Global Applicant Privacy Notice

Welcome to the Accumulus Synergy Careers Site (the “Site”). The Site serves as the centralized career application portal for Accumulus Synergy, Inc.. Because we gather certain types of information about applicants during the recruitment process, we want to help you understand our practices surrounding the collection, use and disclosure of your personal information.

This Privacy Notice addresses the following topics:

• Equal Employment Opportunity Statement
• Assistance for Disabled Applicants
• Your Consent
• Scope of This Notice
• Personal Information We Collect About You
• Categories of Sources of Your Personal Information
• How We May Use Your Personal Information
• How We May Disclose Your Personal Information
• Retention of Your Personal Information
• International Transfers of Your Personal Information
• Security For Your Personal Information
• How to Access, Correct, or Delete Personal Information in Your Account
• Jurisdiction-Specific Information
• Changes to this Notice
• Inquiries and Concerns

Equal Employment Opportunity Statement

The Company is an equal employment opportunity employer.  The Company does not discriminate against any applicant or employee on the basis of race, color, sex, religion, national origin, age, disability, or any other consideration made unlawful by applicable federal, state, or local laws.  The Company also prohibits harassment of applicants and employees based on any of these protected categories.

For U.S. Applicants: It is also the Company’s policy to comply with all applicable laws respecting consideration of unemployment status in making hiring decisions.  The complies with the Americans with Disabilities Act (“ADA”), the ADA Amendments Act of 2008 (“ADAAA”) and applicable state law and considers reasonable accommodation measures that may be necessary for qualified applicants/employees to perform the essential functions of the job. Hire may be contingent upon a post-offer medical examination, and to skill and agility tests, as appropriate for the position.

Assistance for Applicants with a Disability

Alternative methods of applying for employment are available to individuals unable to submit an application through this Site because of a disability.  Contact jobs@accumulus.org to discuss modifications.

Your Consent

To submit your job application, you will need to (1) click on “Read and accept data privacy statement”, (2) review this Privacy Notice and then (3) click “Accept”.  By clicking “Accept”,

you consent to the collection, use, disclosure, transfer across borders and other processing of your personal information as described below.  Once you agree, your consent will continue to apply to our collection, use, disclosure, cross-border transfer and other processing of your personal information unless you revoke your consent by contacting us at jobs@accumulus.org.   

If you do not click “Accept” you will not be able to use the online application page to apply for global career opportunities within the Accumulus Synergy corporate group, and the Company may not be able to consider you for the position for which you are applying. To discuss the possibility of an alternative method of application, please contact jobs@accumulus.org.   

Scope of This Notice

This Privacy Notice applies only to information collected for recruitment purposes through the Site and from other sources.  The other sources might include information that you provide other than through the online application page as well as information obtained, for example, from recruiters, prior employers, other references, pre-employment screening providers, and educational institutions.  This Notice does not apply to any other site or page that we own or operate.  Our other sites have their own privacy policies.

Personal Information We Collect About You

If you choose to apply for a position with us, the categories of personal information that we may collect about you through the Site and other sources are listed below.  Please remember that you are responsible for providing information that is accurate, complete and up to date when you disclose information to us during the employment process.

Information About Protected Classification

When you apply for a position in the United States, you may have the opportunity to provide information about your protected classification, i.e., gender, race/ethnic origin and/or veteran status in order for us to conduct equal opportunity monitoring. The provision of this information is entirely voluntary.  If you decline to provide this information, your application(s) will not be affected in any way. If you do choose to provide this information, you consent to our using it for equal employment opportunity monitoring purposes. This information will be held and stored anonymously and will not be used to evaluate your application for employment and also will not be used to infer any characteristics about you.

Except as described above, we will not request or otherwise collect information about your health, race or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, or sexual orientation or your genetic information or biometric information through the on-line application or during the application process unless the law, as an exception, requires us to do so. We, or a third-party background check company under our direction, may check criminal history records for information about convictions, but only if and to the extent permitted by applicable law.

Categories of Sources of Your Personal Information

We may collect the categories of personal information listed above from the following sources:

• You, for example, in your job application, forms you fill out for us, assessments you complete, surveys you complete, and any information you provide us during the course of your application and interview process.
• Vendors and service providers, for example, recruiters.
• Third parties, for example, job references, affiliated companies, professional employer organizations or staffing agencies.
• Public internet sources, for example, social media, job boards, public profiles, and other public online sources
• Public records, for example, court records, and credentialing and licensing organizations.
• Automated technologies on Company’s electronic resources, for example, to track logins and activity on Company’s careers page.
• Surveillance/recording technologies installed by Company, for example, voicemail technologies, webcams, and audio/video recording technologies with consent to the extent required by law
• Government or administrative agencies, for example, law enforcement or public health authorities. 
• Acquired company, if Company acquired your employer, Company might collect personal information from that employer

How We May Use Your Personal Information

We will use the information that we collect about you for purposes of the hiring process, including:

Recruiting

• To evaluate your qualifications or suitability for employment with Company
• To communicate with you
• To check your references
• To conduct a pre-employment or criminal history background check
• For identification purposes
• For diversity and inclusion purposes where permitted by applicable law
• For recordkeeping purposes
• To demonstrate your agreement to, or acceptance of, documents presented to you, e.g., pre-employment arbitration agreement, acknowledgment of employment application, offer letter
• To evaluate and improve the recruiting process
• To comply with our legal obligations and to defend against administrative charges or legal claims

If you are not hired for the position for which you initially apply, we may use the information that we collect about you through the recruiting process to evaluate your suitability for future job openings.  Based on that evaluation, we may use your personal information to contact you to find out whether you are interested in applying for new job openings.

