Simtra Recruitment Platform Privacy Policy

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Last updated: September 2023

Thank you for visiting the Simtra Recruitment Platform (collectively, the “Services”) which are tools for Simtra’s and application process. Before using the Services, you should read this entire Privacy Policy. If this Privacy Policy is not acceptable to you, please do not use the Services or submit any information to us via the Services.

This Privacy Notice will provide you with information on the data processing activities of Simtra¹ and its affiliates and subsidiaries (collectively “Simtra”, “we”, “our”, or “us”).  

Simtra is the data controller under applicable data protection law for any personal data collected, processed, used disclosed or transferred in connection with the Services.  

Please review Simtra’s Global Privacy Statement and applicable policies which can be found on Simtra’s website² for more information regarding Simtra’s privacy obligations.

This Privacy Policy only applies to the Services, which are comprised of the following:

• Simtra Recruitment Platform accessible when you log into your account via https://Simtra.wd1.myworkdayjobs.com/Simtra/login; and

While using the Services, you may see links to other components of our Services which are owned or operated by Simtra, or one of our authorized service partners (e.g., when you click “apply now” for a specific job opportunity).   However, there may also be links that will take you to Simtra’s social media pages located on social media sites like Facebook and LinkedIn.  Please note that our pages on social media sites are governed by the privacy policy of the company providing it.

In order to provide you with the Services and for the other purposes described in this Privacy Policy, we receive and collect certain information from you, including personal data (also referred to as “personally identifiable information” or “personal information” in some jurisdictions).

For purposes of this Privacy Policy, “personal data” means information that is about, or relates directly or indirectly to an identified or identifiable individual (as determined by applicable laws).  Examples of personal data you may submit or which may be generated in connection with your use of the Services include your name and contact details, educational background, employment background, job qualifications, information you include in curriculum vitae, resume or transcripts, and any supporting documentation attached to your resume, career interest areas and preferences, such as salary expectations, willingness to relocate, travel, and preferred work location, preferences regarding what information you would like to receive from Simtra, information you list in social media such as LinkedIn IP address, the date and time you access the Services, other technical details associated with your use of the Services, responses you provide to written-response  questions, and to the extent you consent to a video recorded interview, video recordings. Read more about the types of personal data we³ collect in conjunction with the Services in “How We Collect and Process Personal Data.”

This Privacy Policy serves to inform you about how Simtra collects, stores, processes, uses and discloses your personal data when you use and interact with the Services. Learn more about what categories and types of personal data we collect below.

For purposes of this Privacy Policy, the Services consist of the Simtra Recruitment Platform.  The Services are intended to carry out Simtra’s recruitment and hiring initiatives, and consist of multiple web applications and components.  The purpose of the Services is to support your online job application process, for recruiting, screening, and hiring purposes, and to email and communicate with you and respond to your requests and/or areas of interests regarding employment opportunities.  We may also use your personal data to find interested and qualified candidates for our job vacancies.

We collect, use, share and process your personal data that we collect via the Services for recruitment and hiring purposes, such as to do the following:  

• collect, use, share and process your personal data if you indicated that you wish to learn more about Simtra and receive alerts/newsletters about career opportunities;
• keep your account after the initial recruitment process is over via the Simtra Recruitment Platform, for the purposes of recruitment for later offers of jobs, which you have not applied for but which are similar to the job you have applied for;

Depending on where you are located, Simtra may process this personal data on the basis of Simtra’s legitimate interests in filling its job vacancies with qualified candidates or based upon your consent.  If we rely upon your consent, you have the right to withdraw your consent at any time. The revocation of your consent shall not affect the lawfulness of our handling and processing your personal data based on your consent before its withdrawal.

You can withdraw your consent by contacting us at the contact details provided below.

We reserve the right to process, use and disclose (including transfer) personal data for our legitimate interests, and/or compliance with applicable laws as necessary to:

• respond to your requests,
• comply with applicable laws, regulations, legal process, and law enforcement inquiries, as required by litigation,
• to take precautions against liability and protect the security and integrity of the Services and the safety of its users.

The Services collect and generate personal data from its users in two ways: actively and passively. Active data collection refers to situations in which we gather personal data from you when you send it to us, such as in submitting a job application to Simtra. Passive data collection refers to situations in which we generate personal data about you that you have not actively provided (e.g., data that your web browser automatically collects and submits to us when visiting the Services).

Active Personal Data Collection

In order to run an application process or to be notified of a job opportunity, and depending on where you are located, you may be required to provide us with the following personal data: your contact details (email address and phone number), your password, your name, your address, your education information (e.g., school and university history), your professional/work history and CVs, your qualifications and skills, the location and department you would like to work for at Simtra and how you have learned about Simtra, your travel preferences, willingness to relocate, current job termination period, the name of the person who might have referred you to a specific job position, your ethnicity and gender, veteran status, salary expectations, current work status to work in a particular country and whether or not you require sponsorship, whether you have a relative working at Simtra, and if you voluntarily self-identify a disability. Furthermore, we may collect other personal data you provide to us (e.g., reference letters, work certificates, etc.) as well as personal data you provide us with in conjunction with updates and corrections, and information on whether you have given your consent to the storage of your data for later job offers.

• If you choose to do so, you may also import your personal data from your social media profiles such as LinkedIn.
• If you apply for any or our vacancies and we believe that you are a suitable candidate, we may ask you for additional information as a part of the recruitment process (e.g., in interviews or assessment centers).  
• If you are selected for a particular position we may also perform screening and ask third parties for information on your professional history, qualifications and skills (e.g., former employer, based on the information given by you) and perform a background check where admissible according to local laws applying to the entity you are submitting an application for (e.g. verification in the criminal records where it is permitted by the applicable law). We will perform such screening or background checks on the basis of Simtra’s legitimate interest or based on your oral consent, depending on your country, and subject to local laws.
• If you are applying for a job at one of our Local Simtra Entities, the local HR department of such Local Simtra Entity will receive access to your personal data and will use and process the personal data to assess whether you are a suitable candidate for such Local Simtra Entity’s vacancies and, if so, contact you, as described above.
• The information you give us in connection with the Services will be used to determine your suitability for Simtra job opportunities.  If we find a match between your application information and the requirements for a particular job, a member of our HR department may contact you.

In case you do not complete an application process, Simtra will collect, process and use personal data that you have provided and saved during an application process until you discontinue with the application process (information on contact details, work experience, education and certifications, attachments, questionnaire and diversity for the sole purpose of enabling you to proceed with the application process later without having to again provide the information that you have already filled-in and saved. This personal data will not be used for any other purposes.

Passive Personal Data Collection

We may also collect your personal data through the following tracking technologies:

• Cookies:  Small files that are transferred to your device’s hard drive for a period of time to store your preferences and other types of information to help us provide you with certain features.  Read more about cookies in our Cookie Policy⁴.  
• Web Beacons:  Electronic images placed in the code of a webpage, application, or email that allow us to monitor things such as your activity and site traffic. 
• Google Analytics: Google Analytics uses cookies to collect data such as time of visit, website pages visited, time spent on each Simtra website page, IP address, URL, and type of operating system. To learn more about how Google Analytics collects and processes personal data, please visit www.google.com/policies/privacy/partners.

In addition, we may also receive information about you from other sources, including through third-party services and organizations.  For example, if you use third-party sites, such as Facebook, LinkedIn, Google, or Twitter, we may collect information that you make public on these third-party sites to enrich your contact profile.

Any personal data we collect from or obtain about you will be processed, used and disclosed (including transferred) for the purposes set out in this Privacy Policy or as specifically defined and disclosed at the time when the data is collected or provided.

We may transfer, share, or otherwise permit access to your personal data in certain circumstances:

• To Simtra employees belonging to the Simtra human resources team and other Simtra employees serving as administrators or other support staff;  
• To Local Simtra Entities, acting as further data controllers, for the recruitment purposes as described in this Privacy Policy;
• To the extent applicable, to our global service providers who provide technical, administrative, or market research support to Simtra and/or as required for maintenance, hosting and management of the Services. All such service providers are contractually bound and obliged to comply with required privacy standards in compliance with applicable law.  Simtra has data processing agreements with its business partners to ensure they provide an adequate level of protection for your personal data.  These entities are authorized to use your personal data only as necessary to provide these services to us;
• In the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, you will be informed about this and may withdraw your consent to or - as applicable - object to the transfer of your personal data to, and processing and use of your personal data by, the transferee.

Some of the individuals and entities who will receive your personal data may be located both within and outside of your country, including in countries that have less adequate protections, safeguards and rules to protect personal data and where you may not have the same rights to your data that you do in your own country. Simtra is a global company and, therefore, uses global vendors and subcontractors, as well as global IT systems and applications. As a result, your personal data may be transferred to our vendors, subcontractors, global affiliates and to our employees and contractors who work for us and are located outside of the EU/EEA or the country where you are located, such as in the United States, for the purposes described in this Notice. These countries may have less strict data protection laws compared to your country.  If this is the case, we will take legally required steps to ensure that adequate safeguards are in place (e.g., standard contractual clauses) to protect your personal data. You may contact us for a copy of the safeguards which we have put in place to protect your personal data and privacy rights when your personal data is transferred outside of your country/region.

In certain circumstances, local privacy laws may give you rights with respect to your personal data, as described in more detail below. You may exercise your rights by contacting us using the information at the end of this Privacy Notice.

We will handle any request to exercise your rights in accordance with applicable law, but please note that these rights may not be absolute.  Simtra may refuse or deny a request in accordance with applicable privacy laws. Additionally, depending on the circumstances and where you are located, not all of the below rights may be available to you.

Your rights with respect to your personal data may include the following:

Withdraw Consent

If we use or share your personal data based on your consent, you may withdraw your consent at any time. Note that withdrawal of your consent will not affect the lawfulness of our uses or sharing of your personal data before you withdraw your consent.

Access 

You may request access to or copies of your personal data. You may also request what types of personal data we have, the purposes for which we process it, and who has received access to your personal data.   

Correction and Deletion 

You may request that we correct your personal data if you think it is inaccurate or incomplete. You can also request that we erase or delete your personal data in certain circumstances.  

Restrict Processing  

You may request that we restrict the processing of certain personal data.

Data Portability

You may request that we provide you with your personal data that we obtained from you, and you can ask us to provide it to another entity.    

Object

You may have the right to object to our processing of your personal data for certain purposes. 

Lodge a Complaint 

If you believe we are using, disclosing, or otherwise processing your personal data in a way that is not in accordance with applicable law, you can lodge a complaint with the relevant data protection authority in your countryWe will only retain your personal data until the purpose for which it was collected has been accomplished and, beyond that, as described in the following:

For the Simtra Recruitment Platform:  If and to the extent permitted under applicable law, we will retain your personal data for 365 days after your last active date in the system in a manner that allows us to actively use it to provide you with information about other open positions that could be of interest to you*. After these periods, we will cease to use your personal data for such purposes and will only retain your personal data in accordance with our data retention policies for as long as applicable law requires or allows us to do so, such as to comply with applicable data retention obligations.

*If you are located in Germany, we may retain your personal data for purposes of providing you with information about other open positions that could be of interest to you for up to 6 months.

**How long we retain your data may depend on where you are located.  In general, we retain data for 3 years.  If you are located Russia, 6 years; Portugal, 5 years; Lithuania, 1 year; Bulgaria, 6 months.

For California residents, please review the California Candidate & Applicant Privacy Notice provided at the end of this Privacy Policy.

We have reasonable and appropriate security measures in place to protect against the loss, misuse, and alteration of any personal data we receive. We maintain reasonable security standards to protect personal data that we maintain. If you have any questions about the security of your personal data, you can reach us using the contact details below.

Certain laws require Simtra to indicate whether we honor “Do Not Track” settings in your browser concerning targeted advertising. As of the effective date of this Privacy Policy, an industry standard has not yet been established on how to respond to these signals, and therefore the Services do not currently respond to such signals.   Instead, we adhere to the standards set out in this Privacy Statement. If you have any questions, please contact us using the information provided below.

We may periodically update this Privacy Policy to describe new components of the Services and how it may affect our use of information about you. If we make material changes to this this Privacy Policy, we will post a notice on this site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

If you have questions or concerns about this Privacy Policy, our information practices, or any other aspect of the privacy and security of your personal data, please contact us using the information below.

Email: [email protected]

Ethics and Compliance Hotline: 1-844-294-5418

SIMTRA CALIFORNIA CANDIDATE & APPLICANT PRIVACY NOTICE

This California Candidate & Applicant Privacy Notice (“Notice”) applies to the processing of California residents’ personal information in connection with the Services described in the Simtra Recruitment Platform Privacy Policy.  This Notice sets out how Simtra collects and uses personal information about you in connection with your prospective employment and the use of our Services.  If you later become an employee of Simtra and are a California resident, you will receive a separate notice to describe how your personal information is used as an employee.  

Simtra may amend or modify this Notice at any time. The new version of the Notice will be communicated in the same or similar manner as this version of the Notice.

