Zip Co Us Inc. Applicant and Candidate Privacy Notice

Overview

Zip Co US Inc. and any of our U.S. affiliates’ (collectively, “Zip”, “the Company”, “we”, “us” or “our”) is committed to the protection of your privacy. As part of the recruitment process, Zip collects, stores and processes personal data relating to job applicants and/ or candidates (collectively, “you”) in order to evaluate candidacy for employment. This Applicant and Candidate Privacy Notice (“Notice”) has been created to promote transparency around the way in which we handle personal information in relation to all pre-employment activities, including your initial application, the hiring process and any applicable background checks.

If you are also a customer of Zip or its lending partners for personal purposes (or apply for a Zip product or facilitated loan for such purposes), your personal information collected in that customer-related context will be protected as described in our customer Privacy Policy and Notice, available at https://zip.co/us/privacy-policy.

In this Notice, “personal data” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. This notice also applies to sensitive personal data, a category of personal data. It includes data like your social security number and account log-in credentials, as well as biometric information. We are the “controller” of the Personal Information you provide us and will process any such Personal Information in accordance with applicable regulations and the terms in this Notice. Kindly note that the precise data controller in respect of your personal information will typically be the Zip entity to which you are applying, although other entities in the Zip group may access and process your information for the purposes set out in this Notice.

The term “applicant” is used in this Notice to refer to anyone who applies for a job role and/or internship opportunities, or who otherwise seeks to carry out work with or for us (whether on a permanent or non-permanent basis).

What Data We Collect

Personal Data

The types of personal data we may collect and process when you apply for a role with us include (but not limited to):

• Identification Data and contact information: Name, email address, residential address, phone number.
• Education and employment background: Resume/ CV and/or LinkedIn profile, cover letter, academic/professional qualifications, transcripts and employment references, information about criminal convictions and offenses and other information revealed during background screening.
• National Identifiers and work eligibility information: National ID/passport, immigration status, work authorizations, visas, social security numbers.
• Demographic Information: Race/ ethnic origin, sex/gender, gender identity, military or veteran status.
• Application-related Information: Position preferences, willingness to relocate, desired salary, interests and aspirations and any other information you provide to us in support of and during the recruitment process.
• Content of Interviews/ other Forms of Assessment: In-person, audio, or video interviews (live and recorded), information about you available online, and other forms of assessment you might provide.
• Internet or other electronic network activity and analytics: Data about the pages you access, computer IP address, device ID or unique identifier, device type, geo-location information, computer and connection information, mobile network information, statistics on page views, traffic to and from the sites, referral URL, ad data, and standard web log data and other information.

Sensitive Personal Data

We collect certain personal data considered sensitive personal data (“sensitive personal data”). To support our legal and business activities, and as permitted by law, we may collect personal data as part of our employment recruitment process. This includes government issued identifiers, such as social security information, driver’s license information and diversity information such as disabilities for the purposes of equal opportunities monitoring. You may provide, on a voluntary basis, other Sensitive Personal Information during the recruitment process.

Sources of Personal Data

Depending on your residency, we may collect some information from sources other than you in the course of our recruitment process, including:

• Directly from you
• Previous and current employers
• Service providers (e.g. recruiters)
• Background check services
• Individuals who refer you
• Online sources including social networks and recruiting sites (e.g. LinkedIn)
• Open government databases and other public sources

We also may collect personal data through our use of cookies, web beacons, and mobile analytics sent to us by your computer, mobile phone, or another access device.

Use of Personal Data

In general, and subject to applicable law, we collect and use your Personal Data primarily for recruitment purposes. In particular, we use this information to determine your qualifications for employment or a temporary assignment, and to help us reach a hiring decision. This means, in part, that we need to:

• Assess your skills, qualifications and suitability for the role.
• Verify your information and carry out background and reference checks, where applicable.
• Communicate with you about the recruitment process.
• Track an application through the recruitment process.
• Evaluate you for current and future job opportunities, including matching your skills and interest to applicable job requirements.
• Where we need to comply with legal or regulatory requirements.
• Conduct internal analyses to understand the job applicants and/or candidates who apply and to improve our recruitment process.
• Equality and diversity monitoring.
• Where it is necessary for our legitimate interests (or those of a third-party) and your interests and fundamental rights do not override those interests.
• Facilitate personality, ability and occupational assessments by a third-party provider.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the rules mentioned above, where this is required or permitted by law.

