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StriVectin Global Applicant Privacy Policy

Last Updated: January 1, 2021

This Global Applicant Privacy Policy (the “Policy”) describes the personal information StriVectin Operating Company, Inc. (“StriVectin,” “we” or “us”) collects, uses, discloses, transfers and stores (collectively, “processes”) in connection with our recruitment activities. While this Policy is intended to describe the broadest range of our processing activities globally, those activities may be more limited in some jurisdictions based on local laws. For example, the laws of a particular country may limit the types of personal information we can collect or the manner in which we use that information. In those instances, we adjust our internal policies and practices to reflect the requirements of local law.

      I.         APPLICABILITY OF OTHER POLICIES

This Policy does not cover our processing of personal information collected from you as a StriVectin customer or a visitor of our websites. To learn more about StriVectin’s data collection practices in these cases, please read our online Privacy Policy.

In some cases, you may provide personal information to third parties that we work with. This could be, for example, a third-party website where you applied for a job at StriVectin. You understand that the information you provide to such third parties is not under our control and is not subject to this Policy. Please contact such third parties for questions regarding their privacy practices.

    II.         INFORMATION WE COLLECT

We collect information in connection with your application to work with us. For example, we may collect:

  • Information you provide on our application forms, including full name, telephone number, personal email address, gender, location, availability, employment history (including whether you have previously worked for StriVectin), qualifications, references, LinkedIn profile and website (if provided voluntarily), work authorization status, and how you heard about the job;
  • Information you provide to us in your resumé, cover letter and any other files you choose to upload or share with us regarding your qualifications, such as design portfolios;
  • Information you provide to us during an interview or that we collect through the recruitment process (e.g. work authorization status, willingness to relocate, current salary, type of employment contract, interview notes, results of any assessment);
  • Reference information and/or information received from background checks if you are offered a job (where applicable), including information provided by third parties such as past employers, educational institutions and references;
  • Information about your educational and professional background from publicly available sources, including online, that we believe is relevant to your application (e.g. your LinkedIn profile); and
  • Inferences drawn to create a profile about an applicant reflecting the applicant’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Your decision to apply for a position and provide your personal information to us is voluntary. We will tell you if information is required to move forward with your application.

Sensitive Information: In certain countries, where permitted by law and on a voluntary basis, we may ask questions about race or ethnicity, veteran status and disabilities for specific purposes, such as to accommodate a disability or illness and to comply with legal obligations relating to diversity and anti-discrimination. You are entirely free to decide whether or not to provide such information and your application will not be affected either way. Except as specifically requested, we ask that you avoid submitting information which may qualify as sensitive information under applicable law, including race, religion, ethnicity, nationality, age, gender identity, sexual life or sexual orientation, medical or health information, genetic or biometric data, political opinions, political party or trade union membership and judicial data such as criminal records.

Information About Others: If you provide us with personal information of a reference or any other individual as part of your application, it is your responsibility to obtain consent from that individual prior to providing such information to us.

   III.         HOW WE COLLECT YOUR INFORMATION

Most of the personal information we process is obtained directly from you, such as when you submit a job application or when we conduct a phone or in-person interview. We may also receive information about you from other sources, such as from your named references, persons who referred you for a position, from background checks (if applicable), recruiting agencies, third party recruitment sources and websites and publicly available sources such as your LinkedIn profile.

When you visit our sites, including our Career Opportunities webpage, we collect certain information automatically. To collect this information, we may use cookies, web beacons, and similar technologies. A “cookie” is a text file that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as a pixel tag or clear GIF, is used to transmit information back to a web server. We may also collect information about your online activities over time and across third-party websites. The information we collect automatically may include:

  • URLs that refer visitors to our websites;
  • Search terms used to reach our websites;
  • Details about the devices that are used to access our websites (such as IP address, browser information, device information, and operating system information);
  • Details about your interaction with our websites (such as the date, time, length of stay, and specific pages accessed during your visits to our websites, and which emails you may have opened); and
  • Usage information (such as the number and frequency of visitors to our websites).

We may associate this information with your StriVectin account if you have one, the device you use to connect to our Services, or email or social media accounts that you use to engage with StriVectin.

For more information about how we use cookies please read our online Privacy Policy.

   IV.         HOW WE USE YOUR INFORMATION

We use your personal information to evaluate a potential employment relationship with you and for other business purposes. Such uses include:

  • Assessment of your skills, qualifications, and suitability for the role;
  • Communication with you about the recruitment process;
  • Verification of your information and completion of reference and/or background checks (where applicable) if we offer you a position;
  • Retention of records related to our hiring processes, including a record of the name of unsuccessful applicants, the date of their application and the reason that their application was not successful, in order to streamline future hiring processes;
  • Legal and compliance purposes, such as responding to suspected fraud, security incidents, or other activity which is illegal or violates StriVectin’s policies, protecting StriVectin’s and others’ rights and property, exercising a legal claim, cooperating with law enforcement investigations and complying with applicable laws, regulations, legal processes or governmental requests;
  • Other uses with your consent, which you may withdraw at any time; and
  • Other legitimate interests, including our interests in considering candidates for current and future employment opportunities and in managing and improving our recruitment and hiring process.

If we hire you, information we collect in connection with your application will become part of your employment record and used to manage the onboarding process and for other employment-related purposes in accordance with our Global Personnel Privacy Policy.