The Company’s employees involved in the evaluation of your application and, if you are hired, in the administration of your employment relationship with the Company will have access to your personal information on a need–to-know basis.

Lawful Basis For Processing:  Where applicable information protection law requires a lawful basis for collecting, using and otherwise processing your personal information, the Company relies on your consent to do so.  The processing of your personal information also is necessary for the Company to determine whether to enter into an employment agreement with you.  If you do not provide requested information, the Company may not be able to consider you for employment.  In addition, the processing of your personal information is necessary for the Company to pursue its legitimate interests in recruiting and hiring suitable personnel.

How We May Disclose Your Personal Information

Company will not sell, lease, or license your personal information to any third party.  There are limited circumstances when Company may disclose the personal information we collect about you to third parties, most notably:

• Service Providers:  With third-party service providers.  We may, for example, retain a service provider to host all or portions of this Site, to help maintain and manage our databases, to assist in the recruiting process, or to conduct pre-employment screening.  Service providers will be permitted to use your personal information only for the purpose(s) for which it was disclosed to them and in accordance with the Company’s instructions.  Service providers generally will be located only in the United States or in the country where you are applying for a position;
• Corporate Affiliates:  With affiliated companies, such as grandparent, parent and/or subsidiary corporations, for their recruitment, recordkeeping and/or reporting purposes;
• Required By Law:  When required by law, such as when we respond to subpoenas, court orders, legal process, or a discovery request in civil litigation;
• Legal Violations:  If we believe that your actions violate applicable law, or threaten the rights, property, or safety of our Company, our users, or others;
• Corporate Transactions:  If we sell some or all of our business, we may disclose all of the information that we have collected about you to a purchaser or, in due diligence, to a potential purchaser, but subject to a confidentiality agreement.

Company will make such disclosures only as permitted by applicable information protection laws.

Retention Of Your Personal Information

If Company hires you, the information that you submitted through the online application and the information that we collect during the application process will become part of your personnel file and may be used to administer the employment relationship and for related reporting and recordkeeping purposes.  We retain your information including, without limitation, for as long as needed or permitted in light of the purpose(s) for which it was collected.

Company will retain the information of applicants who (i) apply from California or from outside of the U.S. and (ii) are not hired for one year after the hiring decision has been made unless (a) the applicant indicates that we may maintain the information on file until the applicant asks to delete the information, or (b) a shorter or longer retention period is legally required.  These records will be retained for our internal recordkeeping and reporting purposes.  During that time, we may use your personal information to consider you for positions in addition to the position(s) for which you initially applied.  If you wish to withdraw your application from consideration at any time during this retention period, you can do so by contacting us at jobs@accumulus.org.   

International Transfer of Your Personal Information

If you are applying for a position with us from outside the U.S., the personal information that we collect about you in the recruitment process will be transferred to, and stored on, our servers, located in the U.S., and on servers maintained by our recruitment service provider, Greenhouse Software, Inc. in the U.S.  Authorized employees of the Company at locations outside the United States may have access to your personal information as part of the recruitment process. These employees may use and disclose your personal information only for recruitment purposes and must handle that information in accordance with this Privacy Notice and applicable information protection laws and guidance.  The information protection laws where these employees are located may be less stringent than the laws of your home country. 

If you reside in countries with restrictions on cross-border data transfers, such as the European Union or Brazil, we rely on your consent for the transfer of your personal information outside your country of residence.  Where applicable information protection law requires additional protections to transfer your personal information to the U.S., Accumulus has taken steps to ensure an adequate level of protection for your transferred personal information.  You may obtain information about cross-border data transfer by submitting a request to jobs@accumulus.org.  

For Japan Only: For international data transfers to the United States, the applicable information with respect to the personal information requirement of the United States can be found here at https://www.ppc.go.jp/files/pdf/USA_report.pdf (Federal),

https://www.ppc.go.jp/files/pdf/california_report.pdf (California)

https://www.ppc.go.jp/files/pdf/newyork_report.pdf (New York)

https://www.ppc.go.jp/files/pdf/illinoi_report.pdf  (Illinois)

Security For Your Personal Information

We want you to feel confident about providing your personal information through the online application page, so we have implemented a security program to keep information that is transmitted to our systems protected from unauthorized access.  Your submissions of information to our secure server are protected by Hypertext Transfer Protocol Secure (“HTTPS”) and Transport Layer Security (TLS) technology, utilized by many popular browsers to safeguard transmissions.  This technology allows us to use encryption tools to protect information transmitted between your computer and our server.  After we have received your information, access to it is limited to employees with a need to know.