If we hire you, personal information we collect in connection with your application can be incorporated into our human resources systems and used to manage the new-hire process; any such information can become part of your employee file and used for other employment-related purposes.

Personal Data Sharing

We may disclose personal data, including sensitive personal data, to the following categories of recipients, for the business purposes described in this Notice and below:

Disclosures to Subsidiaries and Affiliates

We may share your personal information with affiliates under common ownership or control of Zip for purposes of recruiting or evaluating job applicants and/or candidates, resource planning, and talent and recruitment as well as other legitimate business purposes such as Human Resources administration and general business management and operations.

Disclosures to Third Party Agents and Service Providers

Your personal data will be shared with companies providing services under contract to Zip as part of the recruitment process which may include hosting and operating the Careers site, recruiting assistance, reporting and analytics, assessing the applicant’s potential fit with respect to the applicable role, and background check processing.

Disclosures to other Third Parties:

We may also disclose Personal Information to other third parties, in an effort to:

• To comply with applicable law.
• To respond to requests from public and government authorities.
• To cooperate with law enforcement.
• Sell, assign, or transfer of all or part of our business.
• To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
• Establish, exercise or defend against potential, threatened or actual litigation, as needed.
• In connection with a sale or business transaction.

Data Retention of Personal Data

Personal information will be stored in accordance with applicable laws and kept as long as needed to carry out the purposes described in this Notice, unless a longer retention period is permitted or required by applicable law. We may also retain your personal information in accordance with applicable law to consider you for other job opportunities, unless you have explicitly indicated that you do not wish us to retain your information for such purposes.

In the event that you are unsuccessful, please note that your Personal Information will be automatically deleted upon expiration of the relevant retention period. If you become a Zip employee, personal information you provide will become a part of your employee file and may be used later for the management of the employment relationship.

Your Privacy Rights & Choices

You may exercise the rights available to you under applicable data protection laws. These may include (subject to the data protection laws that apply to you):

• You have the right to access the personal information we store about you, including details of why we are processing it.
• You have a right to request that we correct inaccurate or incomplete personal information.
• In certain situations, you can ask that we erase your personal information. Please note, we may not delete all your data because certain exceptions may apply.
• You have the right to request portability or export of your personal information to another controller.
• You have the right to limit the use and disclosure of your personal information (e.g. marketing with non affiliates)

In order to process your request, you may be asked to verify your identity, including by providing government issued identification or specific pieces of personal information. If Zip is unable to verify your identity, your request may be denied. Please note that certain personal information may be exempt from such requests pursuant to applicable data protection laws or other laws and regulations.

You can submit your privacy request here.

How We Protect Your Personal Information

At Zip, we have a responsibility to keep your personal information safe and secure—and we take that responsibility very seriously. First, we limit those who have access to your information to those who have a legitimate business reason for using it. Then depending upon the type and form of Personal Information, we manage it according to our data handling policies and procedures to help ensure it’s transferred, processed, and stored with the proper safeguards in place. In addition, we have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Notice to AU Residents

If you reside in Australia or New Zealand, please click here to review the ANZ Applicant and Candidate Noticed.

Changes to This Privacy Notice

This privacy notice may be updated periodically. When we update this Notice, we will note the date of its most recent revision above. On some occasions, we may also actively advise you of specific data handling activities or significant changes to this privacy notice, as required by applicable law.

Contact Us

If you have questions about this privacy notice or wish to contact us for any reason in relation to our personal data processing, please contact privacy.usa@zip.co