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GDPR JOB CANDIDATE PRIVACY NOTICE

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Footprint International Holdco, Inc. having its registered address at 250 E. Germann Rd., Gilbert, Arizona 85297 or its affiliate or subsidiary being your employer or contracting party (the “Company”, “Footprint”, “we”, “our” or “us”) takes your data protection rights and our legal obligations seriously. The information that you provide to us in the course of your application for employment with us as well as other information that relates to you or other identified or identifiable individuals (“Personal Data”) will be treated in a secure and confidential manner as set out in this Privacy Notice (“Notice”).

The Company is the controller of your Personal Data, determining why Personal Data is processed, and how it is processed. In addition, where processing of Personal Data is undertaken by affiliates of the Company for their own independent purposes, these affiliates may be controllers or joint controllers of your Personal Data and a separate privacy notice will be provided to you.

Throughout this Notice we use the term “processing” to refer to all activities involving your Personal Data, including collecting, handling, storing, sharing, accessing, using, transferring, erasing and disposing of Personal Data.

 

This Notice is provided to you in compliance with data protection laws. This Notice does not constitute or form part of any contract nor is it an offer to contract. This Notice does not confer any contractual right on you, or place any contractual obligation on us.

 

1. Personal Data

We may collect various types of Personal Data about you for the purposes described in this Notice, including:

  • Data about you: forename and surname, nationality, , date of birth, age, home contact details (e.g., address, telephone number, e-mail), national ID number, immigration Data about your employment history and qualifications: education, qualifications, references

  • Data about your application: CV and application, interview data

 

You may give us the Personal Data described above during the recruitment process, whether through your application, further communications, on the telephone or during interviews.

We may also receive (where this is relevant and to the extent permitted by applicable law) Personal Data about you from third parties: recruiters; references from a previous employer; business partners; sub-contractors providing recruiting or technical services; analytics providers; background check providers; search information providers, as well as from publicly available sources such as social media where such Personal Data is proportionate to the position for which you are applying. We may also retain that Personal Data after you have been employed (where this is relevant and to the extent permitted by applicable law).

We may also receive information (which may include your Personal Data) from our hiring manager, from our Human Resources staff, and, from time to time, from our other employees (for instance, in the course of conducting an interview).

 

2. Why We Process Your Personal Data; Legal Bases

The Personal Data requested from you during the recruitment process is required by us in order to assess your application for employment with the Company. If you do not provide some or all of this Personal Data it may affect our ability to process your application and therefore to enter into an employment agreement with you. In some cases, it may mean that we are unable to continue with your application for employment as the Company will not have the Personal Data we believe to be necessary for the effective and efficient management of the recruitment process.

 

We collect the Personal Data described in Section 1 above for the purposes of managing the Company’s recruitment related activities, namely: verification of qualifications; the evaluation and selection of candidates; setting up and conducting interviews and tests (where this is relevant and to the extent permitted by applicable law) and conducting evaluations, assessments and otherwise as needed in the recruitment process, including if relevant, issuing employment offers.

We process your Personal Data for the purposes described above on the following legal bases:

  • the processing is necessary for compliance with an EEA or UK legal obligation to which the Company is subject (purposes of processing: complying with obligations regarding non-discrimination); or

  • the processing is necessary in order to take steps at your request prior to entering into an employment contract with you (purposes of processing: communicating with you about your application, and verifying your academic, work and other qualifications); or

  • the processing is necessary for the legitimate interests pursued by the Company in hiring qualified and appropriate persons (purposes of processing: setting up and conducting interviews and tests; conducting evaluations and assessments; evaluating and selecting candidates for further consideration or to issue an employment offer), except if in light of particular circumstances our interests are overridden by your interests or fundamental rights and freedoms that require protection of Personal Data; or

  • the processing is conducted with your consent (if you consent to allow us to retain your application so that we can consider you for future job positions or verifying references).

 

3. With Whom Do We Share Your Personal Data?

As part of a multinational with affiliates in several countries, the Company may hire for its sites, and use resources, located outside the country where you live. Your Personal Data may be shared with affiliated companies, including Footprint International LLC, Footprint LLC, and Footprint Holdco, Inc. where it is reasonable and necessary to do so, such as to ensure a consistent application of standards for candidate recruitment. Within the Company, your Personal Data can be accessed by or may be disclosed internally on a need-to-know basis to persons responsible for managing or making hiring decisions, Human Resources staff, system administrators and other support teams (such as IT and Finance).

Your Personal Data may also be accessed by third parties who provide us with services relevant to your recruitment, namely recruiters; companies that host, support and/or maintain the IT systems supporting our recruitment system; and companies that verify your references, undertake background checks or conduct vetting on our behalf (where this is relevant and to the extent permitted by applicable law).

If your application for employment with the Company is successful and you accept a job offer from us, your Personal Data may also be shared as described in our employee privacy notice, and notably with Human Resources management, payroll and benefits systems, and the Personal Data contained in such systems may be accessible by providers of those systems, their affiliated companies and sub-contractors; tax authorities; regulatory authorities; and our lawyers, auditors, investors, consultants and other professional advisors.

