Job Applicant Privacy Notice

1. Scope

This Applicant Privacy Notice applies to personal information that we collect, online and offline, about individuals who apply for a position with H1, are recruited by or referred to H1, or otherwise participate in our recruiting process, including candidates for employee, intern, and contractor roles.

This Applicant Privacy Notice does not apply to information about current or former H1 employees, to users of our website and Services, or to the healthcare professionals and other Experts whose information appears in the H1 platform. Those individuals should refer to our Privacy Policy or to the applicable internal H1 privacy notice. If you are hired, information collected about you during the recruiting process may become part of your personnel file and will be handled in accordance with our employee privacy notice.

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2. Information We Collect

The information we collect depends on the role you apply for, the stage of the process you reach, and where you are located. We may collect the following categories of personal information:

• Identifiers and contact information, such as your name, email address, phone number, postal address, and the username associated with any account you create in our applicant system.
• Professional and employment information, such as your resume or CV, cover letter, employment history, job titles, skills, certifications, professional licenses, references, and links to professional profiles (for example, LinkedIn) or portfolios you choose to share.
• Education information, such as schools attended, degrees and credentials earned, and transcripts where relevant to the role.
• Application and assessment information, such as your answers to application questions, interview notes, interviewer feedback and evaluations, results of any skills assessments or work samples, and correspondence with our recruiting team.
• Compensation and preferences, such as desired salary or compensation (where permitted by law to ask), preferred work location, willingness to relocate, and start date availability.
• Work authorization information, such as your citizenship, immigration or visa status, and whether you require sponsorship to work in the relevant country.
• Background check information, such as the results of identity, employment, education, and, where permitted by law, criminal history checks, as described in Section 5.
• Accommodation information, such as information you choose to provide about a disability or other condition so that we can provide a reasonable accommodation during the recruiting process.
• Technical information, such as IP address, browser type, and device information collected when you use our careers website or applicant system, as described in the “Cookies and Similar Technologies” section of our Privacy Policy.
• Other information you choose to provide, such as information included in your resume, cover letter, or communications with us. Please do not include sensitive information (for example, health, religion, or government identification numbers) in your application materials unless we specifically request it.

Sensitive information

Some of the information described above, such as government identification numbers, immigration status, criminal history, and information about a disability, may be considered “sensitive” or “special category” information under applicable law. We collect and use sensitive information only where it is necessary for the purposes described in this Applicant Privacy Notice and where permitted or required by applicable law.

Sources of information

We collect most of this information directly from you, for example when you submit an application, complete an assessment, or participate in an interview. We may also collect information from:

• recruiters, staffing agencies, and other third parties who refer you to H1, including current H1 employees;
• references you provide, and former employers and educational institutions you list (with your authorization where required);
• background check providers, where permitted by law (see Section 5);
• publicly available professional sources, such as professional networking sites and professional licensing databases; and
• our recruiting technology providers, such as our applicant tracking system and interview scheduling tools.

If you do not provide information that we reasonably request, or that is required by law, we may not be able to consider your application.

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3. How We Use Your Information

We collect and use applicant personal information for the purposes described below. If you are located in the EEA, UK, or Switzerland, we need a legal basis to process your information; the legal basis we rely on for each purpose is also set out below. Section 12 contains additional information for individuals in California, the EEA, UK, and Switzerland, and India.

We do not use applicant personal information for marketing purposes, and we do not use it to train artificial intelligence models offered as part of our Services.

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4. Use of Automated Tools and Artificial Intelligence

We may use technology tools, including tools that use artificial intelligence (“AI”), to support our recruiting team. For example, we may use such tools to organize and search applications, schedule interviews, generate interview notes or transcripts, and summarize candidate information for interviewers.

These tools assist, and do not replace, human judgment. H1 does not make hiring decisions about you based solely on automated processing; a member of our recruiting team or hiring team reviews applications and makes the final decision.

If you would like to request an alternative selection process or a reasonable accommodation, or if you have questions about our use of these tools, please contact us using the details in Section 11. Where applicable law requires additional notices or disclosures regarding the use of automated decision tools in hiring (for example, in New York City, Illinois, Colorado, or California), we will provide them at the appropriate time.