If you have any questions regarding this Notice, please contact the Privacy Office at:  [email protected].    California residents who are unable to review or access this Notice for any reason (e.g., language or disability) please contact the Privacy Office to receive a copy in an alternate format.  

Categories of Personal Information Collected & Disclosed

For the purpose of this Notice, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.

Simtra will use your Personal Information that is collected during your use of the Services.  The categories of Personal Information that Simtra may process in connection with the Services are listed below.  

• Contact and demographic information such as full name, home and work address, home and work phone number, home and work fax number, home and work email address, work mobile phone number, web address data, job code, employment location, job title, employee ID;
• Internet or other similar network activity such as browsing history, search history, information on your interactions with a website, application, or advertisement; and  
• Master data and qualified HR data such as job function, business title, contractual details, education, work experience, employment history, CV, certification information, data about employee appraisal, national ID type, national ID, citizenship status, citizenship country, nationality, place and date of birth, gender, marital status, language skills, military service information, passport issue country, passport issue city, passport issue state, passport expiry date, visa status, country for visa/permit (country name for which visa is applied/granted), visa effective date, visa type (work permit/business/etc.), visa contract, visa expiry date (only for compliance with immigration law purposes), drivers’ license information, emergency contact information, employment location, employment action (hire/rehire/termination/leave), reason for employment action (hire/rehire/termination/leave), job code, reports, employee classification, employment status, work schedule, type of contract, contractual starting date, contractual end date, contract duration information, probation period, job classification, full time/part time status, work duration information, part time percentage, job title and job title code, company, department, sub-department, region, market, project and project allocation, information on international internal assignments, accomplishment information, cost center and cost center allocation, supervisor (employee name and ID), staff travel details, employee expenses, company credit card expenditure, mobile device information, education, company training history, development plan, award information, membership information, performance rating history, skills, qualifications and special competencies,   days of absence taken per year (but not including health related Personal Information), all Personal Information required to provide data subjects (1) access to company computer systems, mobile devices and networks and (2) tools to electronically communicate within the Simtra group, including but not limited to IP address, device ID and user login name.

We refer to this candidate and applicant related information as “Personal Information.”  Simtra collects Personal Information for its business purposes.  

The provision of your Personal Information is voluntary. However, if you do not provide your Personal Information, the affected HR processes and/or use of the Services might be delayed or impossible.

How we Obtain your Personal Information 

Simtra collects Personal Information directly from you or from third parties including through references, background and identity checks, medical tests or reports, performance feedback or tests, complaints, through an investigation or inquiry into a workplace incident, from government authorities or as otherwise authorized or permitted by law.  It also collects information indirectly from you, for example, when you navigate our site.

Who we Disclose your Personal Information to

We disclose the above listed categories of Personal Information to the following categories of third parties:

• Our Service Providers, who have executed privacy contracts with us and have agreed to treat your Personal Information confidentially and not sell your Personal Information.  
• To third-party analytics providers and advertising partners. 

Why we Process your Personal Information

Simtra will process your Personal Information for the following business purposes:

Prospective Employment Relationship

To manage and administer the prospective employment relationship, as a candidate or as an applicant, via your interaction with the Services.  

Legal and Compliance Requirements

• To maintain and improve the security and integrity of Simtra’s information databases, systems, and assets;
• To comply with government and legal requirements, including for instance record keeping and reporting;
• To exercise Simtra’s legal rights in order to defend itself, and to fulfil the employee’s rights under local employment laws.

Sale and Sharing of Personal Information 

Certain state laws regulate the “sale” of Personal Information, which may include not only the traditional selling of data, but also many sharing arrangements where the recipient can use the personal information that they receive for the recipient’s own commercial purposes.  State laws may also regulate the disclosure of Personal Information to third parties for cross-context behavioral advertising (“sharing” under the California Consumer Privacy Act of 2018).

We make certain categories of Personal Information available to third parties in order to receive targeted advertising-related services, such as when we make browsing information available (e.g., through third-party tags on our digital properties) to carry out, measure, and improve our ad campaigns and reach users with more relevant ads and content and to third-party analytics providers to help us improve our websites and your user experience. These disclosures may be considered a “sale” and “share” of personal information under applicable state law. To opt-out of these activities, please see below.

The categories of Personal Information (described above) that Simtra may use and disclose for these purposes are:

• Contact and demographic information 
• Internet or other similar network activity 

How to Opt Out:  To opt-out of the “sale” and “sharing” of your Personal Information please email [email protected] or use the contact information at the end of this policy.  We do not knowingly “sell” or “share” the Personal Information of individuals under the age of 16.  

