Recruiting Privacy Notice

Effective Date: January 1, 2023

PRIVACY NOTICE TO CALIFORNIA JOB APPLICANTS REGARDING THE COLLECTION OF PERSONAL INFORMATION

Advanced Systems Group LLC and its operating groups, subsidiaries and affiliates (the “Company,” “us” or “we”) is committed to protecting the privacy and security of the personal information you provide to us. Please read this Job Applicant Privacy Notice (the “Privacy Notice”) to learn how we collect and process your personal information when you apply for a job or other role with us. As a job applicant, you have the right to know and understand the categories of personal information we collect about you, and the purposes for which we use such personal information, pursuant to the California Consumer Privacy Act of 2018 (the “CCPA”). This Privacy Notice only applies to job applicants who are residents of the State of California. The Company does not sell or otherwise disclose this personal information for monetary or other consideration to any third parties.

Categories of Personal Information Collected

In each case, as permitted by applicable law, we collect the following categories of personal information

through your application for the purposes described below:

Personal identifiers, such as your name, preferred name, postal address, email address, account name, Social Security number, date of birth, and other similar identifiers.
Personal Records, such as your signature, Social Security number, address, telephone number, education, employment or employment history.
Protected characteristics, such as minority, veteran and disability status, through voluntary self-disclosure. Such information will only be collected as permitted by applicable law and will not be used to make hiring decisions.
Internet or other similar network activity information, such as your IP address, log-in

information or information regarding your interaction with a website, application or

advertisement.

Geolocation Data, such as IP addresses, from which we can determine your general location.
Sensory data, such as audio and visual information, for example, if you use video interviewing as part of the application process. If you visit our facilities, your entry and exit may be monitored by CCTV.
Professional or employment-related information, such as your work history, references,

information about skills and abilities, accomplishments and awards, training and development information, performance evaluation information, and employment termination information.

Education information, such as your education history, education records (such as grades,

transcripts and class lists), and other information included in your resume or cover letter.

Inferences drawn from other personal information, such as a profile reflecting your

preferences, characteristics, psychological trends, predispositions, behavior, attitudes,

intelligence, abilities and aptitudes.

Other: Job interview notes, responses to screening questions, assessment results, and any other information you provide in connection with the recruitment process. We also collect legal and contractual information, such as information necessary to respond to law enforcement and governmental agency requests, comply with legal and contractual obligations, exercise legal and contractual rights, and initiate or respond to, or establish, exercise and defend, legal and contractual rights claims.

Sources of Personal Information

We collect personal information you voluntarily provide to us when you apply for a job or otherwise

also automatically collect device information such as IP addresses and device identifiers.

We may also combine personal information collected from other sources with the personal information that you provide to us. For example, we may collect information from:

Recruiters
Prior employers (e.g., for references)
Professional references you provide to us
Educational institutions
Pre-employment screening services
Credentialing and licensing organizations
Publicly available sources such as your social media profile (e.g., LinkedIn, Twitter and Facebook)
Other sources as directed by you

Use of Personal Information

We use the categories of personal information listed above for the following purposes:

Process and manage your application: We use your personal information to process your job application, establish a job applicant profile for the recruitment process, assess your

qualifications for a specific role with us, schedule and conduct interviews, communicate with you, and carry out background and reference checks (see the following bullet point for

additional information). We may collect audio and visual information of job applicants through photographs used for identification purposes. With your consent, we may record video of you in connection with the application process, for example through a third party screening service. Additionally, if you are offered a position with us, we may use your personal information in the employee on-boarding process.

Conduct reference and background checks (as permitted by applicable law): We use personal information we collect to conduct reference checks and to evaluate your qualifications and experience. We may also conduct background checks (as authorized by you and permitted by applicable law).
Provide immigration support: If applicable and as permitted by applicable law, we may collect your personal information to assist with immigration support, such as applying for visas or work permits.
Analyze and improve our recruitment process and tools: For example, we analyze trends in our applicant pool, and use personal information to understand and improve our recruitment process and tools (including improving diversity and inclusion). If you use our online job application process, we collect personal information in this category, such as your interactions with our “Careers” page and our online application process.

