Candidate Privacy Policy
Last updated: 12 August 2026
Light Robotics respects the privacy and personal data of candidates. In principle, the Light Robotics group company responsible for recruiting or hiring for the position to which you apply will act as the data controller of the relevant personal data. This may include, without limitation, Shenzhen Light Robotics Co., Ltd. and LIGHT ROBOTICS PTE. LTD. (collectively, "Light Robotics", "we", "us" or "our"). Where more than one group company participates in the recruitment process, each company will assume the data protection responsibilities corresponding to its actual role in that process.
This Policy explains how we collect, store, use, disclose and otherwise process candidates' personal data during the application and recruitment process, and how you may exercise your rights.
This Policy applies when you apply for a position with a Light Robotics group company or participate in a related recruitment process through our careers website, a recruitment agency or executive search firm, an employee referral, campus recruitment, an offline event, email or any other channel.
We use recruitment products operated by Beijing Sirius Technology Co., Ltd. and its affiliates ("Moka") as our recruitment management system. Where Moka processes candidate personal data on our instructions, it generally acts as our processor and provides CV collection, candidate management, interview scheduling, talent pool management, system security and other enabled recruitment management functions.
When you access or use a recruitment page or related service powered by Moka, Moka may independently determine the purposes and means of certain processing activities in connection with account administration, platform security, cookie management or other functions that it provides independently. Moka's own Policy apply additionally to such independent processing. This Policy applies to processing carried out by us as the recruiting organization, while Moka's Policy apply to processing independently carried out by Moka. If there is any inconsistency between them, the applicable notice should be determined by reference to the specific processing activity and the entity responsible for that activity.
1. How We Collect Your Personal Data
We may collect your personal data from the following sources:
Directly from you, for example when you complete an application form, upload a CV or portfolio, participate in an assessment or interview, communicate with our recruitment personnel, accept an offer or submit pre-employment documentation;
From Moka and other systems or services engaged to support recruitment, including information submitted through recruitment pages, activity records, interview arrangements and information generated through enabled functions;
From third parties, such as recruitment agencies, executive search firms, talent sourcing providers, employee referrers, referees designated by you, former employers, educational or credential verification institutions, background screening providers and assessment providers; and
From information that you have made public or that is otherwise lawfully available to the public, such as professional networking platforms, public portfolios, industry websites or published materials, provided that we will only process such information where it is relevant and reasonably necessary for recruitment.
If you provide us with personal data relating to a referee, emergency contact or any other individual, you should ensure that you are authorized to provide such data, have obtained any authorization or consent required under applicable law, and have informed the relevant individual that we will process their personal data for recruitment-related purposes in accordance with this Policy.
2. Personal Data We Process and Why
The personal data we actually process will depend on the position for which you apply, the relevant stage of the recruitment process, your location, the functions you choose to use and the requirements of applicable law.
| Purpose | Personal data that may be processed |
|---|---|
| Receiving and administering applications | Name, preferred name, photograph, contact details, location, position applied for, application source, availability, notice period, cover letter, CV, portfolio, career preferences, visa or sponsorship requirements, and communications with recruitment personnel. |
| Assessment, screening and interviews | Educational background, employment and internship history, project experience, professional skills, qualifications, language proficiency, research or publications, work samples or code, assessment results, interview content, interviewer notes and evaluations, current and expected compensation, and other information provided during the recruitment process. |
| Identity, eligibility and background checks | To the extent permitted by applicable law and relevant to the position, identity card or passport information, date of birth, nationality, work authorization or visa information, educational and employment history, professional qualifications, referee feedback, conflicts-of-interest information, and background screening results obtained after any required notice and authorization. |
| Offers, contracting and pre-employment arrangements | Hiring decisions and feedback, contracts and signature records, residential or correspondence address, emergency contacts, pre-employment medical examination conclusions or fitness-for-work information, and reasonable accommodation requirements. For prospective hires, this may also include tax, social insurance, housing provident fund and bank account information required for onboarding. |
| Talent pools and future opportunities | Basic identity and contact details, CV, career preferences, assessment results and communications. We generally do not retain unnecessary identity documents or other sensitive personal data for talent pool purposes. |
| Diversity, equality and inclusion analysis | Where permitted by law, relevant to recruitment management and generally provided voluntarily, gender, age range, disability or accommodation requirements, nationality, race or ethnicity. Such data will generally be used for aggregated analysis and will not be used to make adverse decisions about you. |
| AI-assisted or automated functions | We may use artificial intelligence to support CV parsing, candidate search and matching, duplicate CV detection, interview scheduling, interview transcription or summarization, evaluation or question suggestions, and recruitment analytics. AI outputs may be inaccurate or biased. Authorized recruitment personnel will be required to conduct a human review based on the requirements of the position and the complete application materials. We will not make a final hiring decision solely on the basis of AI output. |
| Recruitment analytics and improvement | Application source, position, recruitment stage, process duration, feedback, use of pages and functions, and other recruitment metrics. Where practicable, we will use aggregated, de-identified or anonymized data. |
| Compliance, audits, disputes and business changes | We may process the above data to the extent necessary to comply with legal obligations, enforce internal policies, identify conflicts of interest, investigate misconduct or security incidents, establish or defend legal claims, cooperate with regulatory authorities, or support a merger, financing, restructuring or asset transaction. |
You may choose whether to provide personal data. However, where certain data is necessary to assess your application, contact you, verify your eligibility, make an offer or comply with legal obligations, a refusal to provide that data may prevent us from continuing with your application or providing relevant recruitment functions.
The recruitment process may involve personal data that constitutes sensitive personal data under applicable law, such as identity documents, financial account information, health data, data concerning specific identities, background screening information and personal data relating to children under the age of 14. We will process such data only for a specific purpose and where strictly necessary, apply enhanced safeguards, and explain the necessity of the processing and its potential impact on your rights and interests as required by applicable law.
Where required by applicable law, we will obtain your separate consent before processing sensitive personal data. A refusal to provide sensitive personal data that is not necessary will not affect your application. However, where such data is strictly necessary to verify eligibility for a particular position, comply with legal obligations or complete onboarding procedures, a refusal to provide it may prevent us from completing the relevant process.
3. Lawful Bases for Processing
For candidates in China, we will process your personal data where one or more of the following statutory grounds apply:
We have obtained your consent;
The processing is necessary to enter into or perform a contract to which you are a party, or is necessary for human resources management in accordance with employment policies lawfully adopted or collective agreements lawfully concluded;
The processing is necessary for us to perform statutory duties or comply with legal obligations, such as providing personal data to social insurance authorities for the payment of social insurance contributions;
The processing is necessary to respond to a public health emergency or, in an emergency, to protect the life, health or property of a natural person;
The processing is carried out within a reasonable scope for news reporting, public supervision or other activities conducted in the public interest;
The processing concerns personal data that you have made public or that has otherwise been lawfully made public, and is carried out within a reasonable scope in accordance with law; or
Another ground prescribed by applicable laws or administrative regulations applies.
For candidates outside China, we may process your personal data on one or more of the following lawful bases, as permitted by applicable law:
The processing is necessary to enter into an employment contract or to take steps at your request before entering into an employment contract;
The processing is necessary to comply with legal obligations relating to employment, social insurance, occupational health and safety or other matters;
You have provided consent where consent is required or permitted under applicable law;
The processing is necessary for our legitimate interests, such as assessing your suitability for current or future positions, administering and improving recruitment, protecting the security of recruitment systems and managing potential disputes, provided that those interests are not overridden by your interests, fundamental rights or freedoms;
The processing is necessary to protect your vital interests or those of another individual; or
Another lawful basis available under applicable law applies.
4. How We Share, Disclose and Transfer Personal Data
4.1 Sharing of Personal Data. We will disclose your personal data to third parties only for lawful, legitimate and necessary purposes and in accordance with the principle of data minimization. This may include:
Disclosing personal data as required by applicable laws and regulations, for litigation or dispute resolution, or in response to a lawful request from an administrative authority, court, law enforcement agency or other competent authority;
Sharing personal data, to the extent necessary, with Light Robotics affiliates participating in the relevant recruitment process for job matching, candidate assessment, hiring approval or group recruitment management. Such affiliates will apply appropriate safeguards in accordance with this Policy and applicable law; and
Sharing personal data with other third parties where we have obtained your separate consent or where otherwise permitted by applicable law.
Where required by applicable law, we will separately inform you of the recipient's name, contact details, purposes and means of processing, and the categories of personal data involved, and obtain your separate consent.
4.2 Processors and Service Providers. To support our recruitment activities, we may engage the following third-party service providers to process personal data on our behalf:
Moka and other recruitment management, recruitment and pre-employment screening providers;
Background screening, assessment, credential verification or medical examination providers;
Recruitment event organizers and travel service providers;
Equipment, system, cloud service and other information technology providers; and
Auditors, accountants, lawyers and other professional advisers.
We will enter into appropriate arrangements with our processors governing the purposes, duration and means of processing, the categories of personal data, security measures, and the respective rights and obligations of the parties. We will also supervise their processing activities. Processors may process personal data only on our documented instructions and within the agreed scope, and may not appoint a sub-processor without our authorization.
