Employee Privacy Notice

Effective Date: May 4, 2021 — Last Reviewed: March 18, 2022

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1. Introduction2. Data Controller, Data Protection Officer, and Representative3. Information We Will Collect4. Use of Personal Information5. Data Sharing6. Cross-Border Data Transfers7. Data Security8. Data Retention9. Rights of Access, Correction, