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Information for individuals who apply to work for, or who attend a recruitment event or undertake an assessment with ThinkOnward.
ThinkOnward is part of the Shell group of companies. As such, this Privacy Policy aligns with the standards and practices adopted across Shell entities and reflects our commitment to safeguarding personal data in accordance with applicable laws and Shell’s global privacy principles. This notice sets out what personal information we collect, for what purposes and your rights in this respect.
What does this Recruitment Policy cover?
This Privacy Notice provides information about personal information which is processed by ThinkOnward in relation to individuals who apply to work for, or who attend a recruitment event or undertake an assessment with ThinkOnward. This includes prospective employees, interns and contractors. It outlines our use of Greenhouse Software, Inc. (“Greenhouse”) as our applicant tracking system (ATS) and describes how candidate information is collected, stored, and protected.
This Privacy Notice explains what personal information we process about you, why we are processing your personal information and for which purposes, how long we hold your personal information for, how to access and update your personal information, as well as the options you have regarding your personal information and where to go for further information.
For individuals who are successful in their application for employment, internship or engagement as a contractor, the Privacy Notice - ThinkOnward Employee, Contractor and Dependents’ available at https://www.thinkonward.com/employment-privacy-notice will apply.
As well as this Privacy Notice, bespoke privacy notices and supplementary privacy statements may contain further information about how ThinkOnward is processing your personal information. In those instances, such privacy notices will be communicated to you separately.
Notices are also available from the ThinkOnward websites in the various locations in which we operate, in local languages and to reflect local requirements as appropriate.
Who is responsible for any personal information collected?
ThinkOnward LLC will be responsible for processing your personal data, either solely or jointly with its affiliates within the Shell group of companies or the relevant employing or engaging company within ThinkOnward.
ThinkOnward does not knowingly sell or share your personal information for cross-context behavioral advertising and/or for targeted advertising purposes.
Special Notice: if you are under 13 years old. Processing children’s personal data. ThinkOnward does not intentionally collect personal information of individuals under 13 years old. If you are under 13 years old, please do not send us your personal information for example, your name, address and email address. If you wish to contact ThinkOnward in a way which requires you to submit your personal information please get your parent or guardian to do so on your behalf.
Use of Greenhouse Recruiting Platform
ThinkOnward uses Greenhouse as its primary platform for managing job postings, candidate applications, and interview scheduling. Greenhouse is a third-party application that enables us to:
Collect candidate information (e.g., name, contact details, resume, work history, education).
Schedule and manage interviews.
Track candidate progress through the recruitment pipeline.
Greenhouse is used exclusively for recruitment purposes and does not provide login access to external candidates.
What categories of personal information do we process about you?
Through Greenhouse, ThinkOnward processes personal information relating to individuals who apply to work for, or who attend a recruitment event and/or undertake an assessment (‘Applicants’). This includes:
First and last name
Email address
Phone number
Home address
Resume and cover letter
Employment and education history
This data is used to evaluate candidate qualifications, communicate with applicants, and make hiring decisions.
Sensitive personal information
For the purposes of recruitment, personal information regarding health data may be processed only as strictly required and as permitted or required by local law for the purposes of making adjustments to the recruitment process, for assessing eligibility for positions and fitness to work and provision of facilities in the workplace to accommodate health problems.
In addition, we gather personal information where it is necessary for the purposes of complying with employment and social security laws including those specifically for the purposes of ensuring equal employment opportunities as required by US law, covering applicant and employee information such as gender, race/ethnicity, nationality, disability and veterans status.
For what purposes do we process your personal information?
We process your personal information for the following purposes:
Human Resources, personnel management, business process execution and internal management - including resource planning, and recruitment;
Health, safety and security - including protection of an individual’s life or health, occupational health and safety, protection of ThinkOnward’s assets and staff, authentication of individual status and access rights;
Legal and/or regulatory compliance - including compliance with legal or regulatory requirements; or
Management reporting and analysis - including statistical analysis and surveys regarding the quality of the recruitment process.
We may also process your personal information for a secondary purpose where it is closely related, such as:
storing, deleting or anonymizing your personal information;
fraud prevention, audits, investigations, dispute resolution or insurance purposes, litigation and defense of claims; or
statistical, historical or scientific research.
