Privacy Statement for Applicants

Last Modified:

May 27, 2021

Last Updated: May 27, 2021

This Privacy Statement is applicable to European Union and California candidates.

This Privacy Statement for Applicants (the “Privacy Statement’’) sets out the basis on which Crossbeam and its affiliates (collectively “Crossbeam”, “we”, “us” and “our”) will process the Personal Data of job applicants (the “Applicants”, “you”).

Please read this Privacy Statement carefully because it explains important information about the processing of your Personal Data by Crossbeam, including your rights with respect to your Personal Data. We may amend this Privacy Statement at any time and advise you to consult this Privacy Statement on a regular basis to ensure you stay informed of any such amendments. If you are a California resident, please be sure to review the information provided in Annex 1: California Applicant Privacy Notice.

1. What is covered by this Privacy Statement?

This Privacy Statement applies to the processing of Personal Data. For the purpose of this Privacy Statement, “Personal Data” means any information relating to an identified or identifiable person, and “processing” means any operation or set of operations which is performed on that Personal Data.

2. The Types of Personal Data We Collect

The Personal Data that an Applicant provides includes the following categories of information:

Contact details including name, mailing address, e-mail address and phone number;

Information you provide in your CV or on an application form including your education, professional and training history, and details of any other relevant skills, such as language capability;

Any other information you choose to share with Crossbeam, including in your CV or cover letter;

As appropriate, copies of certificates, diplomas or other documentation verifying the information you provide to us;

Information captured as part of the application process, including interview notes and internal communications; and

Right to work information including information required to confirm your right to work in the country in which you will be employed, including as appropriate your nationality, national identity number and passport details.

We may also collect information from third parties, including:

References from professional referees on request;

Information provided to us by recruitment agencies or other referring parties;

Information from third party talent prospecting services, and

Information made publicly available by you via LinkedIn.

To the extent permitted by applicable law, Crossbeam may compile Personal Data about an Applicant obtained through a background check.

3. Why We process Your Personal Data

Crossbeam processes the Personal Data of Applicants to identify and hire talented individuals whose skills, experience and character align with Crossbeam’s vision, in particular:

negotiating and communicating with you in relation to your application;

reviewing your suitability for joining Crossbeam, seeking references and conducting any appropriate checks;

undertaking efficiency and recruitment efficacy analytics;

workforce planning;

candidate prospecting;

preventing illegal working; and

carrying out equal opportunities monitoring.

We may also analyze your Personal Data or aggregated/pseudonymized data to improve our recruitment and hiring process and augment our ability to attract successful candidates. In addition, in the event of a reorganization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business, we may disclose or transfer your Personal Data.

We may desire to retain your Personal Data to consider you for future employment opportunities. The basis of this form of processing is your consent. If you do not want us to retain your information for such opportunities, please let us know.

We process the Personal Data of Applicants on the basis of several legal justifications:

For Contractual Purposes: Crossbeam and Applicants are working together with a view to potentially entering into a contractual relationship. For successful Applicants, Crossbeam will make a formal offer of employment that will generally require the preparation of contractual terms.

For our Legitimate Interests: Crossbeam has a legitimate interest in hiring talented people who will support our vision and play a key role in our success.

To Fulfill a Legal Obligation: Certain laws and regulations may require Crossbeam to process the Personal Data of Applicants in order to comply with our legal or regulatory obligations.

4. How We Share Your Personal Data

Crossbeam may share the Personal Data of Applicants internally for the purposes described above. We may also share your Personal Data with other parties who provide products or services to us, such as the provider of our recruitment software.

In addition, we may disclose your Personal Data to third parties where it is in our legitimate interest to do so, including to a potential buyer or seller of any business or assets, and to government/ state related agencies where we are under a duty to disclose or share your Personal Data in order to comply with a legal obligation.

5. How We Transfer Your Personal Data

We may transfer your Personal Data outside of the EEA, to countries that do not offer an equivalent level of protection. Regardless of where your Personal Data is transferred, we shall ensure that relevant safeguards are in place to afford your Personal Data adequate protection. Further details regarding the relevant safeguards can be obtained from us on request.