4.3 Transfers in Connection with Business Changes. If personal data is transferred as a result of a merger, demerger, dissolution, bankruptcy or other business change, we will inform you, as required by applicable law, of the recipient's name and contact details and require the recipient to continue to comply with the obligations applicable to a data controller. If the recipient changes the original purposes or means of processing, it will be required to obtain your consent again where required by law.
4.4 Public Disclosure. We do not publicly disclose your personal data unless otherwise permitted or required by law. Where public disclosure is necessary, we will provide a separate notice and obtain your separate consent as required by applicable law.
5. How Long We Retain Your Personal Data and How We Protect It
5.1 How Long We Retain Your Personal Data
We retain your personal data only for the minimum period necessary to fulfil the purposes described in this Policy. When determining the applicable retention period, we consider the duration of the recruitment process, whether you have agreed to join a talent pool, applicable statutory retention requirements, limitation periods, dispute management, audit requirements and information security needs.
After recruitment and pre-employment screening activities have been completed, if you have agreed to join a talent pool, we may continue to retain the personal data necessary to consider you for future opportunities for the period notified to you. Data subject to statutory retention requirements will be retained for the period required by applicable law. Specific retention periods may vary between countries and regions.
At the end of the applicable retention period, we will delete or anonymize the relevant personal data. Where immediate deletion is technically impracticable, we will cease all processing other than storage and the application of necessary security safeguards.
5.2 How We Protect Your Personal Data
We employ industry-recognized security technologies and administrative measures to protect your personal data from unauthorized access, use, disclosure, alteration, or destruction. We implement strict access control mechanisms and apply tiered access management based on the principle of minimum necessity, ensuring that only authorized personnel with a legitimate business need may access relevant personal data.
6. International Transfers of Personal Data
The personal data we collect is primarily stored in the United States of America and Europe. As Light Robotics operates globally, we may transfer your personal data to Light Robotics group companies or service providers located outside your country or region, or permit authorized personnel located overseas to access your personal data remotely, for purposes including group recruitment collaboration, candidate assessment, hiring approval, system support, audits and compliance management.
We will conduct a personal data protection impact assessment where required and implement applicable cross-border transfer mechanisms, such as entering into the Standard Contract Clauses or completing other applicable regulatory procedures. We will also implement appropriate contractual, technical and organizational measures to protect personal data transferred across borders.
Where required by applicable law, we will separately inform you of the overseas recipient's name, contact details, purposes and means of processing, the categories of personal data transferred, and the procedures through which you may exercise your rights against the overseas recipient. We will also obtain your separate consent where required.
7. Your Data Protection Rights
The specific rights available to you depend on the lawful basis on which we process your personal data and the laws applicable in your country or region. Subject to applicable conditions and exceptions, you may have the right to:
Access and obtain a copy of your personal data;
Request correction or completion of inaccurate or incomplete personal data;
Obtain information about how we process your personal data and request an explanation of our processing rules;
Request deletion of your personal data;
Request restriction of the processing of your personal data;
Object to the processing of your personal data;
Where the applicable legal conditions are satisfied, request that your personal data be transferred to another data controller designated by you, or receive the relevant data in a structured, commonly used and machine-readable format;
Withdraw any consent that you have previously provided; and
Lodge a complaint with us or with a competent data protection or privacy authority.
You may submit a request through the contact details set out in Section 9 of this Policy.
If you object to our processing of your personal data or withdraw your consent, we will handle your request in accordance with applicable law. However, this may prevent us from continuing certain recruitment or pre-employment screening activities described in Section 2 of this Policy.
For candidates in China, where we process personal data on a statutory ground other than consent, the withdrawal of consent will not affect our continued processing to the extent that the relevant statutory ground applies. The withdrawal of consent will also not affect the lawfulness of processing carried out on the basis of your consent before its withdrawal.
8. Changes to This Policy
We may update this Policy from time to time to reflect changes in applicable laws or regulatory requirements, recruitment processes, system functions, service providers, industry practices or business arrangements.
The updated Policy will be published on the relevant recruitment page and will state the date on which it was last updated. If an update may materially affect your rights or our processing activities, we will provide additional notice through an appropriate channel and obtain your consent again where required by applicable law.
9. Contact Us
If you have any questions, comments, complaints or suggestions regarding this Policy, believe that your personal data may have been compromised, or wish to exercise any of your data protection rights, please contact us at privacy@lightorigins.com.
We will review and respond to your question or request in a timely manner. To protect your personal data and that of others, we may need to verify your identity before processing your request. We will respond within the period prescribed by applicable law. For example, we will generally respond and provide a reasonable explanation within 15 working days after receiving your request and completing any necessary identity verification, unless otherwise required by applicable law.