Pre-screening of Applicants
We carry out screening of all Applicants who we intend to make an offer of employment, engagement or internship (as the case may be) and prior to any offer being confirmed for the purposes of:
verifying the information that an Applicant provides during the screening/interview process. This will include verifying information with current/previous employers and educational institutions. No steps will be taken in this respect until the Applicant confirms the verification can take place;
screening Applicants against publicly available or government issued sanctions lists and media sources. This is to ensure Shell is able to comply with legal and regulatory obligations, to protect assets and employees/contractors of ThinkOnward and also Shell, and specifically to ensure that Shell can comply with trade control, anti-money laundering and/or bribery and corruption laws and other regulatory requirements.
Any personal data collected through the screening will not involve profiling or automated decision making regarding suitability for continued employment, internship or engagement as a contractor.
Automated decision making and profiling
All applicants must answer questions which are necessary to ensure that individuals can lawfully enter into a contract with ThinkOnward if they are successful in their application. ThinkOnward does not engage in automated decision-making processes that produce legal effects or significantly impact candidates, such as automated resume or application screening, performance monitoring, or skills gap analysis. If such processing is ever introduced, candidates will be fully informed and provided with meaningful information about the logic involved, the potential consequences, and their rights in relation to the decision-making process.
Why do we process your personal information?
We only process personal information of Applicants:
in order to take steps at the request of the Applicant prior to entering into a contract;
where it is necessary to comply with a legal obligation to which ThinkOnward is subject to ensure compliance with applicable employment, social security laws and regulations;
where it is necessary for the legitimate business interests of ThinkOnward (such as ensuring compliance with legal obligations other than those related to employment or social security, the protection of ThinkOnward assets, reputation and ThinkOnward employees and contractors) except where such interests are overridden by the interests or fundamental rights and freedoms of the Applicant; or
(only if legally required) with the explicit consent of the Applicant.
In those cases where processing is based on consent you have the right to withdraw your consent at any time. This will not affect the validity of the processing prior to the withdrawal of consent.
Who will we share the personal information with?
Your personal information is exclusively processed for the purposes referred to above and will only be shared on a strict need to know basis with:
Authorized third party agents, service providers, external auditors and/or subcontractors of ThinkOnward in particular authorized third parties who carry out reference and background checks on behalf of ThinkOnward;
Greenhouse, as our ATS provider, for platform functionality and support.
Greenhouse is contractually obligated to maintain confidentiality and comply with applicable data protection laws. For more information, candidates may refer to Greenhouse’s Privacy and Compliance Center.
A competent public authority, government, regulatory or fiscal agency where it is necessary to comply with a legal or regulatory obligation to which ThinkOnward is subject to or as permitted by applicable law; or
Any person to whom ThinkOnward proposes to transfer any of its rights and/or duties.
Interacting with ThinkOnward through social media
If you choose to interact with ThinkOnward through social media on a ThinkOnward administered social media page (‘ThinkOnward Social Media Page’) - such as Facebook, Instagram, Twitter or LinkedIn, your personal information (such as your name, your profile picture and the fact that you are interested in ThinkOnward) will be visible to all visitors of your personal webpage depending on your privacy settings on the relevant social media platform, and will also be visible to ThinkOnward. You can delete any data that you shared on these sites at any time through your relevant social media platform’s account. ThinkOnward does not track your activity across the different social media sites that you use. Please contact ThinkOnward at support@thinkonward.com if you wish to make a request that you are unable to action yourself and which relates to a ThinkOnward Social Media Page.
Additionally and to the extent ThinkOnward is jointly responsible with a social media platform of a ThinkOnward Social Media Page, ThinkOnward will have access through the social media platform to aggregated data providing statistics and insights that help to understand the types of actions you take on ThinkOnward Social Media Pages. For more information on how your personal information are processed on those social media platforms, including any targeted advertising that you may receive, please refer to your privacy settings accessible through your relevant social media platform’s account.