Record-keeping: We keep records of your personal information as required by law and in accordance with our record retention policies.

Meeting legal requirements and enforcing legal terms: We collect and process your personal information for purposes of: fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property or safety of you, us or another party; enforcing any agreements with you; responding to claims; and resolving disputes. Additionally, we may use information about protected characteristics to analyze and monitor the diversity of our job applicants in accordance with applicable laws.

Disclosure of Personal Information

We may share your personal information as necessary for the purposes described in this Privacy Notice, including internally with our personnel involved in the hiring process. For example, we share your personal information with the following parties:

Affiliates: We may share your personal information with our affiliates.
Service Providers: We use service providers to operate, host and facilitate our hiring and recruitment process. These include hosting, technology and communication providers; security and fraud prevention consultants; analytics providers; background and reference check screening services; and hiring process management tools.
Government authorities and law enforcement: In certain situations, we may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Business transfers: Your personal information may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).
Professional advisors: We may share your personal information with our professional advisors.
Other: We may also share your personal information with third parties in conjunction with any of the activities set forth under “Meeting legal requirements and enforcing legal terms” in the “Use of Personal Information” section above.

Contact for Questions

If you have any questions or concerns regarding this Privacy Notice or the collection of your personal information, please contact HR@asgllc.com. Job applicants with disabilities may access this notice in an alternative format by contacting 510.654.8300 ext. 152.

PRIVACY NOTICE TO US JOB APPLICANTS REGARDING THE COLLECTION OF PERSONAL INFORMATION

Last Updated: 01/01/2023

This document describes how Advanced Systems Group LLC Inc., located at 1226 Powell St, Emeryville, CA, USA 94608, and its affiliates (collectively “ASG LLC”, “we”) collect, process, and transfer personal data about job applicants. Please read it carefully.

ASG LLC does not sell or otherwise disclose this personal information for monetary or other consideration to any third parties.

1. Responsible party for personal data processing

The entity responsible for the processing of your personal data is the ASG LLC entity to which you decide to apply for a position.

2. Types of personal data collected

We collect your personal data to take pre-contractual steps at your request, to comply with legal obligations and to pursue legitimate interests of ASG LLC such as to transmit personal data within the ASG LLC entities for internal administrative purposes. To the extent permitted by applicable law, we collect the following personal data from you in connection with your job application:

Information collected through the online application form such as: name, address, gender, telephone number, email address, user name, password, CV/Resume and other files that you chose to upload regarding your qualifications, work experience, education history, location, right to work, previous or other employment, name and contact details of references, how you heard about the job, reason for leaving your previous employer and availability;
Information that you provide or that we collect through the recruitment process such as: position, department, date of birth, location, willingness to relocate, start date, whether the position or the applicant has a restrictive covenant, whether the position or the applicant are eligible for transfer or secondment, type of employment contract, payment structure (e.g., hourly or salaried), full-time or part-time status, professional membership, jurisdiction, expat status, language spoken, assessment of qualifications, licenses or certifications required to hold the position.

Your decision to apply for a position and provide your personal data to us is voluntary. We indicate on our online form what data fields are mandatory to complete your job application. Failure to provide this information may hinder the processing of your application. You may sign up to receive job alerts from us by providing your name, email address, job category and location. For some positions, we may collect additional information to conduct background checks before we conclude an employment contract with a successful candidate in which case we will provide specific notice. Our recruitment portal may use cookies to function effectively.

3. Special types of personal data

ASG LLC does not process special categories of personal data. However, there may be circumstances where we will process such data, such as, (i) you have consented to the processing of this personal data for one or more specified purposes, or (ii) the processing is required or permitted by applicable law. These special kinds of personal data include data about a  person’s religion or philosophical beliefs, race or ethnic origin, political opinions, health, sexual life or sexual orientation, genetic or biometric data, personal data concerning trade union membership as well as criminal behavior or offenses.  Please refrain from uploading such information in our online recruitment platform.

