Candidate Privacy Notice

This special notice applies to personal data of applicants based in certain geographic locations with specific privacy regulations, including California and the European Union. For questions concerning our processing of your personal data please reach out to the Talent Team (talent@tropicapp.io).

California Notice at Collection for California Applicants

This California Privacy Notice of Collection (“Notice”) applies to California applicants for employment at Tropic. This Notice provides information about the categories of personal information Tropic Technologies, Inc. (“Tropic”, “we”, “us” or “our”) collects from California applicants, and the purposes for which we use the information.

What is Personal Information?

When we use the term “personal information” in this Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you within the context of your acting as a job applicant. It does not include aggregated or de-identified information that is maintained in a form that is not capable of being associated with or reasonably linked to you.

Collection of Personal Information

During the recruiting process and when you apply for a job with us, Tropic may collect the following categories of Personal Information about you:

Identifying information, such as your full name, name pronunciation, pronouns, date of birth, and signature.
Contact information, such as your home address, telephone numbers, and email addresses.
Educational history and qualifications, such as your academic qualifications, educational records, academic references, and interview notes.
Employment history and qualifications, such as your current employment information, including job title, position, hire dates, compensation, employment references, and referrals, in addition to any previous employment information.
Social media, website profiles, and other information from publicly available sources.

We may also collect, store and use the following types of more sensitive personal information (known as “Special Category Data”), where this information is relevant to the role you apply for and/or you choose to disclose to us:

Demographic data, such as gender, race, ethnic origin, marital status, disability, and veteran or military status.

Sources of Personal Information

Tropic may receive personal information from third parties, for example, in connection with a background, employment, or reference check, subject to your consent where required by law. If you have submitted your application through our recruitment portal, Gem ATS, or other third-party platforms such as Indeed or LinkedIn, we may also link the data you provide to us with other publicly available information about you that you have published on the internet, including sources such as LinkedIn and other social media profiles.

Use of Personal Information

Tropic may use or disclose your Personal Information as appropriate for:

Identifying and evaluating job applicants, including assessing skills, qualifications, and interests for the purposes of determining suitability for the position for which you have applied.
Verifying your information and carrying out employment, background, and reference checks, where applicable, subject to your consent where required by applicable law.
Communicating with you about the recruitment process and your application.
Keeping records related to our hiring processes, for only as long as appropriate under the circumstances.
Creating and submitting reports as required by applicable laws or regulations.
To comply with our legal, regulatory, or other corporate governance requirements.
Analyzing and improving our application and recruitment process.

Third Parties

This Notice does not address, and we are not responsible for, the practices of any third parties, which have their own rules for how they collect and use your personal information. Our links to third-party websites or services are not endorsements.

EU General Data Protection Regulation (GDPR) Candidate Privacy Notice

NOTE: This Privacy Notice applies to job applicants in the European Economic Area or if you are resident in a country that has adopted a local law to implement or adopt the GDPR such as the United Kingdom, the applicable local law implementing or adopting the GDPR.

Tropic Labs, Inc. and Tropic Labs UK Limited (collectively, “Tropic”) is committed to protecting the privacy and security of your personal data. This Notice describes how Tropic collects and processes personal data about you during the application and recruitment process. We will only process your personal data in accordance with this Notice unless otherwise required by applicable law. We take steps to ensure that the personal data that we collect about you is adequate, relevant, not excessive, and processed for limited purposes.

Tropic is a “data controller” in relation to personal data collected during the application and recruitment process. This means that we are responsible for deciding how we hold and use personal data about you. You have received a copy of this Notice because you are applying for work with us (whether as an employee, worker or contractor). This Notice does not create or form part of any contract for employment or otherwise.

Collection of Personal Data

For the purposes of this Notice, personal data means any information about an identifiable individual collected in connection with the recruitment process. We may collect, store, and process the following categories of personal data, most of which we require in order to conduct our recruiting activities.

Tropic collects the following categories of personal data:

Identifying information, such as your full name, name pronunciation, pronouns, date of birth, and signature.
Contact information, such as your home address, telephone numbers, and email addresses.
Educational history and qualifications, such as your academic qualifications, educational records, references, and interview notes.
Employment history and qualifications, such as your current employment information, including job title, position, hire dates, compensation and employment references and referrals, in addition to any previous employment information.
Social media, website profiles, and other information from publicly available sources.

We may also collect, store and use the following types of more sensitive personal data (known as “Special Category Data”), where this information is relevant to the role you apply for and/or you choose to disclose to us:

Demographic data, such as gender, race, ethnic origin, marital status, disability, and data concerning personal health.

Sources of Personal Data

Tropic may receive personal data from third parties, for example, in connection with a background, employment, or reference check, subject to your consent where required by law. If you have submitted your application through our recruitment portal, Gem ATS, or other third-party platforms such as Indeed or LinkedIn, we may also link the data you provide to us with other publicly available information about you that you have published on the internet, including sources such as LinkedIn and other social media profiles.

