DATAMINR CANDIDATE PRIVACY NOTICE

Privacy and transparency are important to Dataminr. Dataminr respects the privacy rights of individuals and is committed to handling personal data (which is any information relating to an identified or identifiable living individual) consistent with applicable laws. This Candidate Privacy Notice (this “Privacy Notice” or this “Notice”) applies to personal data processed by or on behalf of Dataminr, Inc. and its subsidiaries and affiliates world-wide (“Dataminr”, “us”, “our” or “we”) in connection with Dataminr’s recruitment process for employment or engagement with a Dataminr company (“Recruitment Process”).

1. Applicability

This Privacy Notice applies to all job candidates (including those that may be unsuccessful in the application process) whose information is provided to us in connection with an application for employment; however, some of the clauses under this Privacy Notice apply only to EU/EEA job candidates or Australian job candidates, as identified. The term “job candidates” is used in this Privacy Notice to refer to anyone who applies for a job role, an internship, placement, or otherwise seeks to carry out work with or for us (whether on a permanent or temporary basis). If you are successful in the application process, your personal data will be transferred to your personnel file or record and thereafter will be subject to Dataminr’s Personnel Privacy Notice.

2. Data Controller.

Where applicable under data protection laws, the “data controller” in respect of any personal data processed in connection with this Privacy Notice is the company within the Dataminr group of companies which would be the employing entity in respect of the position advertised and applied for, as further detailed below:

If you live in:	then your information is controlled by:
the United States	Dataminr, Inc., 6 East 32nd Street, Floor 6, New York, NY 10016
Australia	Dataminr, Inc., 6 East 32nd Street, Floor 6, New York, NY 10016
Denmark	Dataminr Denmark ApS, Højbro Plads 10, 3. 1200 Copenhagen K
France	Dataminr France SAS, 259 rue Saint Honoré 75001 Paris
Germany	Dataminr Germany GmbH, Regus Business Center, 2nd & 3rd Floor, Putzbrunner Str. 71-73, 81739 Munich
Ireland	Dataminr Ireland Limited, 25-28 North Wall Quay, Dublin 1, D01H104
the United Kingdom	Dataminr UK Limited, 5 New Street Square, London EC4A 3TW

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3. Personal Data Processed by Dataminr.

A. Information Collected from You.

Dataminr collects and processes the personal data that you provide to Dataminr during the Recruitment Process, which may include, but is not limited to, the following:

• Identifiers and contact information, such as names (e.g., full names, nicknames, and/or preferred names), residential or home address, telephone number(s), email address(es) and other contact information for you, and your reference checks;
• Photographs, such as a headshot included on a resume/CV;
• Past employment history, such as previous employers, job titles or positions, responsibilities, experience, compensation, etc.;
• Educational or academic information, such as undergraduate studies, graduate studies, degrees obtained or earned, honors or awards received, etc.;
• Professional training or certifications;
• Job qualifications and work eligibility, such as nationality, country of residence, visa and/or immigration status, etc.;
• Government issued identification documents, such as a passport, or national identification card;
• Information that you make available through social media accounts (e.g., LinkedIn);
• Demographic information, such as gender/identity, racial or ethnicity information, military or veteran status, disability information;
• Information that you make available through your resume or CV;
• Information that may be contained in general correspondence or communication between you and Dataminr; and
• Any other information that you voluntarily make available to Dataminr during or in connection with the Recruitment Process.

B. Information Generated by Dataminr.

In connection with the Recruitment Process, we may create or generate information about you that may qualify as personal data, including, without limitation, the following:

• Interview records, such as information in connection with our evaluation about your competency, suitability, or ability for employment.

C. Information Collected About You from Other Sources.

In connection with the Recruitment Process, we may collect, and process personal data received from other sources including, without limitation, the following:

• Information provided during a reference check;
• Criminal record information obtained through a criminal records check;
• Information provided by background checking agencies and/or other external database holders (e.g., information provided by credit reference agencies, professional organizations, etc.); and
• Information provided by or through recruiting, job, or executive search agencies, firms, or companies.

D. California Consumer Privacy Act of 2018 (“CCPA”) Notice. 

For compliance with the CCPA, the above information sets out the personal information (as defined under the CCPA) and the categories of personal information that are collected, used, and disclosed by Dataminr.

