Candidate Privacy Statement

The Company generally collects the following categories of personal information in the course of the recruiting and hiring process:

• Your name, street address and contact details, including email address and telephone, educational background, employment history, job interest, and voluntary demographic information provided by you.
• Details of your qualifications, skills, experience and employment history.
• Information about your current level of remuneration, including benefit entitlements.
• Whether or not you have a disability for which the organization needs to make reasonable adjustments during the recruitment process.
• Data you submit in résumés / CVs, letters, writing samples, or other written materials necessary for evaluation of employment.
• Data generated by interviewers and recruiters based on interactions with you.
• Other information otherwise related to your application for employment at the Company.

We prefer that you do not send the following sensitive personal information, except when such information is required by law: sexual orientation, race, ethnic origin and religious beliefs.

When you provide us with information about a reference or other third party as part of your application or submission, it is your sole responsibility to obtain the consent of that third party before you provide this information to us.

You are not required to provide any information to the Company, but failing to do so may result in our inability to process your application properly, or at all.

When you apply for a position at the Company, we will need to collect and process personal information about you necessary for the recruiting and hiring process. Your personal information will be utilized by the Company for the purpose of:

• Assessing your qualifications for employment for the role for which you are applying;
• Assessing your suitability for employment for future roles that may become available;
• Performing recruitment related administrative functions;
• Communication with you about your job application;
• Performing background checks when you are offered a job; and
• Performing analysis of our applicant pool based on the recruiting information you provide to better understand who is applying to positions at the Company and to attract top talent.

The Company will be the data controller of your personal information.  The Company processes your personal information only when the processing is necessary for:

• Compliance with a legal obligation;
• Performance of a contract to which you are a party or in order to take steps at your request prior to entering into such a contract; and/or
• The legitimate interests pursued by the Company, specifically, the recruitment of suitable personnel and the effective administration and management of staff.

The Company collects and records the personal information that you submit through the Careers Site, directly to our personnel in written form (in paper or electronically), or through verbal information provided in interviews or otherwise, which may be recorded electronically or manually.

In addition, further information about you will come from other forms of assessments, such as public social profile and aptitude tests. The Company also obtains certain information from third parties, such as references supplied by former employers and/or recruiting agencies.

The Company uses iCIMS, Inc.’s (“iCIMS”) Recruiting Platform to process the recruiting and hiring information as provided by you. iCIMS is a third party sevice provider that hosts and maintains the database that contains applications submitted through the Company’s Careers Site.

The Company may transmit or share your personal information with its subsidiaries, and its affiliates for the above listed purposes. The Company’s subsidiaries, affiliates and third-party agents are only given access to (or are allowed to collect on Company’s behalf) the information they need in relation to the above purposes. They have no independent rights to your personal information, and they have agreed to protect the confidentiality and security of this information.

The Company may also share personal information about you with selected service providers or consultants acting on our behalf, such as recruitment agencies or third parties who carry out reference and background checks on behalf of the Company. The Company will take reasonable steps to ensure that those third parties take appropriate measures to protect the confidentiality and security of personal information.

Your personal information may also be shared with a competent public authority, government, regulatory or fiscal agency where it is necessary to comply with a legal or regulatory obligation to which the Company is subject to or as permitted by applicable local law.

As the Company is a global business, any personal information may need to be transferred between locations around the world. The Company may process your personal information in the United States or in such other location(s) as the Company reasonably deems appropriate and the Company may move that information from one place to another, including, but not limited to, into or, out of, places in which the law regarding personal information that applies in your current or home jurisdiction do not apply. In these circumstances, appropriate measures will be put in place to ensure the protection of candidate’s personal information and, where required, the necessary authorizations for the transfers will be obtained from the relevant authorities in compliance with applicable law.

We take the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.

The Company stores your personal information gathered in the course of the recruitment process in the iCIMS Recruitment Platform.  iCIMS is also committed to protection of your personal information. The privacy statements and the security policies of iCIMS, Inc. can be found at https://www.icims.com/gc/Talent-Platform-Security-Policy. Contact iCIMS, directly if you have any questions or concerns regarding the privacy, security, or other policies and practices of iCIMS, Inc.

The Company will hold your personal information for no longer than three (3) years after the recruitment process or assessment has been completed. When you have indicated in your application that you reside in Germany, your personal information will be held for no longer than 3 months after the recruitment process or assessment has been completed.

In all cases information may be held for a longer period of time where there is a legal or regulatory reason to do so, or a shorter period where you object to the processing of your personal information and there is no longer a legitimate purpose to retain it.

The Company takes reasonable steps to ensure that information you provide to us is maintained in an accurate and complete manner.  We provide you with the ability to examine your personal information as part of the online application process and to make changes by editing, deleting, or appending your personal information you provide on this website.  It is your responsibility to review your information and ensure its accuracy.  In addition, if you wish to make any changes to your personal information you may do so at any time by logging into the Careers Site.

When you submit a job application to the Company, you signify your understanding and agreement to all of the following terms:  (1) the application is not an offer of employment and by accepting your application, the Company does not guarantee that you will be offered a job; (2) misrepresentation or omission of material information from your application and/or resume submitted to the Company may result in rejection of your application; (3) your personal information will be included and processed in the iCIMS Recruitment Platform, which is a database hosted and maintained by a third party service provider; (4) your personal information will be transferred to countries outside the country where you reside; and (5) your personal information will be disclosed to the Company’s subsidiaries, affiliates and third party services providers as required in the course of the recruitment process.

If you reside in the European Economic Area, under the General Data Protection Regulations (GDPR) you have certain rights when it comes to the personal information you submit for recruitment purposes to iCIMS. These rights include: (1) The right to be informed; (2) the right to access your information; (3) the right to correct any information that is inaccurate; (4) the right to withdraw your consent; (5) the right to have your information erased; (6) the right to restrict or suppress information; (7) the right to portability of your personal information; (8) the right to object to the processing of your personal information; (9) the right to object to how your data is used in automated decision making; and (10) the right to lodge a complaint with the supervisory authority.

If you would like to exercise any of these rights, please contact:  [email protected] or select the relevant button on the Data Subject Requests Page available on the Careers Site when you are logged into your account.

Please note that in accordance with the GDPR, certain exemptions may apply to the exercise of the right to access, the right of correction and the right of objection. In the event consent is withdrawn, this will not affect the validity of the processing prior to the withdrawal of consent.

We hope this policy answers your questions about our collection, use and disclosure of your personal information. If you have additional questions about this Candidate Privacy Statement or the practices described herein, you may contact us at [email protected].

The Company reserves the right to update and make material changes to this Candidate Privacy Statement and to its practices in handling personal information to the extent permitted by applicable law.  Any changes to this Candidate Privacy Statement will become effective upon the posting of the updated Candidate Privacy Statement on the Careers Site. You can determine when the Candidate Privacy Statement has been updated by referring to the “Last Updated” legend on the top of this Statement. By continuing to use the Careers Site or submitting any information in writing or electronically following a change or update to the Candidate Privacy Statement, you will be deemed to have agreed to all such changes.