your Personal Data. Again, you can exercise these rights by contacting us using the following contact details below.
(c) If we have collected and process your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent]
(d) If you have a complaint or concern about how we are processing your Personal Data then we will endeavour to address such concern(s). If you feel we have not sufficiently addressed your complaint or concern, you have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area are available here.).
(e) If you are located in France, you have the right to define general or specific directives regarding the use and disclosure of your personal information after your death according to the French Data Protection Act.
7.2 We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
8. Updates to this Notice
8.1 We may update this Notice from time to time in response to changing legal, technical or business developments. When we update our Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Notice changes if and where this is required by applicable data protection laws.
You can see when this Notice was last updated by checking the “last updated” date displayed at the top of this Notice.
9. How to contact us
9.1 If you have any questions or concerns about our use of your Personal Data, please contact us via email at [email protected].