The Company expects all third parties to process any Personal Data disclosed to them in accordance with applicable law and contract terms, including with respect to Personal Data confidentiality and security. Where these third parties act as a “processor”, they carry out their tasks on our behalf and upon our instructions for the above-mentioned purposes. In this case, your Personal Data will only be disclosed to these parties to the extent necessary to provide the required services.

 

4. Security of Personal Data

We implement what we determine to be reasonable physical, technical and administrative security standards designed to protect your Personal Data from loss, misuse, alteration, destruction or damage.

 

Where we have given you (or where you have chosen) a password that enables you to access certain parts of our recruitment portal, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

 

The transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our recruitment portal; any transmission is at your own risk. Once we have received your Personal Data, we will use strict procedures and security features to try to prevent unauthorized access.

 

5. Where we Process and Store your Personal Data

From time to time your Personal Data will be transferred outside your country for the purposes described in this Notice. For example, your Personal Data may be transferred, among other purposes, to conduct the review of your application, the processing of your details and the provision of support services.

We may share your Personal Data (i) with colleagues within the Company; (ii) with colleagues at Footprint group entities in the United States, which has not received a decision of the European Commission confirming that it provides adequate protection to Personal Data; and (iv) with third parties as described in this Notice.

Transfers outside the EEA or UK may be made pursuant to the European Commission-approved Standard Contractual Clauses, Binding Corporate Rules, because the transfer is necessary to consider your application for employment, or with your explicit consent, or other legally acceptable mechanisms that ensure an adequate level of protection. Where applicable, you are entitled, upon request sent to your local HR manager or stayconnected@footprintus.com, to receive a copy of the relevant contract (such as Standard Contractual Clauses or Binding Corporate Rules) showing that appropriate safeguards have been taken to protect your Personal Data in connection with such transfer.

 

6. Retention of your Personal Data

With your consent, we will retain candidate Personal Data for a period of six months following the closure of the recruitment process relating to the role for which you applied in the event other job opportunities arise within the Company or an affiliate. In all cases, we will retain your Personal Data for a period of time corresponding to the applicable statute of limitations for any kind of claims that we may bring or that may be raised against us, or legal or regulatory obligations.

 

7. Your Rights

Subject to conditions set forth in applicable data protection legislation, you have the following rights:

  • Right to Access - You have the right to request access to any Personal Data concerning you, subject to limited exceptions that may be prescribed by applicable law.

  • Right to Correct (Rectification) - The Company aims to ensure that all of your Personal Data is correct. You are entitled to have any inadequate, incomplete or incorrect Personal Data corrected (that is, rectified).

  • Right to Withdraw Consent - In the event your Personal Data is processed on the basis of your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

  • Right to Data Portability - Where we rely upon your consent as the legal basis for processing, or the fact that the processing is necessary to perform a contract to which you are party or to take steps at your request prior to entering a contract, and the Personal Data is processed by automated means, you have the right to receive all such Personal Data which you have provided to us in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.

  • Right to Erasure - You are entitled to have your Personal Data erased under specific circumstances, such as where you have withdrawn your consent, where you object to processing based on legitimate interests and we have no overriding legitimate grounds or where Personal Data is unlawfully processed.

  • Right to Restriction of Processing - You have the right to restrict our processing of your Personal Data (that is, allow only its storage) where:

    • you contest the accuracy of the Personal Data, until we have taken sufficient steps to correct or verify its accuracy;

    • where the processing is unlawful but you do not want us to erase the Personal Data;

    • where we no longer need your Personal Data for the purposes of the processing, but you require such Personal Data for the establishment, exercise or defense of legal claims; or

    • where you have objected to processing justified on legitimate interest grounds (see below), pending verification as to whether we have compelling legitimate grounds to continue processing.

 

Where your Personal Data is subject to restriction we will only process it with your consent or for the establishment, exercise or defense of legal claims.

 

 

Right to object to processing justified on legitimate interest grounds - where we are relying upon legitimate interest to process Personal Data, you have the right to object to that processing based on grounds related to your particular situation. If you object, we must stop that processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or we need to process the Personal Data for the establishment, exercise or defense of legal claims. Where we rely upon legitimate interest as a basis for processing, we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.

 

 

·       Right to lodge a complaint - You may lodge a complaint with the supervisory authority of your habitual residence, place of work or place of alleged infringement.

 

8. How to Contact Us; How to Exercise Your Rights

To obtain further information regarding your rights, to exercise any of your rights (other than to lodge a complaint), or to ask any questions regarding the processing of your Personal Data, please contact your local HR manager or stayconnected@footprintus.com. To lodge a complaint, please contact the Data Protection Supervisory Authority - the President of the Office for Personal Data Protection, ul. Stawki 2, 00-193 Warsaw.

 

9. Changes to this Notice

Any changes or updates we may make to this Notice will be posted on the privacy page in advance. If we still have your email on file, as described in Section 6 above, we will notify you in advance by email of any changes to this Notice that are material or may impact you. For other changes, please check back frequently to see any updates or changes to this Notice.