California Privacy Rights

As a California resident, you may be afforded certain privacy rights.  In general, California residents may exercise their privacy rights with respect to their Personal Information as set forth in the table below by following the instructions set forth below.  Please note that applicable law sets forth a process to follow when evaluating your request, and there are also some exceptions to these rights.

Privacy Rights	Description
Right to Know/Access	You may have the right to confirm whether your Personal Information is being processed.  You may have the right to request that we disclose to you what Personal Information of yours has been collected, used, disclosed, and sold or shared, including, depending on your location:      The categories of Personal Information collected about you; The categories of sources from which the Personal Information is collected; The business or commercial purpose for collecting, selling, or sharing the Personal Information; The categories of Personal information, if any, that were disclosed for a business purpose or sold to third parties; The categories of third parties to whom the information was disclosed or sold; and the specific pieces of personal information collected about you.
Right to Delete	You may have the right to request deletion of the Personal Information collected about you.
Right to Correct	You may have the right to request the correction of inaccurate personal information that is maintained about you.
Right to Opt-Out of Sale and Cross-Context Behavioral Advertising	Certain laws may provide you the right to opt-out of the sale of your Personal Information and the use or disclosure of your Personal Information for cross-context behavioral advertising (i.e., “sharing” under the California Consumer Privacy Act).   Please see above for details on how to opt-out of these activities.
Automated Decision-Making	You may have the right to request information about the logic involved in certain types of automated decision-making practices and a description of the likely outcome of processes, and the right to opt out of such processes.  Your Personal Information is not subject to such automated decision-making processes.
Sensitive Personal Information	We do not use or disclose Sensitive Personal Information other than to provide our service as described above. However, if we used or disclosed Sensitive Personal Information for other purposes, you would have the right to limit certain uses of Sensitive Personal Information.
Right to Non-Discrimination	You have the right to not receive discriminatory treatment if you exercise any of the rights conferred to you by law.

 

How to Exercise Your Rights

If you are a California resident and would like to exercise any of your rights listed above, please contact us using the information below.  

You may also designate an authorized agent to make a request to exercise your rights on your behalf.   In order to do so, you must contact us using the information below.  

When contacting us to exercise your rights, please adhere to the following guidelines:

• Tell Us Which Right You Are Exercising: Specify which right you want to exercise and the Personal Information to which your request relates (if it does not relate to you). If you are acting as an authorized agent on behalf of a California resident, please clearly indicate this fact and indicate your authority to act on their behalf.
• Help Us Verify Your Identity: Contact us using the information below and provide us with enough information to verify your identity.  Please note that if we cannot initially verify your identity, we may request additional information to complete the verification process. Any Personal Information you disclose to us for purposes of verifying your identity will solely be used for the purpose of verification.
• Direct Response Delivery: Inform us of the delivery mechanism with which you prefer to receive our response. You may specify, for example, email, mail, or through your account (if you have one with us).

Please note that you do not need to create an account with us in order to make a request to exercise your rights hereunder.

Please contact us to appeal any decision made on your request.

Responses to California Resident’s Requests

Receipt of your request will be confirmed consistent with applicable law.  You will generally receive a response to your request within forty-five (45) days. However, where reasonably necessary and where permitted by law, the response time may be extended by an additional forty-five (45) days, provided you are given notice of such extension first.  If the information is provided to you electronically, it will be in a portable format and, to the extent technically feasible, in a machine readable, readily useable format that allows you to freely transmit this information without hindrance.

Please note that you will not be charged for making a request, provided that you make no more than two (2) requests per year.  Where permitted by law, your request may be denied, for example, if your requests are determined to be unfounded or excessive (e.g., repetitive in nature), or a reasonable fee may be charged. In these circumstances, you will receive a notice regarding this denial and the reason for such denial.

California Shine the Light Law:

Under California Civil Code Section 1798.83, individual customers who reside in California and who have an existing business relationship with us may request information about the disclosure of certain categories of personal information to third parties for the third parties’ direct marketing purposes, if any. To make such a request, please use the information in the Contact Information section below. Please be aware that not all information sharing is covered by these California privacy rights requirements and only information on covered sharing will be included in the response. This request may be made no more than once per calendar year.

Contact Information

To exercise one or more of your rights, or to contact us with questions and concerns about this privacy policy, please contact us at:  

Email: [email protected]

Ethics and Compliance Hotline: 1-844-294-5418