Applicant and Candidate Privacy Policy
 

Purpose

The purpose of the FRSecure Applicant and Candidate Privacy Policy is to explain what information we collect during our application and recruitment process, why we collect it, and how we use that information.

Audience

The FRSecure Applicant and Candidate Privacy Policy applies to any individual candidate that applies for a position at the company.
 

Policy

Types of information we may collect:

• Your name, address, email address, telephone number and other contact information.
• Your resume or CV, cover letter, previous and/or relevant work experience or other experience, education, transcripts, or other information you provide to us in support of an application and/or the application and recruitment process.
• Information from interviews and phone screenings you may have, if there is any.
• Details of the type of employment you are or may be looking for, current and/or desired salary and other terms relating to compensation and benefits packages, willingness to relocate, or other job preferences.
• Details of how you heard about the position you are applying for.
• Any sensitive and/or demographic information processed during the application or recruitment process such as gender, information about your citizenship and/or nationality, medical or health information (disclosed for accommodation purposes only), and/or your racial or ethnic origin.
• Information received from background checks, including social security number, addresses from previous 7 years or anything further provided by the applicant, criminal history, or driving records.
• Information relating to any previous applications you may have made to FRSecure and/or any previous employment history with FRSecure.
• Your information from publicly available sources, including online, that we believe is relevant to your application or a potential future application (e.g. your LinkedIn profile).
• Information related to any assessment you may take as part of the interview screening process.

How we may use information we collect

• Assessing your skills, qualifications and interests against our career opportunities.
• Verifying your information and carrying out reference checks and/or conducting background checks (where applicable) if you are offered a job.
• Communications with you about the recruitment process and/or your application(s), including, in appropriate cases, informing you of other potential career opportunities at FRSecure.
• Creating and/or submitting reports as required under any local laws and/or regulations, where applicable.
• Making improvements to FRSecure’s application and/or recruitment process.
• Complying with applicable laws, regulations, legal processes or enforceable governmental requests.
• Proactively conducting research about your educational and professional background and skills and contacting you if we think you would be suitable for a role with us.
• We may process information regarding your demographics as described above where we are required to do so to meet our legal and contractual obligations, such as reporting obligations to authorities and third parties and other similar requirements.

Who may have access to your information

• Your information may be shared with our affiliates, subsidiaries or joint ventures in the US and in other jurisdictions, in relation to the purposes described above. If you have been referred for a job at FRSecure by a current FRSecure employee, with your consent, we may inform that employee about the progress of your application and let the FRSecure employee know the outcome of the process. In some cases, if it is identified that you have attended the same university/school or shared the same previous employer during the same period as a current FRSecure employee we may consult with that employee for feedback on you.
• FRSecure may also use service providers acting on FRSecure’s behalf to perform some of the services described above including for the purposes of the verification / background checks. These service providers may be located outside the country in which you live or the country where the position you have applied for is located.
• FRSecure may sometimes be required to disclose your information to external third parties such as to local labor authorities, courts and tribunals, regulatory bodies and/or law enforcement agencies for the purpose of complying with applicable laws and regulations, or in response to legal process.
• We will also share your personal information with other third parties if we have your consent (for example if you have given us permission to contact your referees), or to detect, prevent or otherwise address fraud, security or technical issues, or to protect against harm to the rights, property or safety of FRSecure, our users, applicants, candidates, employees or the public or as otherwise required by law.

Our retention of your information

If you apply for a job at FRSecure and your application is unsuccessful (or you withdraw from the process or decline our offer), FRSecure will retain your information for a period after your application. We retain this information for various reasons, including in case we face a legal challenge in respect of a recruitment decision, to consider you for other current or future jobs at FRSecure and to help us better understand, analyze and improve our recruitment processes.
 

If you do not want us to retain your information for consideration for other roles, or want us to update it, please contact hr@frsecure.com. Please note, however, that we may retain some information if required by law or as necessary to protect ourselves from legal claims.
 

How we protect your personal information

We have implemented a variety of technical, physical, and organizational measures to protect your personal information from misuse or accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure, acquisition, or access, as well as all other forms of unlawful processing. To achieve this, we have developed and implemented information security policies and other sub-policies and guidelines relating to the protection of your personal information. We also have a rigorous implementation and approval process for the introduction then subsequently use of any tool, application, software, or resource in which applicant or candidate data flows through.
 

Changes to this policy

We may change this policy from time to time. We will post any changes to this policy on this page.