6. Your Data Protection Rights

If you are located in the European Economic Area, you may have the right to:

Request access to and receive information about the Personal Data we maintain about you, to update and correct inaccuracies in your Personal Data, to restrict or to object to the processing of your Personal Data, to have the information anonymized or deleted, as appropriate, or to exercise your right to data portability to easily transfer your Personal Data to another company. In addition, you may also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.

Withdraw any consent you previously provided to us regarding the processing of your Personal Data, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal.

These rights may be limited in some circumstances by local law requirements.

You may exercise these rights at any time by contacting us through this form or via email at privacy@crossbeam.com. You may be required to provide documentation to Crossbeam on request to demonstrate your identity.

7. Security and Data Retention

We maintain administrative, technical and physical safeguards designed to protect the Personal Data you provide or we collect against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

Crossbeam stores all Applicants’ Personal Data for as long as necessary to fulfil the purposes set out in the Privacy Statement, or for as long as we are required to do so by law or in order to comply with a regulatory obligation.

8. Data Controller and How to Contact Us

Crossbeam is the entity responsible (data controller) for the processing of your Personal Data as described in this Privacy Statement.

If you have any questions about this Privacy Statement or wish to exercise your rights, you may contact Crossbeam at privacy@crossbeam.com.

If you have any questions, comments or concerns about our processing activities, or you would like to exercise your privacy rights, please email us at privacy@crossbeam.com or write to us at:

Crossbeam, Inc.

Attn: Head of Legal

1315 Walnut Street, Suite 300

Philadelphia, PA 19107

Annex 1: California Applicant Privacy Notice

We comply with the California Consumer Privacy Act (“CCPA”).

Use of Personal Data

We collect and use your Personal Data in accordance with the specific business and commercial purposes described in Section 3: Why We process Your Personal Data in the above Privacy Statement.

Your California Privacy Rights

What Categories of Applicant Information Do We Collect and How Do We Use This Information

We collect the following categories of Personal Data for the purposes described below:

Category of Personal Data	Personal Data Collected	Purpose
Personal Identifier	Alias Email address Address Social security number Date of birth	We collect personal identifiers to process job applications, to conduct a background check, and for general human resources purposes.
Records identified by State law (including the California Customer Records statute (Cal. Civ. Code § 1798.80(e)))	Telephone number Education Employment history	We collect this information to process job applications, and for general human resources purposes.
Protected Classification Characteristics under State or Federal Law	Race National origin Citizenship Physical or mental disability Sex (including gender) Gender identity Gender expression Veteran or military status	We collect equality and diversity information through voluntary self-disclosure and other means to implement Our diversity programs, and to comply with applicable laws.
Geolocation Data	Physical location	We collect this information for general human resources purposes.
Professional or Employment-Related Information	Current or past job history or performance evaluations Performance management information, such as employment status (full-time or part-time, regular or temporary) Work schedule Job assignments Hours worked Accomplishments and awards Training and development information Discipline and counselling information Employment termination information	We collect professional and employment-related information to process job applications, assess and evaluate your candidacy, and for general human resources purposes.

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 legal claims. We collect this information to comply with legal and contractual requirements and to establish, exercise, and defend legal and contractual rights and claims.

Right to Know and Access. You may submit a verifiable request via this form for information regarding the: (1) categories of Personal Data collected or disclosed by us; (2) purposes for which categories of Personal Data are collected or sold by us; (3) categories of sources from which we collect Personal Data; and (4) specific pieces of Personal Data we have collected about you during the past twelve months. Please contact privacy@crossbeam.com to access this information.

Right to Delete. Subject to certain exceptions, you may submit a verifiable request that we delete Personal Data about you that we have collected from you. Please use this form or email privacy@crossbeam.com to submit a deletion request.

Verification. Requests for access to or deletion of Personal Data are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations.

Right to Opt Out. In some circumstances, you may opt out of the sale of your Personal Data. Please use this form or contact privacy@crossbeam.com to request this.