4. Purposes of the processing

Your personal data will be used by ASG LLC for various purposes, including:

To support the job application process, including to evaluate and assess your experience and qualifications, to conduct talent management activities, to communicate with you about your application or the job alerts that you request and to complete the on-boarding process if we offer you a position;
To record and monitor the total number of job applicants, establish if you are an internal or external applicant and, in some circumstances, to record who was your previous employer;
To provide technical support for the use of our online recruitment platform, including password retrieval;
To comply with or monitor compliance with any applicable law or regulation to which ASG LLC is subject; and
To assist ASG LLC in exercising legal rights, including supporting any claim, defense, or declaration in a case or before any jurisdictional and/or administrative authority, arbitration, or mediation panel.

ASG LLC may also use your personal data to solicit information from you, including through voluntary surveys, to help us improve our recruitment process and experience, or to contact you about future opportunities. Subject to applicable law, you have the right to object to the processing of your personal data for these additional purposes. For more information or to exercise this right, please reach out to your recruitment contact at ASG LLC or email hr@asgllc.com.

5. Disclosure of personal data

ASG LLC may use service providers (data processors) to process personal data on our behalf, such as to offer and manage our online recruitment platform, determine your right to work and financial benefits, provide relocation services, conduct talent management activities, or to conduct surveys on our behalf. We enter into contracts with service providers (data processors) to process your personal data only as needed to perform services on our behalf and to implement appropriate data security measures to protect the data.

If you choose to sign in on our online recruitment platform with a third-party account or to upload your resume data from a professional social network, we may share information with those third parties to allow you to benefit from these functionalities. We are not responsible for the data practices of those third parties, and we strongly suggest you review their privacy policies. 

We or our service providers may also disclose personal data where required or permitted by applicable law (including allowing lawful access to the data by U.S. or foreign courts, law enforcement or other government authorities).

6. Data security

We make reasonable efforts to ensure a level of security appropriate to the risk of the processing of personal data. Taking into account the costs of implementation and the nature of the data processing, we apply technical and organizational measures to prevent unauthorized access, destruction, loss, alteration, or misuse of personal data. Access to your personal data is controlled through the system security within our recruitment platform, systems and network. Your personal data is only accessible by a limited number of human resources professionals, ASG LLC personnel, and our recruitment agents who need access to your personal data to perform their duties.

7. Data retention

ASG LLC will retain your personal data for as long as necessary to complete the application process and for as long as necessary for the purposes set out in this policy (or for as long as your JobVite account remains open), unless a longer retention period is required under applicable law. If you are not offered a position with ASG LLC, we may contact you about future opportunities consistent with this policy and your expressed interests and qualifications.

8. Access and other rights

Subject to applicable law, you may request (i) access to and a copy of your personal data; (ii) correction of your personal data if incomplete or inaccurate; and (iii) deletion of your personal data in certain circumstances. You have the right to object to the processing of your personal data on grounds relating to your particular situation.  Where we have obtained your consent for the processing of your personal data, you have the right to withdraw this consent at any time. If you withdraw your consent, we will apply your preference for the future. When we receive a request, we may ask for additional information from you to verify your identity.  We will comply with your request to the extent required by applicable law. If you are not satisfied with our response, you may consult with a supervisory authority.

9. Questions

10. Changes to our Privacy Policy

Applicable law and our practices change over time. If we decide to update our policy, we will post the changes on our Sites and/or online recruitment platform. If we materially change the way in which we process your personal data, we will provide you with prior notice or request your consent prior to implementing such changes where legally required, We strongly encourage you to read our privacy policy and keep yourself informed of our practices.

EU Applicant Privacy Notice – Processing of Personal Data

We take your privacy seriously. This Applicant Privacy Notice is to help you understand what personal information we collect, why we collect it, and what we do with it. Please read it carefully.

Contacting us

Your personal information is collected by Advanced Systems Group LLC (the “Company,” “us” or “we”). Our address is 1226 Powell Street, Emeryville, CA, USA 94608-2618. Advanced Systems Group LLC and its operating groups, subsidiaries, and affiliates are committed to protecting the privacy and security of the personal information you provide to us.