    V.         WHO MAY HAVE ACCESS TO YOUR INFORMATION

Within StriVectin: We may disclose certain of your personal information to StriVectin personnel and affiliates who need to know the information for the purposes described above, including personnel in the recruiting, human resources and information technology departments, and in the department responsible for the position for which you are applying.

Third-Party Service Providers: We may use third party service providers acting on StriVectin’s behalf to perform some of the services described above. For example, we share certain information with service providers who facilitate our applicant tracking system, video interviews, travel booking and expenses, relocation support, reporting and analytics and verification/background checking services.

Professional Advisors: We also may share information about you with recruitment agencies working with us in relation to your recruitment as well as with our professional advisors, including accountants, auditors, lawyers, insurers and bankers.  We only permit these advisors to process your personal information for specified purposes and, as appropriate, in accordance with our instructions and the provisions of this Policy and applicable law.

Other Third Parties: In certain limited circumstance, we share and/or are obligated to share your personal information with other third parties, including (a) to comply with our obligations, to protect the rights and property of StriVectin, our customers and the public, to cooperate with law enforcement investigations, and to detect and respond to suspected illegal activity and threats to the health or safety of any person or of our systems or services; (b) in connection with, or during negotiations of, any merger, joint venture, sale of company assets, financing, or acquisition of all or a portion of our business, assets or stock by another company (including in connection with any bankruptcy or similar proceedings); and/or (c) with your consent and at your direction.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

   VI.         DATA RETENTION

If your application for employment is unsuccessful (or you withdraw from the process or decline our offer), we will retain your information for a reasonable period of time beyond the end of the application process for the purposes described above, including complying with our legal obligations, resolving disputes and as necessary for our legitimate interests, such as to consider you for other current and future employment opportunities at StriVectin. If you do not want us to contact you regarding other roles, please contact hr@StriVectin.com. After this period, we will securely destroy your personal information in accordance with applicable laws and regulations or make it anonymous such that it cannot be associated with or tracked back to you.

If your application for employment is successful, personal information gathered during the recruitment process will be retained during your employment in accordance with our Global Personnel Privacy Policy and retention policies.

 VII.         CALIFORNIA RESIDENTS

If you are a California resident, the California Consumer Privacy Act (“CCPA”) requires us to disclose the following information with respect to our collection and use of personal information.

Categories of Personal Information Collected: Over the preceding 12 months, we have collected the following categories of personal information: (1) identifiers; (2) characteristics of protected classifications under California or U.S. law; (3) internet or other electronic activity information; (4) geolocation data; (5) audio, electronic, visual, or similar information; (6) professional or employment-related information; (7) education information; (8) inferences; and (9) other information that identifies, relates, to, describes, or is otherwise reasonably be linked to you. For examples of the precise data points we collect, please see “Information We Collect” section above.

Business Purposes for Collecting and Disclosing Information: We collect each category of personal information for the business purposes in the “How We Use Your Information” section above.

VIII.         EUROPEAN RESIDENTS

If European privacy laws apply to you, our processing of personal information for the purposes mentioned above is based on the following legal grounds:

  • as necessary to evaluate and potentially enter into an employment relationship with you;
  • with your consent, which you may withdraw at any time;
  • to comply with our legal obligations;
  • where necessary to protect your vital interests or those of others; and
  • for our (or others’) legitimate interests, including our interests in considering candidates for current and future employment opportunities and in managing and improving our recruitment and hiring process, unless those interests are overridden by your interests or fundamental rights and freedoms.

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use personal information for an unrelated purpose, we will notify the relevant individual and we will explain the legal basis which allows us to do so. Where the collection or processing of personal information is based on your consent, you may withdraw your consent at any time to the extent permitted by applicable law.

You may have certain rights under European privacy laws in relation to your personal information. This may include the right to access, rectify, port or erase certain personal information we have about you. You may also have the right to object to and restrict certain processing of your data. Certain information may be exempt from such requests pursuant to applicable data protection laws. You can contact hr@StriVectin.com to exercise your rights in relation to your personal information. We will respond to your request consistent with applicable law.

If you have a concern about our processing of personal information that we are not able to resolve, you have the right to lodge a complaint with the relevant data privacy authority (this may be linked to where you reside, work or the place of any alleged infringement). For contact details of the relevant Data Protection Authority, please see  http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

   IX.         INTERNATIONAL DATA TRANSFERS

Due to the global nature of our business, StriVectin may transfer your personal information across international borders, consistent with applicable data protection laws, including to the United States.  Where personal information is transferred within StriVectin to countries outside of the EEA that are not recognized as providing an adequate level of protection under European privacy laws, at least one of the following measures will be in place to safeguard the data:

    X.         SECURITY

StriVectin is committed to protecting the security of your personal information and ensuring a level of security appropriate to the risk our data processing presents. Taking into account the costs of implementation, the sensitivity of the data and nature of the data processing, StriVectin applies technical and organization measures to prevent unauthorized access, destruction, loss, alteration or misuse of personal information.

   XI.         CONTACTING STRIVECTIN

If you have any questions regarding this Policy, please contact us at hr@StriVectin.com.

 XII.         POLICY UPDATES

We may change this Policy from time to time. We will post any changes to this Policy on this page. We encourage you to visit this page and to review this Policy regularly to stay informed of our practices and your privacy rights. Each version of this Policy is identified by its effective date.

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