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5. Background Checks

Depending on the role and your location, and only where permitted by applicable law, we may engage a third-party consumer reporting agency to conduct a background check, which may include verification of identity, employment history, education, professional licenses, and criminal history. We generally conduct background checks only after extending a conditional offer of employment.

In the United States, we will provide any separate disclosures and obtain any authorizations required by the Fair Credit Reporting Act and applicable state and local laws before a background check is conducted, and we will consider criminal history only in accordance with applicable fair chance laws. Outside the United States, background checks are conducted only to the extent permitted by local law.

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6. How We Share Your Information

Access to your personal information is limited to H1 personnel and authorized contractors who need it to support our recruiting process, such as members of our Talent, People, and Legal teams, hiring managers, and interviewers. We may also share your information with the following categories of recipients:

• H1 subsidiaries and affiliates that participate in recruiting or would employ you if you are hired, and which are bound to protect your information consistent with this Applicant Privacy Notice;
• Service providers that support our recruiting process, such as applicant tracking, interview scheduling and assessment providers, background check providers, recruiting agencies, IT and hosting providers, and professional advisors, which are contractually required to protect your information and to use it only to provide services to us;
• Government authorities, courts, and other third parties where required by law or legal process, or where necessary to protect the rights, property, or safety of H1, our personnel, or others;
• Buyers or successors in the event of a merger, acquisition, financing, reorganization, or sale of all or part of H1’s business or assets; and
• Any other person or entity with your consent or at your direction.

We do not sell applicant personal information, and we do not share it for cross-context behavioral advertising.

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7. Security and Data Retention

We have implemented appropriate technical and organizational measures designed to protect your personal information against unauthorized, accidental, or unlawful access, destruction, loss, alteration, disclosure, or use. No method of transmission over the internet or electronic storage is completely secure, however, and we cannot guarantee absolute security. If you believe your interaction with us is no longer secure, please contact us immediately using the details in Section 11.

We retain applicant personal information only for as long as reasonably necessary for the purposes described in this Applicant Privacy Notice, including to comply with legal recordkeeping requirements and to establish, exercise, or defend legal claims. In general:

• If you are hired, information from the recruiting process will become part of your personnel file and will be retained in accordance with our employee privacy notice and record retention policy.
• If you are not hired, we generally retain your information for four (4) years after the hiring decision for the relevant role if you applied in the United States, and for twelve (12) months if you applied in the EEA, UK, Switzerland, or India, unless a longer period is required by law or is needed in connection with a legal claim, or you have agreed that we may keep your information to consider you for future roles.
• Background check information is retained only for as long as required or permitted by applicable law.

When we no longer need your information, we will delete or de-identify it or, if that is not possible (for example, because it is stored in backup archives), we will securely store it and isolate it from further processing until deletion is possible.

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8. International Data Transfers

H1 is a global business headquartered in the United States. Our servers are located in the United States, and our affiliates and service providers operate in other countries, including India. As a result, your personal information may be transferred to, stored in, and processed in countries other than the one in which you live, which may have data protection laws that differ from (and may be less protective than) those of your country.

Where we transfer personal information from the EEA, UK, or Switzerland, we do so to a country that has been recognized as providing an adequate level of protection, or we implement appropriate safeguards, such as the European Commission’s standard contractual clauses and the UK and Swiss equivalents. You may request more information about these safeguards by contacting us.

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9. Your Rights and Choices

Depending on where you live, you may have some or all of the following rights with respect to your personal information, subject to exceptions under applicable law:

• to know whether we process your personal information and to access a copy of it;
• to correct, complete, or update inaccurate or incomplete information;
• to request deletion of your personal information;
• to object to or request that we restrict certain processing;
• to request a copy of the information you provided to us in a portable format;
• to withdraw your consent where we rely on consent, without affecting the lawfulness of processing before withdrawal;
• to request human review of, or to contest, decisions made using automated tools, where applicable; and
• to lodge a complaint with a data protection or other supervisory authority.

You can also update certain information directly through your account in our applicant system. To exercise your rights, please contact us using the details in Section 11. Please include your full name, the email address you used to apply, your country of residence, and the role(s) you applied for. We will respond in accordance with applicable law.

Verification and authorized agents. To protect your information, we may need to verify your identity before responding to your request, for example by asking you to confirm information associated with your application or to submit the request from the email address you used to apply. Where permitted by law, you may use an authorized agent to submit a request on your behalf; we may require the agent to provide proof of authorization and may contact you directly to confirm the request.