If you have any questions in relation to the use of your personal information or this Applicant Privacy Notice, you can contact our HR department at hr@asgllc.com

Information that we collect about you

We collect information in relation to your potential employment with the Company. It is either provided by you, or created by us (or on our behalf) in connection with your potential employment with Advanced Systems Group LLC. This information includes:

Personal identifiers, such as your name, preferred name, postal address, email address, date of birth, and other similar identifiers.
Personal Records, such as your signature, Social Security number, address, telephone number, education, employment or employment history.
Professional or employment-related information, such as your work history, references,

information about skills and abilities, accomplishments and awards, training and development information, performance evaluation information, and employment termination information.

Education information, such as your education history, education records (such as grades, transcripts and class lists), and other information included in your resume or cover letter.
Other: Job interview notes, responses to screening questions, assessment results, and any other information you provide in connection with the recruitment process. We also collect legal and contractual information, such as information necessary to respond to law enforcement and government agency requests, comply with legal and contractual obligations, exercise legal and contractual rights, and initiate or respond to, or establish, exercise, and defend legal and contractual rights claims.

If you do not provide your personal information we may be:

unable to enter into, or perform our employment contract with you;
unable to offer you employment;

How we use your information

We use the categories of personal information listed above for the following purposes:

Process and manage your application: We use your personal information to process your job application, establish a job applicant profile for the recruitment process, assess your

qualifications for a specific role with us, schedule and conduct interviews, communicate with you, and carry out background and reference checks (see the following bullet point for

Conduct reference and background checks (as permitted by applicable law): We use personal information we collect to conduct reference checks and to evaluate your qualifications and experience. We may also conduct background checks (as authorized by you and permitted by applicable law).
Provide immigration support: If applicable and as permitted by applicable law, we may collect your personal information to assist with immigration support, such as applying for visas or work permits.
Analyze and improve our recruitment process and tools: For example, we analyze trends in our applicant pool, and use personal information to understand and improve our recruitment process and tools (including improving diversity and inclusion). If you use our online job application process, we collect personal information in this category, such as your interactions with our “Careers” page and our online application process.
Record-keeping: We keep records of your personal information as required by law and in accordance with our record retention policies.
Meeting legal requirements and enforcing legal terms: We collect and process your personal information for purposes of: fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property or safety of you, us or another party; enforcing any agreements with you; responding to claims; and resolving disputes. Additionally, we may use information about protected characteristics to analyze and monitor the diversity of our job applicants in accordance with applicable laws.

Information that we share

Affiliates: We may share your personal information with our affiliates.
Service Providers: We use service providers to operate, host and facilitate our hiring and

recruitment process. These include hosting, technology and communication providers; security and fraud prevention consultants; analytics providers; background and reference check screening services; and hiring process management tools.

Government authorities and law enforcement: In certain situations, we may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Business transfers: Your personal information may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).
Professional advisors: We may share your personal information with our professional advisors.
Other: We may also share your personal information with third parties in conjunction with any of the activities set forth under “Meeting legal requirements and enforcing legal terms” in the “Use of Personal Information” section above.

The Company does not sell or otherwise disclose this personal information for monetary or other consideration to any third parties.

Retention of your information

We will keep your applicant information in accordance with our data retention policy of 1 year.

Securing your information

We follow strict security procedures as to how your personal information is stored and used, and who sees it, to help stop any unauthorized person from getting hold of it. Details of our security procedures are set out in our Information Security Policy.

Transferring any personal information outside the EU

The information we collect from you may be transferred to, and stored, outside the EU and may also be processed by people operating outside the EU who work for us or one of our suppliers.

Countries outside the European Union may have a lower standard of protection for personal information than that required by EU data protection laws. If we need to transfer your data to a company based outside the EU, we will take steps to make sure your personal data is handled in line with EU law and the supplier applies appropriate safeguards (e.g. through a contract, or a recognized certification) in accordance with our Privacy Rules. If you would like to obtain the details of such safeguards, you can request these from the Data Protection Officer.

Your rights

You have a number of rights when it comes to our handling of your data. These are set out in detail in our Individual Rights Policy. Please get in touch with our HR department if you would like to understand which of your personal information these rights may apply to, or to exercise any of these rights.

Questions

If you have questions about the use of your personal information, please contact HR at hr@asgllc.com.

You also have the right to complain to your local data protection regulator about our handling of your data.

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