U.S. state law requirements

Some U.S. state privacy laws, such as the California Consumer Privacy Act (CCPA), require specific disclosures for state residents.

This policy is designed to help you understand how FRSecure handles your information. In the sections above, we explain: (1) the categories of information FRSecure collects and the sources of that information; (2) how FRSecure uses information; (3) when FRSecure may disclose information; and (4) how FRSecure retains information. FRSecure does not sell your personal information. FRSecure also does not “share” your personal information as that term is defined in the CCPA.
 

State laws like the CCPA also provide the right to request information about how FRSecure collects, uses, and discloses your information. And they may give you the right to access and correct your information, and to request that FRSecure delete that information. Finally, the CCPA provides the right to not be discriminated against for exercising these privacy rights.
 

If you have questions or concerns related to your rights under CCPA, or would like to exercise your rights, you (or your authorized agent) can contact FRSecure at hr@frsecure.com. We’ll validate your request by verifying your interactions with FRSecure, and may require that you provide us with additional information, such as any names, phone numbers or email addresses you have used when communicating with us.
 

The CCPA also requires a description of data practices using specific categories. This table uses these categories to organize the information in this policy.
 

Categories of information we may collect

Identifiers and similar information, such as your name, phone number, and address; username and password; and unique identifiers tied to the browser, application, or device you’re using.
 

Demographic information, such as your age, gender, and language(s) spoken. If you choose, you may also provide additional information, like your racial or ethnic origin, religious or philosophical beliefs, trade union membership, or sexual orientation.
 

Financial information, such as your current and/or desired salary and other terms relating to compensation and benefits packages.
 

Internet, network, and other activity information in connection with your use of FRSecure accounts, systems, and services, such as your search terms; views and interactions with content; and information about the interaction of your apps, browsers, and devices with FRSecure services (like IP address, crash reports, and system activity).
 

Geolocation data, including as determined by IP address, depending in part on your device and account settings.

Audio, electronic, visual, and similar information, such as information transmitted in connection with interviews or phone-screenings you may have, if any.
 

Communications data, such as emails that you may send or receive in connection with the application or recruitment process.
 

Health information, if you choose to provide it, in connection with the application or recruitment process, such as data you may provide in connection with an accommodations request.
 

Professional, employment, and education information, such as information you provide in connection with the application and recruitment process, as well as information FRSecure may otherwise collect through reference checks, criminal and financial background checks (where applicable) and information from publicly available sources, including online, that may be relevant.

Other information you create or provide, such as the content you create, upload, or otherwise provide in connection with the application and recruitment process.
 

Inferences drawn from the information above.
 

Business purposes for which information may be used or disclosed

Administrative purposes: FRSecure uses and may disclose information for purposes related to carrying out its application and recruitment process, including for assessing candidates; verifying information and conducting reference checks and criminal and financial background checks (where applicable); communicating with you; responding to requests for assistance with obtaining an immigration visa or work permit (where required); and other related activities.

Protecting against security threats, abuse, illegal activity, and violations: FRSecure uses and may disclose information to detect, prevent and respond to security incidents, and for protecting against other malicious, deceptive, fraudulent, or illegal activity. For example, to protect our services, FRSecure may receive or disclose information about IP addresses that malicious actors have compromised.
 

Auditing and measurement: FRSecure uses information for analytics and measurement to understand use of FRSecure accounts, systems, and services.
 

Maintaining our services: FRSecure uses information to ensure our equipment, accounts systems, and services are working as intended, such as tracking outages or troubleshooting bugs and other issues.

Research and development: FRSecure uses information to improve our application and recruitment process.
 

Use of service providers: FRSecure shares information with service providers to perform services on our behalf, in compliance with this privacy policy and other appropriate confidentiality and security measures. For example, we may rely on service providers to help perform criminal and financial background checks.
 

Legal reasons: FRSecure also uses information to satisfy applicable laws or regulations, and discloses information in response to legal process or enforceable government requests, including to law enforcement.

Parties with whom information may be disclosed

Other people with whom you choose to share your information, such as the content you create, upload, or otherwise provide in connection with the application and recruitment process.
 

Third parties with your consent, for example if you have given us permission to contact your references.
 

Service providers, trusted businesses or persons that process information on FRSecure’s behalf, based on our instructions and in compliance with this privacy policy and any other appropriate confidentiality and security measures.
 

Law enforcement or other third parties, in response to legal process or enforceable government requests, and as necessary to identify, report on and investigate violations of applicable laws and regulations.
 

Version History

Version: 1.0.0

Modified Date: May 2025

Approved Date: May 2025