Simtra Recruitment Platform Privacy Notice (EN)

Last updated: January 25, 2024

Thank you for visiting the Simtra Recruitment Platform (the “Service”), a tool for Simtra’s online job vacancy notification, talent community, and application process. This Privacy Notice (“Notice”) serves to inform you about how Simtra¹ (“we,” “our,” or “us”) collects, stores, processes, uses, and discloses your personal information when you use and interact with the Service and during our offline interactions related to the recruitment process.

For information about Simtra’s privacy practices in other contexts, please see Simtra’s Global Privacy Statement at https://biopharmasolutions.baxter.com/global-privacy-policy. If you later become an employee of Simtra, you will receive a separate notice describing how we will use your personal information as an employee.

The Service is not intended for children under 18 years of age. If you believe we may have inadvertently collected the personal information of someone under 18, please contact us using the contact details provided near the end of this Notice.

The Data Controller

Simtra is the data controller under applicable data protection law for any personal information collected, processed, used, disclosed, or transferred in connection with the Service or related to the recruitment process.

The Personal Information We Collect

To provide the Service and for the other purposes described in this Notice, we receive and collect certain information from you, including personal information (also referred to as “personally identifiable information” or “personal data” in some jurisdictions). For purposes of this Notice, “personal information” means information about, or that relates directly or indirectly to, an identified or identifiable individual (as determined by applicable laws). 

Simtra may collect, process, store, and share the following types of personal information when you engage with the Service and throughout the recruiting process:

• Identifiers and contact details
  • Full name and any aliases or nicknames,
  • Postal addresses, email addresses, phone numbers, fax numbers, social networking site user or account names, or other addresses at which you can receive communications,
  • Your emergency contact details, and
  • Your driver’s license number, passport number, national ID number, Social Security number, or other government identification number.
• Demographic information
  • Your age, date of birth, and gender,
  • Nationality, place of birth, and, where permitted by local law and you choose to disclose it, your race or ethnicity, and
  • Military service information and veteran status.
• Professional, employment, educational, and background information
  • Your educational background and transcripts,
  • Language skills,
  • Employment history, status, and other information included in your resume or CV,
  • Qualifications, certifications, skills, and special competencies,
  • Salary and contract expectations,
  • Reasons for prior terminations,
  • The names of relatives working at Simtra or individuals who may have referred you to a position, and,
  • Where permitted by local law, criminal background check information.
• Citizenship and visa information
  • Citizenship country and status,
  • Visa information including issuing country, status, type, effective date, and expiration date, and
  • Current work status to work in a particular country and whether you require sponsorship.
• Preferences and other characteristics
  • Your career interest areas and preferences,
  • Preferred work location and department,
  • Willingness to travel or relocate, and
  • Preferences regarding the types of information or communications you would like to receive from Simtra.
• Internet or other electronic network and device information
  • Your username and password for the Service,
  • The IDs and IP addresses of the devices you use to access the Service, and
  • Analytics data about your use of the Service, such as the dates and times you access the Service, browsing behavior, and other interactions with the Service, including data from cookies.
• Audio, video, and pictures
  • Recordings of your video interviews, to the extent you provide consent to these recordings, and
  • Security footage that may include your image if you visit one of our facilities.
• Health information
  • Any disability that you self-identify for which you require accommodation, and
  • Where permitted by local law, drug test results.
• Other information you choose to provide us through your responses to our questions, supporting documentation attached to your application, or other interactions where you volunteer to share personal information.

How We Collect Personal Information

We may collect personal information about you in any of the following ways:

• When you submit it to us via the Service or during other online or offline interactions. For example, when you fill out a job application or candidate profile, contact us regarding the Service or an application, or provide information during an interview.
• From the devices you use to access the Service, which may provide technical information to us via technologies such as cookies, web beacons, pixels, tags, and widgets. Please see the Cookies and Similar Technologies section below to learn more about the specific technologies used on the Service and how to adjust your preferences for these technologies.
• From our vendors and service providers, such as our hosting partner for the Service, analytics providers, and advertisers, who may provide us with information about you or your use of the Service. We may also access information about you from service providers, such as our background check and drug test providers, to the extent permitted by applicable law.
• From third parties, such as your former employers or other references you provide.
• From publicly available information, including employment eligibility information and the information you choose to post publicly on social media. 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.

How We Use Personal Information

When you apply for a job with Simtra or otherwise use the Service, we may use your personal information for the following purposes:

• To process your employment application, including collecting relevant employment and skills data, assessing your suitability for the role, scheduling and holding conversations or interviews with you, and communicating with you about the status of your application and our hiring decisions.
• To perform criminal background checks where permitted by law.
• To suggest job vacancies that may meet your skills or interests.
• To store your candidate profile information for future job applications and to meet our legal retention obligations, as described in the Personal Information Retention section below.
• To send you alerts and newsletters about career opportunities with Simtra.
• To respond to your inquiries and requests.
• To comply with applicable laws and our legal obligations. We may use your personal information to comply with applicable laws, regulations, industry codes of conduct, and Simtra’s internal policies and procedures, including:
  • For compliance with applicable retention obligations.
  • To detect, prevent, or otherwise address fraud, security, or technical issues.
  • To respond to lawful requests by public authorities (e.g., to investigate fraud or respond to a government request).
  • To investigate potential breaches.
  • To protect our rights, property, safety, and those of our users.

How and When We Share Personal Information

We share personal information with our affiliates and subsidiaries for the purposes described in this Notice. We may also share your personal information with third-party service providers that we hire to perform various services and functions for us, such as providing the Service, data storage, and financial, legal, and marketing services. Your information will only be shared subject to an agreement with Simtra that permits the service provider to use personal information only to provide the agreed services on our behalf.

We may also transfer, share, or otherwise permit access to your personal information in the following circumstances:

• With law enforcement or governmental agencies to comply with a court order, law, or legal process, including to respond to any lawful government or regulatory request.
• With a business transition partner in the event we go through a business transition such as a merger, acquisition by another company, bankruptcy, reorganization, or sale of all or a portion of Simtra’s assets.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Simtra, our customers, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

Greenhouse Software, Inc.

The Service is hosted and provided by Greenhouse Software, Inc. (“Greenhouse”) on behalf of Simtra. When you visit or share personal information with the Service, your personal information will be processed according to Greenhouse’s privacy policy, which is on their website at https://www.greenhouse.com/privacy-policy. 

Cookies and Similar Technologies

The Service uses the technologies described below to collect technical information to provide, secure, and maintain the Service, to personalize your experience, and to analyze and improve the Service.

• Cookies: Small files that are transferred to your device’s hard drive to store user preferences and other types of information to help us provide you with certain features.
• Web Beacons or Pixels:  Electronic images placed in the code of a webpage, application, or email that allow us to monitor things such as user activity and site traffic.
• Tags: Pieces of code, or tags, which gather information about users. For example, tags are used on our websites to better understand online usage patterns and trends.
• Widgets: Small components embedded within the Service that enable you to use certain functionalities. 

These technologies are managed on Simtra’s behalf by Greenhouse, which provides the Service. To learn more about the specific technologies used on the Service, please refer to Greenhouse’s cookie notice at https://www.greenhouse.com/cookie-notice.

Sale and Sharing of Personal Information with Third Parties

We do not sell personal information for monetary or other valuable consideration. We also do not share personal information for behavioral advertising purposes, including cross-context behavioral advertising. We do not use sensitive personal information for inferring characteristics about individuals. We do not use automated processing of personal information for profiling purposes.

Links to Third-Party Sites

The Services may provide links to other websites or resources over which Simtra does not have control (“External Websites”), including links to our social media pages. Such links do not constitute an endorsement by Simtra of those External Websites. Simtra is providing these links to you only as a convenience and is not responsible for the content of such External Websites. Your use of External Websites is subject to the terms of use and privacy policies located on those External Websites. We encourage you to read the privacy policy of any website you visit before providing any information to the operator of that website.

Legal Bases to Process Personal Information

Simtra will only use or process your personal information if the use or processing is permitted by applicable privacy laws in your jurisdiction. This is sometimes referred to as having a “legal basis” to use or process your personal information. The legal basis Simtra may rely on to process your personal information may include:

• With Your Consent, such as if you choose to receive marketing communications from us, permit us to collect certain personal information like your race or ethnicity, request that we retain your candidate profile for an extended period, or permit the collection of your personal information through cookies and similar technologies.
  • If you provide your consent, you may withdraw your consent at any time by contacting us using the contact details listed at the end of this Notice. Revoking your consent will not affect the lawfulness of our handling and processing of your personal information based on your consent before its withdrawal.
• Our Legitimate Interests. We have a legitimate business need to manage, operate, maintain, and secure the Service, our network systems, and other assets. We may also process personal information for our legitimate business interest in filling our job vacancies with qualified candidates. We believe that our legitimate interests are not outweighed by your rights and freedoms under applicable law. If you wish to object to processing based on legitimate interests, please get in touch with us using the contact information listed below.
• When Necessary to Meet Our Legal Obligations. We may process personal information as required by law, including to respond to lawful requests by public authorities (e.g., to investigate fraud or respond to a government request).
• To Protect Vital Interests. We may process personal information where it is necessary to protect the life or imminent safety of you or another individual, where no other legal basis applies.

International Data Transfers

When you apply for a job with Simtra or otherwise use the Service, we may transfer, store, or access your personal information in a location outside of your country where data protection laws may be less strict than the laws in your country. Any transfers of personal information to Simtra affiliates or third parties outside your local country will be conducted in compliance with the international data transfer restrictions that apply under applicable data protection laws. We take legally required measures to ensure that adequate safeguards are in place to protect your personal information in accordance with applicable privacy laws and this Notice.

When you use the Service, Greenhouse may store or process your personal information in Germany and the United States. Greenhouse has certified to the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework to ensure the protection of personal information transferred between these regions and the United States.

How We Secure Personal Information

We have reasonable and appropriate security measures in place to protect against the loss, misuse, and alteration of any personal information we receive about you. We maintain reasonable security standards to protect the personal information that we maintain. If you have any questions about the security of your personal information, please get in touch with us using the contact information provided below.

Personal Information Retention

If your application for a job is successful and you become an employee of Simtra, we will retain your personal information as described in the Simtra Employee Privacy Notice you will receive when hired.

In all other cases, we will only retain your personal information until the purpose for which it was collected has been accomplished or as otherwise required by applicable law. We retain personal information collected for the purposes described in this Notice for 3 years after we receive it.

Do Not Track

Certain laws require us to indicate whether we honor “Do Not Track” settings in your browser concerning targeted advertising. As of the effective date of this Notice, Simtra does not respond to such signals. Instead, we adhere to the standards set out in this Notice.

Your Privacy Rights

Some privacy laws provide certain rights to individuals regarding their privacy and personal information. Simtra respects your rights concerning your personal information.

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

• Withdraw Consent. If we use or share your personal information based on your consent, you may withdraw your consent at any time by contacting us using the contact information listed below. To withdraw your consent to receive marketing communications from Simtra, you may alternatively follow the unsubscribe process described in the message.
• Access. You may request access to or copies of your personal information. You may also request information about what types of personal information we have, the purposes for which we process it, and who has received access to or a copy of your personal information. 
• Correction and Deletion. You may request that we correct your personal information if you think it is inaccurate or incomplete. You can also request that we erase or delete your personal information in certain circumstances. 
• Restrict Processing. You may request that we restrict the processing of certain personal information.
• Data Portability. You may request that we provide you with your personal information in a machine-readable format, 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 information for certain purposes. 

You may request to exercise your rights at any time by contacting us using the contact information listed below. You will not receive discriminatory treatment if you exercise any of the rights conferred to you by law. Please note that, depending on the circumstances and where you are located, not all of the below rights may be available to you.

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. Please contact us as described below to appeal any decision made regarding your request.

Lodging a Complaint

If you believe we are using, disclosing, or otherwise processing your personal information in a way that is not in accordance with applicable law, you can lodge a complaint with the relevant data protection authority in your state, country, or region.

Changes to this Notice

We may periodically update this Notice to describe changes to our collection and use of personal information. If we make material changes to this Notice, we will post a notice of the material changes on our website. If we use your personal information for other purposes not specified in this Notice, we will notify you and, where required, obtain your consent. We encourage you to periodically review this Notice for the latest information on our privacy practices.  

Contact Information

If you would like to exercise your privacy rights or have questions or concerns about this Notice, our information handling practices, or any other aspect of the privacy and security of your personal information, please get in touch with us using the information below.

Email: [email protected]

Data Protection Officer: Adrian Vornwald | [email protected]

Ethics and Compliance Hotline: US 1-833-221-2651 | Germany +49 (0)80 01 824 463 | www.simtraethicspoint.com