E. Australian Privacy Act 1988 (“Australian Privacy Act”) Notice.

For compliance with the Australian Privacy Act, the above information sets out the personal information (as defined under the Australian Privacy Act) and the categories of personal information that are collected, used, and disclosed by Dataminr.

4. Purpose and Lawful Basis for Processing.

A. Purpose for Processing:

(1) We collect and process personal data for the following purposes:

• For the Recruitment Process, specifically to evaluate and determine your qualifications for employment or engagement and to reach a decision on your candidacy, which includes assessing your skills and qualifications, verifying your information, carrying out checks (where applicable) (e.g., background checks, reference checks, criminal history checks, etc.), and generally managing the hiring or engagement process.

• For the monitoring and promoting of equal opportunities and reporting on the same, both internally and externally, as appropriate.

• For compliance with legal, regulatory and professional requirements.

• For exercising our right to defend, respond to or conduct legal proceedings and to protect our interests and property and the interests and property of others.

• To communicate with you regarding potential job opportunities if you have either signed up to receive such communications or otherwise shown an interest or desire to receive such communications from us.

(2) CCPA Notice.

The above purposes for the collection, use, and disclosure of personal information are for a business purpose (as defined under the CCPA). Dataminr does not sell (as defined under the CCPA) your personal information.

B. Lawful Basis for Processing:

Where applicable data protection law requires a lawful or legal basis for the processing of personal data, Dataminr’s lawful or legal basis for the processing of your personal data shall be as follows:

• Processing necessary for compliance with a legal obligation to which we are subject, such as immigration and employment laws;

• Processing necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;

• With your consent in certain situations, such as when you are registering or signing-up to receive communications from us (e.g., alerts regarding job opportunities);

• Processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in Dataminr;

• Processing necessary for the purposes of the legitimate interest pursued by us or a third party, which are not overridden by your data protection interests or fundamental rights and freedoms taking into consideration the safeguards that we put in place, such as described in the Purpose for Processing section above; and

• Processing to protect the rights and interests of Dataminr, our employees, contractors, applicants, and others, as required and permitted under applicable law.

5. What happens if you do not provide information?

If you do not provide us with certain information when requested, we may not be able to process your application for employment.

6. Recipients of Your Personal Data.

We may disclose your personal data to members of our corporate group including, without limitation, for the following reasons: in order to, run global processes, carry out groupwide reporting, or take decisions about hiring.  It may be necessary from time to time for us to disclose your personal data to third parties or agents, including without limitation to the following:

• Third parties or agents of clients to assist in the administration, processing and management of certain activities pertaining to prospective employees including job posting websites and external reference agencies (such as employee vetting and screening agencies);

• Individuals or companies employed by Dataminr to carry out specific services, functions or consultancy work and other financial institutions;

• Regulatory bodies to whom we are obliged or required to disclose information, courts and court-appointed persons;

• Potential purchasers or bidders;

• Relevant government departments and agencies; and

• Other support service providers necessary to support the organisation in the services listed. 

When we share personal data, we take care to (i) only share the personal data that is necessary for the purpose for which the personal data is shared, (ii) only allow access to those who require access to perform or provide a task, activity or service, and (iii) ensure that the sharing is consistent with the purposes described in Section 4 (Purpose and Lawful Basis for Processing) of this Privacy Notice.

7. International Transfer of Personal Data.

Due to the global nature of our business, we may transfer your personal data outside of the country in which you reside (including, if you reside in the United Kingdom (“UK”) or in the European Union (“EU”)/European Economic Area (“EEA”)) to other countries including, without limitation, to the United States. The transfer of personal data may be to companies within the Dataminr group and/or to third party service providers or processors who are providing services in connection with our processing of your personal data. For international transfers of personal data of a data subject who resides in the UK or EU/EEA to a country that has not received an adequacy determination, we have implemented appropriate contractual protections to ensure that the transfer of personal data is in accordance with applicable data protection laws.

