Candidate Data Collection Policy

This Candidate Data Collection Statement Policy explains our practices regarding collection, use, and disclosure of certain information, including your personal information and your choices, by the BDR Solutions LLC ("BDR") family of companies. This policy applies to our recruitment practices and associated tools and services that link to this policy and to those individuals considered for roles as an employee or contractor at BDR. For clarity, residents of the European Economic Area (“EEA”) are deemed to have acknowledged (rather than agreed to) the policy.

Contacting Us

For questions specifically about this policy, or our use of your personal information, cookies or similar technologies, please contact us at https://www.bdrsolutionsllc.com. The data controller of your personal information is BDR, through which you have applied for a position. Please note that if you contact us to assist you, for your safety and ours, we may need to authenticate your identity before fulfilling your request.

Collection of Information

We receive and store personal information about you such as:

• Information you provide to us: We collect personal information you provide to us including: your name, address, email address and phone number; personal information on your CV/resume or other materials you submit to us, such as your work, professional and educational background and interests, submissions or test results; your salary and job expectations, including your willingness to relocate, and your actual salary to the extent you provide it; the contact information of references you have permission to provide to us; information about your work permit or visa status; travel arrangements; log-in credentials (if applicable); and whether you are a member of a trade union or a veteran, or have a disability, as may be required by applicable law, or to the extent you choose to provide this to us (see “sensitive personal information” below). If extended an offer, we may collect additional personal information to prepare for your onboarding as an employee.‍
• Information from other sources: We also obtain personal information from other sources about your performance or conduct from references, persons who refer you, or former employers; background or identity check data obtained from employment screening agencies (as permitted by applicable law), academic institutions and/or professional organizations; your performance on tests or exercises conducted by recruitment agencies; your travel arrangements from travel agents/agencies who assist in making any travel arrangements for candidates; immigration/work permit status from immigration advisors who, when needed, assist in filings to obtain appropriate work permits or visas; and information you make available publicly through social media (e.g., LinkedIn).‍
• Information we collect automatically: We collect information, including personal information about you and your access of our tools and services and facilities including: your interactions with us and our recruiting posts (e.g., LinkedIn), how you use or interact with our recruiting tools, including our emails and texts; device IDs or other unique identifiers; if you visit a BDR facility, your entry and exit from lobbies and other areas of our facilities may be monitored by cameras; and information collected via the use of cookies, web beacons and other technologies. See our “Cookies” section for more details.‍
• Sensitive Personal Information. We may also collect and use “special” or “sensitive” personal information, which may include personal information relating to your sexual orientation, religion or beliefs, political persuasion, marital status, race, ethnicity, health status, or whether you are a veteran, have a disability, are a trade union member, or have criminal convictions and history. Where such personal data is required, we will only process this as follows (if local law permits): where we have your explicit consent; where it is necessary for carrying out our obligations and exercising our rights in the field of employment, social security or social protection law or collective agreement; where it is necessary for the assessment of your working capacity; where it is necessary for reasons of substantial public interest; where required under a specific legal obligation; or where you have manifestly made this information available to us.

Use of Personal Information

We use personal information to:

• Manage your application, including to identify potential candidates; collect and review applications; process your application, including evaluating your skills for your suitability for the role you may have applied for, or for other roles available at the time you apply or in the future; communicate with you about your application, your stage in the recruiting process and roles and events that we believe may interest you; operate and manage our recruiting tools and processes, including our registration portals and making travel arrangements; if extended an offer, we may use any additional personal information collected to prepare for your on-boarding as an employee;‍
• Conduct reference checks to validate your qualifications, experience, and suitability for a role. For certain roles, we may also conduct background checks (as permitted by applicable law);‍
• Provide immigration support such as to facilitate filing of any necessary visas or work permits;
• Improve our recruiting and employee processes and tools, including to enhance our software and tools and understanding market conditions such as compensation, hiring, and benefits practices;‍
• Conduct data analytics and reporting to monitor, test, and enhance the effectiveness of our recruiting processes and tools, and identify trends in areas including market conditions such as compensation, hiring, and benefits practices, and representation of underrepresented populations;‍
• Keep records of our recruiting processes and tools; and‍
• Protect our systems and business interests and comply with law, including to comply with applicable legal and other requirements; meet recordkeeping and reporting obligations; conduct audits; comply with law enforcement and similar requests in accordance with law; pursue legal rights and remedies; defend litigation and managing any internal complaints or claims; and comply with internal policies and procedures.