No retaliation. We will not discriminate or retaliate against you, or treat your application less favorably, because you exercise any of your privacy rights.

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10. Updates to this Applicant Privacy Notice

We may update this Applicant Privacy Notice from time to time. When we do, we will post the updated notice on our website and update the “Last updated” date above. If we make material changes, we will take appropriate steps to inform you, consistent with applicable law.

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11. Contact Us

If you have questions about this Applicant Privacy Notice or would like to exercise your rights, please contact us at:

• Email: [email protected]
• Mail: H1 Insights, Inc., Attn: Legal, 373 Park Ave S, 4th Floor, New York, NY 10016

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12. Region Specific Terms

Additional terms apply to you depending on where you are located.

California

This section is provided under the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and its implementing regulations (together, the “CCPA”), and serves as our notice at collection for California residents who apply to work with H1.

Categories of personal information collected. In the preceding 12 months, we have collected the following categories of personal information about applicants, for the business purposes described in Section 3 and from the sources described in Section 2:

Sensitive personal information. We use and disclose sensitive personal information only for purposes permitted by the CCPA regulations (Cal. Code Regs. tit. 11, § 7027(m)), such as evaluating your eligibility to work, complying with legal obligations, and providing accommodations. We do not use it to infer characteristics about you.

Disclosures, sales, and sharing. In the preceding 12 months, we have disclosed each category listed above for a business purpose to the categories of recipients described in Section 6. We do not sell applicant personal information or share it for cross-context behavioral advertising, and we have not done so in the preceding 12 months. We do not knowingly sell or share the personal information of consumers under 16 years of age.

Retention. We retain each category of personal information for the periods described in Section 7. California employment law generally requires us to retain applicant records for at least four (4) years.

Your rights. As a California resident, you have the right to (i) know what personal information we have collected about you, including the categories of personal information, sources, purposes, and recipients, and the specific pieces of personal information we hold; (ii) request deletion of your personal information; (iii) request correction of inaccurate personal information; and (iv) not be discriminated or retaliated against for exercising these rights. Because we use sensitive personal information only for permitted purposes, the right to limit its use does not apply. You may submit a request by emailing [email protected]. Our verification and authorized agent procedures are described in Section 9.

EEA, UK, and Switzerland

If you apply for a role in, or are located in, the European Economic Area, the United Kingdom, or Switzerland, the following additional terms apply.

Legal bases. The legal bases on which we rely are set out in Section 3. Where we process special categories of personal data, such as health information you provide when requesting an accommodation, we do so where necessary to carry out our obligations and exercise rights in the field of employment law, or with your explicit consent. We process information relating to criminal convictions only where authorized by applicable law.

Automated decision-making. We do not make decisions that produce legal or similarly significant effects about you based solely on automated processing, including profiling.

Your rights. You have the rights described in Section 9. Where we rely on legitimate interests, you may object to our processing on grounds relating to your particular situation. You also have the right to lodge a complaint with the data protection authority in the country where you live or work, or where an alleged infringement occurred.

India

If you apply for a role in India, or are located in India, the following additional terms apply under the Digital Personal Data Protection Act, 2023 and the rules issued under it (together, the “DPDP Act”).

Purposes and basis for processing. We process your personal data for the purposes described in Section 3. By submitting your application, you consent to that processing. Where permitted by the DPDP Act, we may also process your personal data for legitimate uses without consent, such as to comply with law or a judicial order.

Withdrawing consent. You may withdraw your consent at any time by contacting us using the details below, and it will be as easy to withdraw consent as it was to give it. Withdrawal does not affect processing carried out before withdrawal, but we may no longer be able to consider your application.

Your rights. Subject to the DPDP Act, you have the right to (i) obtain a summary of the personal data we process about you and the processing activities undertaken, and the identities of others with whom it has been shared; (ii) request correction, completion, updating, or erasure of your personal data; (iii) have readily available means of grievance redressal; and (iv) nominate another individual to exercise your rights in the event of your death or incapacity.

Grievances. You may contact our Grievance Officer at Micah C. Brooks, [email protected]. If you are not satisfied with our response, you may file a complaint with the Data Protection Board of India.

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