Notice of Privacy Practices for Job Applicants

Last Updated: April 18, 2024

This Notice of Privacy Practices for Job Applicants (“Applicant Notice”) describes how Soter, Inc. and its affiliates (“Soter,” “we,” or “us”) process information in connection with our recruiting activities.

1. Information We Collect

When you apply for a job with us, we may collect certain information from and about you in order to evaluate and process that application. This information may include:

• Contact information, such as name, telephone number, physical address, email;

• Previous work experience, compensation, education, degrees, language, and other skills and employment-related information;

• Professional and other work-related licenses, permits, and certifications;

• Awards and professional memberships;

• Information regarding your use of our website, as described in the Cookie Notice.

• Work authorization status;

• Information relating to references;

• Information from social media sites if you choose to link your application to a social media; and

• Any other information you elect to provide to us (e.g., employment preferences, willingness to relocate, and desired salary, possession of Driver’s license).

  
  

Sensitive Personal Information

Certain types of information are considered sensitive personal information in certain jurisdictions. This includes the following: information on race, religion, ethnicity, nationality or national origin, age, gender identity, sex, life or sexual orientation, criminal convictions and offenses, marital status, medical or health information (including disability status), genetic or biometric information, religious or philosophical beliefs, political party or trade union membership, background check information, and veteran status.

Under the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act  of 2020 (“CPRA”), the following information are also defined as sensitive personal information: precise geolocation, social security number; driver’s license number, state identification card number, passport number, account log-in/financial account/debit card/credit card number in combination with any required security or access code, password, or credentials allowing access to an account, and the contents of a consumer’s mall, email and text messages, unless the business is the intended recipient of the communication.

Depending on the stage of an application, in addition to the information you provide to us, we may obtain information about you from other third parties, such as platforms used to collect application information, recruiters, references, former employers, and law enforcement agencies.

2. How We Use Information

The information that you submit during a job application process may be used for personnel recruitment, management, and planning purposes including the following:

• Analyze your qualifications for the job you applied for or future jobs that may match your profile;

• Communicate with you regarding your job application, your inquiries and requests, other job openings, or important notices;

• Conduct criminal history, background, and employment checks, if we offer you a position;

• Support our efforts to maintain a diverse workforce; and

• Comply with or monitor our compliance with any applicable law or regulation.

We may use and share information in an aggregated or de-identified manner data at our discretion, including for research, analysis, modeling, marketing, and improvement of our Services.

3. Accuracy of Information You Provide

You are responsible for the information you provide to Soter, Inc. and that it is honest, truthful, accurate, and not misleading in any way.

4. How We Share Your Information

We may share your information in the following circumstances:

• Agencies, Individuals. We share your information with agencies and individuals strictly for recruiting activities, including but not limited to, candidate assessment, interview scheduling, and employment offers.

• Vendors, Service Providers. We may share your information with vendors and service providers that we believe need the information to perform a technology, business, or other professional function for us, including providing products or Services to you or our clients on our behalf, creating or maintaining our databases, researching and analyzing the people who request information from us, preparing and distributing communications, or responding to inquiries.

• Affiliates. We may share your information with companies that we own or control, that are owned or controlled by us, or that are under common ownership or control.

• Business Transition. If Soter, Inc., or any portion of our assets, are acquired by, merged with, transferred to, or invested in by another company, we may share your personal information with that company or other third parties involved in the business transition. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Policy.

• Legal. We share information where necessary to comply with applicable law, to respond to requests from law enforcement agencies or other government authorities or third parties, as permitted by law, and without your consent when it is necessary to protect our customers, employees, or property; in emergency situations; or to enforce our rights under our terms of service and policies.

5. Cookies and Other Tracking Technologies

We may use various cookies, technologies, and other automated means to collect certain information about your use of our Services. For more information regarding our use of cookies, please see our Cookie Notice.

6. Retention & Disposal

We retain information as long as necessary to fulfill the purposes for which we collected it, for legitimate business reasons, or as required by law. We may need to keep your data for longer than our specified retention periods to honor your requests, including to continue keeping you opted out of marketing emails, or to comply with legal or other obligations. When we dispose of information, we use secure means, such as either physically or electronically erasing information or making it anonymous in a non-recoverable manner.

7. Security

We implement the appropriate organizational, technical, and physical security measures and controls to protect the confidentiality, integrity, and availability of the personal information entrusted to us. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us at recruit@soter.ai

8. California Notice at Collection

Under the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act  of 2020 (“CPRA”), you are entitled to be informed about the following, at or before the point of collection of your personal information:

• The categories of personal information we will collect, the purposes for which those categories of personal information will be collected or used and whether such information will be sold or shared;

• The categories of sensitive personal information to be collected and the purposes for which those categories of sensitive personal information will be collected or used and whether such information is sold or shared; and

• The length of time we intend to retain each category of personal information, including sensitive personal information, or the criteria used to determine such period;

To the extent that we collect your personal information that is subject to the CPRA, that information and our practices are described below. The categories we use to describe the information are those enumerated in the CPRA; categories not listed are not collected. Certain personal information may fall into multiple categories.