While we strive to protect your personal information, we cannot guarantee the security of any information that you submit through the online application, and you do so at your own risk.  We urge you to keep your username, password and any other log-in credentials in a safe place as you share responsibility for maintaining the confidentiality of the information that you submit to us.  It is a good practice to sign off your account and close your browser window when you have finished your visit to the Site.

How to Access, Correct, or Delete Your Personal Information in Your Account

If you would like to access the information that you have submitted through the online application page; wish to request that we update, modify, or delete your information; or if you have any questions about this Privacy Notice, please contact jobs@accumulus.org.

Jurisdiction-Specific Information

• All locations outside of the United States
• European Economic Area, United Kingdom, and Switzerland[1] 

All locations outside of the United States

For purposes of applicant personal information, Accumuls Synergy Inc. is the data controller of your personal information

The personal information collected through the Site is downloaded to a server maintained by Company, or its service provider, in the United States.  The laws of the United States may provide a different level of protection for your personal information than what is required in the country where you reside.

To the extent provided by applicable law and subject to any relevant exceptions, you may be able to exercise the following rights:

• Access:  The right to request access to your personal information maintained by the Company.
  • More on the right of access:  Right to access your personal information may include your right to receive a copy of all, or a portion, of their personal information in Company’s possession as long as Company’s providing the personal information would not adversely affect the rights and freedoms of others.
• Rectification:  The right to request that Company update or correct your personal information that is outdated or inaccurate.
• Deletion:  The right to request that Company to delete/erase your personal information.
• Restrict Processing:  The right to request restriction of processing of your personal information in certain situations, such as while a dispute concerning the accuracy of personal information is being resolved.
• Withdraw Consent:  The right to withdraw your consent to the processing of your personal information, at any time, where you previously consented to the processing of your personal information.
• More on the right to withdraw consent: Any withdrawal shall not affect the lawfulness of processing based on your consent before its withdrawal, and Company will continue to retain the personal information that you provided us before you withdrew your consent for as long as allowed or required by applicable law.  

How To Exercise Your Rights

You can contact jobs@accumulus.org to request to exercise your data rights.  Company will respond to requests to exercise individual data rights in accordance with applicable law. Company will recognize any additional rights you may have under applicable law, but it will not grant you more rights than applicable law provides. 

European Economic Area, United Kingdom, and Switzerland

The information in this section applies to applicants who reside in the European Economic Area (EEA), the United Kingdom (UK), and Switzerland (collectively, “Europe”).  Individuals in Europe (“European Individuals”) are not required by statute or by contract to provide any personal information to the Site. 

No Automated Decision-Making

Company will not use European applicants’ personal information submitted through the Site for automated decision-making, including profiling, that produces legal effects or similarly significantly affects the European applicants. 

Your Additional Rights

To the extent provided by applicable law and subject to any relevant exceptions, European applicants have the rights identified in the section entitled “All locations outside of the United States” as well as the right to data portability and right to object as described below:

• Data Portability:  You have the right to request that Company transfer your personal information to a third party.
  • More on the right to information portability: Subject to certain limitations, the right to information portability allows you to obtain from Company, or to ask Company to send to a third party, a copy of your personal information in electronic form that you provided to Company in connection with your interactions with Company.
• Objection:  You have the right to object to the processing of your personal information.
  • More on the right to object:  You have the right to object when processing of your personal information is based solely on Company’s legitimate interests.  If you do object in these circumstances, the processing of your personal information will be stopped unless there is an overriding, compelling reason to continue the processing or the processing is necessary to establish, pursue or defend legal claims.

Right to Lodge a Complaint:  If European Individuals believe that their personal information has been processed in violation of applicable information protection law, they have the right to lodge a complaint with the competent supervisory authority in the country where they reside, where they work, or where the alleged violation occurred. 

• Individuals who reside in the European Union can find their competent supervisory authority here.
• Individuals who reside in Switzerland can find their competent supervisory authority here.
• Individuals who reside in the UK can find their competent supervisory authority here.

Changes to This Notice

Company may change this Privacy Notice from time to time in its sole discretion.  If we make a material change to this Notice, we will inform you by posting a notice on this Site.  Those changes will go into effect on the effective date posted in the revised notice.  The new policy will apply to all current and past users of the online application page and to all information collected before the date of the change.  The new policy will replace any prior policies that are inconsistent.  Please check periodically for changes to this Notice, and especially before you provide any personal information to us.  If we will materially change how we use, disclose or otherwise process your personal information, we will contact you before doing so and obtain your consent before using, disclosing or otherwise processing your personal information other than as described in this Notice.

Inquiries and Concerns

Please direct any questions or concerns you may have about this Privacy Notice to jobs@accumulus.org.