Use of Personal Data

We only process your personal data where applicable law permits or requires it in connection with carrying out our application and recruitment process, to take steps necessary to enter into an employment contract with you, where the processing is necessary to comply with a legal obligation that applies to us, for our legitimate interests or the legitimate interests of third parties, or with your consent if applicable law requires consent. We may process your personal data based on the following legitimate interests:

Identifying and evaluating job applicants, including assessing skills, qualifications, and interests for the purposes of determining suitability for the position for which you have applied.
Verifying your information and carrying out employment, background, and reference checks, where applicable, subject to your consent where required by applicable law. We only collect criminal conviction data where it is appropriate given the nature of your role and where the law permits.
Communicating with you about the recruitment process and your application.
Keeping records related to our hiring processes, for only as long as appropriate under the circumstances.
Creating and submitting reports as required by applicable laws or regulations.
To comply with our legal, regulatory, or other corporate governance requirements.
Analyzing and improving our application and recruitment process.

In addition to using your personal data for the position for which you have applied, we may retain and use your personal data to inform you about and consider you for other positions that may be appropriate for you with your consent. We will only process your personal data for the purposes we collected it for or for compatible purposes. If we need to process your personal data for an incompatible purpose, we will provide notice to you and, if required by law, seek your consent. We may also process your personal data for our own legitimate interests, including for the following purposes:

To prevent fraud.
To ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution.

Sharing of Personal Data

We may share your personal data with other parties as necessary for the purposes described above. For example, we may share your personal data with:

Affiliates. Our corporate parent, subsidiaries, and other affiliates under the control of our corporate parent, for purposes consistent with this Notice or to operate shared infrastructure, systems, and technology.
Company service providers. Companies that provide us with services that help us manage the recruiting process and operate our business, such as job boards, recruiters, interviewing and testing, pre-employment screening, interview travel booking and expense reimbursement (where applicable), relocation (where applicable), recruitment analytics, and software providers.
Law enforcement, government bodies, regulators, and other parties for legal reasons. We may share your personal data with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements; and/or (iii) exercise or protect the rights, property, or safety of Tropic, our Employees or others.
Business transfers. Parties to transactions and potential transactions whereby we sell, transfer, or otherwise share some or all of our business or assets, including your personal information, such as a merger, consolidation, acquisition, reorganization, or sale of assets, or in the event of bankruptcy or dissolution.
Professional advisors. Lawyers, immigration advisors, and other outside professional advisors.

Note on Service Providers

We will only share your data with third parties for the purposes of processing your application. All third-party service providers are required to take appropriate security measures to protect your data in accordance with the law and in line with our policies. We do not allow our third-party service providers to use your data for their own purposes. We only permit them to process your data for specific purposes and in accordance with our instructions. Your personal data will be shared with these providers used by Tropic to help manage its recruitment and hiring process on Tropic’s behalf:

Gem ATS, a cloud services provider located in the United States of America
Candidate.fyi, a candidate experience portal and scheduling tool

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Cross-Border Data Transfers

If you are located outside of the United States, your personal data will be transferred to the United States once you submit it through this site. Because the European Union Commission has determined that United States data privacy laws do not ensure an adequate level of protection for personal data collected from EU data subjects, the transfer will be subject to appropriate additional safeguards under Standard Contractual Clauses (“SCCs”) adopted by the EU Commission or adopted by a supervisory authority and approved by the EU Commission. You can obtain a copy of the SCCs by contacting us at talent@tropicapp.io

Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will normally retain your personal data for up to 3 (three) years or 1,095 days to fulfill the purposes we collected it for, as required to satisfy any legal, accounting or reporting requirements, or as necessary to resolve disputes.

To determine the appropriate retention period for personal data, we consider our statutory obligations, the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes we process your personal data for, and whether we can achieve those purposes through other means. We specify the retention periods for your personal data in our data retention policy.

Under some circumstances, we may anonymize your personal data so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

If you are offered and accept employment with Tropic, the personal data we collected during the application and recruitment process will become part of your employment record, and we may use it in connection with your employment consistent with our employee personal data policies. If you do not become an employee, or, once you are no longer an employee of Tropic, we will retain and securely destroy your personal data in accordance with our document retention policy and applicable laws and regulations.

Rights of Access, Correction, Erasure, and Objection

Under certain circumstances, by law, you have the right to:

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. Please inform us of any changes to your personal information so that we can ensure that the personal information we store about you is accurate and up to date.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object to where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party. This enables you to ask us to provide you with the personal data that you have provided to us in a structured, commonly used, and machine-readable format, or to transfer your personal data to another controller.

If you want to review, verify, correct, withdraw consent, or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact us at talent@tropicapp.io. You also reserve the right to lodge a complaint with the supervisory authority in the EU Member State where you are a resident or where you work. For further information on your rights, please see the supervisory authority of your country or EU Member State.

We may request specific information from you to help us confirm your identity and your right to access and to provide you with the personal data that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal data that we hold about you, or we may have destroyed, erased, or made your personal data anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal data, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we reserve the right to charge a reasonable fee or refuse to acknowledge your request if such request is clearly unfounded, repetitive or excessive.

We do our best to respond to all requests in a timely fashion, and commit to responding to all standard requests within thirty days.

Third Parties

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need-to-know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Changes to This Privacy Notice

We reserve the right to update this Privacy Notice at any time, and we will provide you with a new Privacy Notice when we make any updates. If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose. We may process your personal data without your knowledge or consent only where required by applicable law or regulation.

If you have any questions about our processing of your personal data or would like to make an access or other request, please contact us at: talent@tropicapp.io

Effective Date: January 1, 2023

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