For residents of the EEA, our legal basis for collecting and using the personal information described in this Statement will depend on the personal information concerned and the specific context in which we collect and use it. We will normally collect personal information from you where we need the personal information to prepare for or perform a contract with you (for example, if you accept an offer and entering into an employment contract is required); where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms (for example, to assess your candidacy); where processing is necessary for carrying out our obligations and exercising our rights in the field of employment, social security or social protection law or collective agreement; or where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect a substantial public interest or your vital interests or those of another person (for example, to protect the security of you or others).

Disclosure of Information

We disclose your personal information to third parties for certain purposes, as described below:

• Service Providers: We use other companies, agents, or contractors ("Service Providers") to perform services on our behalf or to assist us with our recruiting processes. For example, we engage Service Providers to promote our positions (e.g., LinkedIn), and provide communications, infrastructure and IT services; identify and recruit candidates and assist with recruiting administration, including organizing recruiting events and activities; interview and testing support services; make travel arrangements; provide immigration support services, including advising and assisting in filings to obtain proper work permits or visas; perform background checks; and perform data analytics and provide us with aggregated demographic data. In the course of providing such services, these Service Providers may have access to your personal or other information. We do not authorize them to use or disclose your personal information except in connection with providing their services (which includes maintaining and improving their services);
• Vendors/Employers: In some instances, with your consent, we may share personal information with vendors/employers who work with BDR to enable them to consider you for opportunities;‍
• BDR Employees: We may share personal information about you in our recruiting process with BDR employees;‍
• Academic Institutions and Professional Organizations: We may work with academic institutions to assist with recruiting, including organizing recruiting events and activities;‍
• The BDR family of companies: We share your personal information among the BDR family of companies as needed for data processing and storage; providing you with access to our recruiting tools; making decisions about enhancements to our processes, practices, and tools; and other purposes described in the Use of Personal Information section of this Statement.‍
• Protection of BDR and others: BDR and its Service Providers may disclose and otherwise use your personal and other information where we or they reasonably believe such disclosure is needed to: satisfy any applicable law, regulation, legal process, or governmental request; enforce applicable terms of use, including investigation of potential violations thereof; detect, prevent, or otherwise address illegal or suspected illegal activities, security or technical issues; or protect against harm to the rights, property or safety of BDR, its employees or the public, as required or permitted by law.‍
• Business transfers: In connection with any reorganization, restructuring, merger or sale, or other transfer of assets, we will transfer information, including personal information, provided that the receiving party agrees to respect your personal information in a manner that is consistent with our Statement.

International Data Transfers

Whenever, in the course of sharing information, we transfer personal information to countries outside of the EEA and other regions with comprehensive data protection laws, we will ensure that the personal information is transferred in accordance with this policy and as permitted by the applicable laws on data protection. We ensure that appropriate contractual, technical, and organizational measures are in place.

For contingent workers based in Korea, personal information transferred (such as name and contact information) may be saved electronically on servers operated by our Service Providers for record keeping purposes and other purposes as set out in this Statement.

Your Choices

Email and Text Messages. If you no longer want to receive certain communications from us via email or text message, click the "unsubscribe" link in the email or reply STOP (or as otherwise instructed) to the text message. Please note that you cannot unsubscribe from correspondence from us relating to your application.

Your Information and Rights

You can request access to or request deletion of your personal information, or correct or update out-of-date or inaccurate personal information we hold about you. You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent; you have the right to complain to a data protection authority about our collection and use of your personal information.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Please also see the "Your Choices" section of this Statement for additional choices regarding your personal information.

Retention

We may retain personal information to fulfill the purposes described in this Statement and as may be required by or permitted by applicable law or regulation. Specifically, we will retain information about your candidacy, including your resume/CV for consideration for future roles. If you would like to exercise your rights for personal information we retain, please contact us as described in the “Your Information and Rights section” above. We take reasonable measures to destroy or de-identify personal information in a secure manner when it is no longer required.

Security

We use reasonable administrative, logical, physical and managerial measures to safeguard your personal information against loss, theft and unauthorized access, use and modification. These measures are designed to provide a level of security appropriate to the risks of processing your personal information, but even reasonable security measures may not prevent all incidents.

Other Websites, Platforms and Applications

Our sites may be provided through and/or include features operated by third party platforms or contain links to sites operated by third parties whose policies regarding the handling of information may differ from ours. For example, you may be able to share a link to a recruiting post on social media. These websites and platforms have separate and independent privacy or data policies, privacy statements, notices and terms of use, which we recommend you read carefully.

Changes to this Policy

We will update this policy from time to time in response to changing legal, regulatory or operational requirements. We will provide notice of any such changes (including when they will take effect) in accordance with law. Your continued use of the services after any such updates take effect will constitute acknowledgement and (as applicable) acceptance of those changes.