8. Special Categories of Personal Data

Certain personal data are regarded as “special” (or “sensitive” data under applicable data protection and privacy laws). These include data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as genetic, biometric, and health data, and data concerning your sex life or sexual orientation. We only process such data where necessary for carrying out the obligations, and exercising specific rights, of Dataminr or of you under employment law, or for the assessment of your working capacity or to facilitate or make arrangements for you to attend an interview or meeting with Dataminr. If we wish to process your special/sensitive personal data for any other purpose, we will seek your explicit consent to do so. You have the right to withdraw your consent to that processing at any time. We will only process data relating to a job candidate’s criminal convictions or involvement in criminal proceedings when permitted by law, or when provided voluntarily by a job candidate.

9. Security and Storage of Personal Data.

Dataminr takes the security of personal data seriously and we use appropriate technologies, security controls, and procedures to protect personal data (including administrative, technical, and physical safeguards) according to the risk level and the service provided. While we use means to protect your security as described above, data transmission over the internet cannot always be guaranteed to be one hundred percent (100%) secure. We cannot and do not warrant the security of any personal data you transmit, and all such transmissions are done at your own risk.

Our information security policies and procedures are closely aligned with widely accepted international standards and are reviewed regularly and updated as necessary to meet the sensitivity of the personal data we handle, our business needs, changes in technology and regulatory requirements.

10. Data Retention.

We keep your personal data for no longer than necessary to fulfil the purposes for which it is processed or as otherwise required under applicable laws. The length of time for which we retain personal data depends on the purposes for which we collected and processed it and/or as required to comply with applicable laws. As an alternative to deletion, we may anonymize data for compliance with reporting and analytic purposes. Where there are technical limitations that prevent deletion or anonymization, we safeguard personal data and limit active use of it.

11. Your Data Rights.

Depending on your jurisdiction of residence, and subject to applicable data protection laws, you may have certain rights pertaining to your personal data and Dataminr’s processing of such personal data. These rights are not absolute, meaning that the rights may not apply in all situations, and we may not be required to fulfill or comply with all rights requests.

Depending on your jurisdiction of residence (e.g., Europe, Australia, California) you may have certain rights in relation to your personal data, such as to:

• access a copy of your personal data held by us;
• request rectification of your personal data if it is inaccurate or incomplete;
• request erasure of your personal data in certain circumstances;
• restrict our use of your personal data in certain circumstances;
• move (or port) personal data which you have given us to process on the basis of your consent or for automated processing; and
• object to the processing of your data where our legal basis for processing your data is our legitimate interests.

If you wish to exercise your rights under applicable data protection law(s), please submit your request via our online webform available here. We will process rights requests in accordance with the requirements under applicable data protection laws. We may need to request additional verification of your identity in order to process your request.

Dataminr does not discriminate against an individual for the individual exercising rights under applicable data protection laws.  

12. Complaints.

If you have a complaint regarding this Privacy Notice and/or Dataminr’s data protection/privacy practices, we would prefer to have you initially raise the complaint to Dataminr (using the contact details in Section 12 (Contact Us) of this Privacy Notice), and if we are not successful in resolving or addressing the complaint, then you can proceed with lodging a complaint with the applicable data protection authority or regulator. Notwithstanding the foregoing, Dataminr acknowledges that you may have the right under applicable data protection laws to lodge or file a complaint directly with the applicable data protection authority or regulator.

A list of National Data Protection Authorities in the EEA can be found here. For the Information Commissioner’s Office in the United Kingdom, please visit https://ico.org.uk/.

If you are a resident of Australia, you have the right to lodge a complaint with the Office of the Australian Information Commissioner (OAIC). You can visit their website at www.oaic.gov.au.

13. Further Information.

Please see our Privacy Policy for further information about how we handle personal data.

14. Contact Us.

If you have any questions or complaints regarding your personal data, our processing of your personal data, and/or this Privacy Notice, please contact us as follows:

Via mail or post at:

Dataminr Privacy
Dataminr, Inc.
6 East 32nd Street
Floor 6
New York, New York 10016
United States

Or

via email at: [email protected]

For candidates located outside of the United States, the Dataminr entity to which you applied for a job with is the data controller of your personal data; however, questions or complaints may still be directed to [email protected].

15. Changes to This Privacy Notice.

This Privacy Notice will not form part of any potential employment contract and we may change it from time to time.

Last Updated: September 19, 2024