Transfers of your personal data to other countries
Where your personal data have been transferred to companies within the Shell group and/or to authorized third parties located outside of your country we take organizational, contractual and legal measures to ensure that your personal data are exclusively processed for the purposes mentioned above and that adequate levels of protection have been implemented to safeguard your personal data. These measures include Binding Corporate Rules for transfers among the Shell group and for Shell companies in the European Union, European Commission approved transfer mechanisms for transfers to third parties as well as any additional local legal requirements. You can find a copy of Shell Binding Corporate Rules at https://www.shell.com/privacy.html or by contacting privacy-office-SI@shell.com.
Security of your personal information
We have implemented technology and policies with the objective of protecting your privacy from unauthorized access and improper use and will update these measures as new technology becomes available, as appropriate.
How long do you hold my personal information for?
Candidate data submitted through Greenhouse is retained in accordance with ThinkOnward’s internal retention policies:
Candidate records are retained for up to 3 years for audit, compliance, or future consideration purposes.
Information may be held for a longer period of time where there is a legal or regulatory reason to do so (in which case it will be deleted once no longer required for the legal or regulatory purpose).
If you are successful in your application, the personal information gathered through the recruitment process will be retained in line with the Privacy Notice - Employees’, Dependents’ and Contractors’ Personal information, which is available at https://www.thinkonward.com/employment-privacy-notice.
What are the consequences of not providing your data?
Personal information requested and provided by Applicants are required in order to fulfil legal requirements and/or which is required for entering into a contract with you (or in the case of a contractor your employer/service provider). Failure to provide us with the information requested which is limited to that required for these purposes will negatively affect your chances of being selected for any potential employment, engagement or internship.
Your rights in relation to your personal information
We aim to keep our information about you as accurate as possible. Any US resident, regardless of state of residency, can request the following information:
access to your personal information, including access to specific pieces of personal information where local law applies;
correction, or deletion of your personal information (but only where they are no longer required for a legitimate business purpose);
restriction and objection to the processing of your personal information under certain circumstances and where local law applies;
to limit the collection, disclosure or use of your personal information, including sensitive personal information, if collected for unrelated purposes where local law applies;
opt-out from the collection and use and/or to limit the disclosure or use of your personal information, including sensitive personal information if collected and where local law applies;
opt-out from the sale or sharing of your personal information, including for cross-context behavioral advertising or for targeted advertising, if sold or shared and where local law applies;
to no longer receive marketing communications on behalf of the relevant Business Customer, Supplier or Business Partner; and/or
to receive personal information that you have provided to ThinkOnward, in a structured, digital form to be transmitted to another party, if this is technically feasible.
How to exercise your rights
To exercise any of your rights listed above, please contact support@thinkonward.com.
Who can you contact if you have a query, concern, complaint, about your personal information?
If you have any issues, queries or complaints regarding the processing of your personal information please contact support@thinkonward.com.
You may also contact the Shell Group Chief Privacy Officer at Privacy-Office-SI@shell.com or Shell International B.V. The Hague, The Netherlands - Trade Register, No. 27155369 Correspondence: PO Box 162, 2501 AN, The Hague.
Without prejudice to any rights you may have in line with local law you have the right to lodge a complaint with the Dutch Data Protection Authority whose address is Prins Clauslaan 60, 2595 AJ The Hague, The Netherlands. Please visit https://autoriteitpersoonsgegevens.nl/en for more information.
For any technical issue with regards to your recruitment process or in case of questions or comments regarding job opportunities at ThinkOnward please contact us at support@thinkonward.com.
Cookies and similar technologies
ThinkOnward uses cookies and similar technologies that aim to collect and store information when you visit a ThinkOnward website. This is to enable ThinkOnward to identify your internet browser and collect data on your use of our website, which pages you visit, the duration of your visits and identify these when you return so that we improve your experience when visiting our website(s). You can control and manage your cookies preferences by adjusting your browser settings or using the ThinkOnward cookies preference tool on ThinkOnward websites - for more information, please refer to the ThinkOnward Cookie Policy at https://thinkonward.com/cookie-policy.
Changes to this Privacy Notice
We reserve the right to update this Privacy Notice periodically and without notice, for example, when a new category of personal information is collected and used and upon changes/enactment of data protection and privacy laws. You are advised to regularly review this Privacy Notice for possible changes. For significant or material changes to this Privacy Notice, we will prominently post such changes on this page and update the revision date to provide awareness. This Privacy Notice was last updated in September 2025.