Cookies

We and our Service Providers use cookies and other technologies (such as web beacons), for various reasons. We want you to be informed about our use of these technologies, so this section explains the types of technologies we use, what they do, and your choices regarding their use.

• Cookies and similar technologies and web beacons. Cookies are small data files that are commonly stored on your device when you browse and use websites and online services. We may use other technologies such as browser storage and plugins (e.g., HTML5, IndexedDB and WebSQL). Like cookies, these other technologies may store small amounts of data on your device. Web beacons (also known as clear gifs or pixel tags) often work in conjunction with cookies. In many cases, declining cookies will impair the effectiveness of web beacons associated with such cookies.
• Why does BDR use these technologies? We use these types of technologies for various reasons, like making it easy to access our services by remembering you when you return; to provide, analyze, understand and enhance our site; improve site performance, monitor visitor traffic and actions on our site; and to deliver and tailor our messages, and understand interactions with our messages (including emails, and recruiting posts on third party sites).
• We may use these and various other technologies for similar purposes as cookies, such as to enforce our terms, prevent fraud, and analyze the use of our sites. There are a number of ways to exercise choice regarding these technologies. For example, many popular browsers provide the ability to clear browser storage, commonly in the settings or preferences area; see your browser's help function or support area to learn more. Other technologies may be cleared from within the application.

To help you better understand how we use cookies, please see the different types below:

Essential cookies: These cookies are strictly necessary to provide our website or online service. For example, we and our Service Providers may use these cookies to authenticate and identify visitors when they use our job sites and applications so we can provide our service to them. They also help us to enforce our terms, prevent fraud, and maintain the security of our services.

Performance and functionality cookies: These cookies are not essential but help us to personalize your interactions with our sites. For example, they help us to remember your preferences. We also use these cookies to collect information (such as click-through and other information) about our visitors' interactions with our sites so that we can enhance and personalize our website and service and conduct research. Deletion of these types of cookies may result in limited functionality of our tools.

California Consumer Privacy Act (CCPA) Candidate Privacy Statement

This Statement applies to California consumers and supplements our policy.

Personal Information We Collect

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“CCPA personal information”). We have collected the following categories of CCPA personal information from consumers within the last twelve (12) months:

• Identifiers: “Identifiers” covers a broad range of information, including things like name, email address, postal address, telephone number, IP address. We collect some CCPA personal information that falls into this category. For example, when you apply for a position, we’re going to collect your name, email address, phone number and your postal address as part of the application process. If we require a background check, we may collect information like your social security, driver's license, state identification, or passport number to run such a check. If you are provided access to recruiting tools, we may collect your username and password. If you accept an offer at BDR, we may collect additional information such as your medical information and health insurance information as part of our pre-on-boarding process. We collect IP addresses when you connect to our job sites. If you click on a recruiting post we place on sites like LinkedIn, we may create an identifier that helps us know that you interacted with our post. These sorts of identifiers are connected to your recruiting file.
• Characteristics of protected classifications under California or federal law: This covers a broad range of information like race, citizenship status, sex, gender identity, marital status, sexual orientation, military status or whether you are a veteran, religion, political affiliation, and whether you are a person with a disability. When you apply for a job, you may provide information about such characteristics.
• Internet or other electronic network activity information: Our job application process is online, so we collect CCPA personal information in this category, like your interactions with our job sites.
• Geolocation data: Our job sites don’t collect precise geolocation data from GPS sensors, which is what we understand this term to mean. However, as noted above, we do collect IP addresses from which we can determine your general location.
• Audio, electronic, visual, thermal, olfactory or similar information: If you visit BDR facilities, your entry and exit from lobbies and other areas of our facilities may be monitored by CCTV.
• Professional or employment-related information: As part of the candidate screening process, we collect CCPA personal information in this category, like information on your resume.

Uses of CCPA Personal Information

We use categories of personal information listed above for the purposes noted in the Use of Information section of our policy. For ease of reference, we repeat that section below:

We use personal information to:

• Manage your application including to identify potential candidates; collect and review applications; process your application, including evaluating your skills for your suitability for the role you may have applied for or for other roles available at the time you apply or in the future; communicate with you about your application, your stage in the recruiting process and roles and events that we believe may interest you; operate and manage our recruiting tools and processes, including our registration portals and making travel arrangements. If extended an offer, we may use any additional personal information collected to prepare for your on-boarding as an employee.
• ‍Conduct reference checks to validate your qualifications, experience, and suitability for a role. For certain roles, we may also conduct background checks (as permitted by applicable law);‍
• Provide immigration support such as to facilitate filing of any necessary visas or work permits;
• Improve our recruiting and employee processes and tools, including to enhance our software and tools and understanding market conditions such as compensation, hiring, and benefits practices;‍
• Conduct data analytics and reporting to monitor, test, and enhance the effectiveness of our recruiting processes and tools, and identify trends, in areas including market conditions such as compensation, hiring, and benefits practices, and representation of underrepresented populations;‍
• Keep records of our recruiting processes and tools; and‍
• Protect our systems and business interests and comply with law, including to comply with applicable legal and other requirements; meet recordkeeping and reporting obligations; conduct audits; comply with law enforcement and similar requests in accordance with law; pursue legal rights and remedies; defend litigation and managing any internal complaints or claims; and comply with internal policies and procedures.

Categories of CCPA Personal Information Disclosed for a Business Purpose

We disclose categories of personal information for business purposes. Please see the Disclosure of Information section of our policy for additional details that may be of interest to you.

Sensitive Personal Information

CCPA personal information may include information that may be considered Sensitive Personal Information as defined in the CCPA. We do not use or disclose Sensitive Personal Information for any purpose inconsistent with section 7027 (l) of the CCPA Regulations.

Sources of CCPA personal information

We explain our sources of information in the Collection of Information section of our Statement. (Please see that section for more information that may be of interest to you.) For ease of reference, in regard to CCPA personal information these are:

• You: We collect CCPA personal information you provide to us including your name, address, email address and phone number; personal information on your CV/resume or other materials you submit to us, such as your work, professional and educational background and interests, submissions or test results; your salary and job expectations, including your willingness to relocate, and your actual salary to the extent you provide it; the contact information of references you have permission to provide to us; information about your work permit or visa status; travel arrangements; and whether you are a member of a trade union or a veteran, or have a disability, as may be required by applicable law, or to the extent you choose to provide this to us (see “Sensitive Personal Information” above). If extended an offer, we may collect additional personal information to prepare for your on-boarding as an employee.‍
• Other sources: We also obtain personal information from other sources about your performance or conduct from references, persons who refer you, or former employers; background or identity check data obtained from employment screening agencies (as permitted by applicable law), academic institutions and/or professional organizations; your performance on tests or exercises conducted by recruitment agencies; your travel arrangements from travel agents/agencies who assist in making any travel arrangements for candidates; immigration/work permit status from immigration advisors who, when needed, assist in filings to obtain appropriate work permits or visas; data providers, from which we obtain aggregated demographic data; and information you make available publicly through social media (e.g., LinkedIn).‍
• Automatic collection based on your interaction with our systems or movement within our facilities: We collect information, including personal information about you and your access of our tools and services and facilities including: your interactions with us and our recruiting posts (e.g., LinkedIn), how you use our interact with our recruiting tools, including our emails and texts; device IDs or other unique identifiers; if you visit BDR, your entry and exit from lobbies and other areas of our facilities may be monitored by video; and information collected via the use of cookies, web beacons and other technologies (see our “Cookies" section for more details.)

Your Rights under the California Consumer Privacy Act

• You have the right to know: what categories and specific pieces of CCPA personal information have been collected about you; the categories of sources from which CCPA personal information are collected; our business or commercial purpose for collecting, using, or disclosing CCPA personal information; the categories of third parties with whom we share CCPA personal information; the categories of CCPA personal information we have disclosed about you for a business purpose.You have a right to confirm whether or not we process your CCPA personal information as well as to access and receive a copy of the specific CCPA personal information we have collected about you.
• You have a right to request the deletion of your personal information, subject to exceptions under the CCPA.
• You have a right to request correction of any inaccurate CCPA personal information we hold about you.
• You have the right to receive notice of our practices at or before collection of CCPA personal information (for example, this notice) and not receive discriminatory treatment or be retaliated against if you choose to exercise any of your rights.

We do not sell or share CCPA personal information. We do not knowingly sell, share or use the personal information of minors under 16 years of age. In order to verify the request, we may ask you to verify your identity.

Retention

We retain categories of CCPA personal information in accordance with this policy. For ease of reference, we repeat that section below:
We may retain CCPA personal information to fulfill the purposes described in this policy and as may be required by or permitted by applicable law or regulation. Specifically, we will retain information about your candidacy, including your resume/CV for consideration for future roles. If you would like to exercise your rights for personal information we retain, please contact as described in the “Your Rights under the California Consumer Privacy Act” section above. We take reasonable measures to destroy or de-identify the CCPA personal information in a secure manner when it is no longer required.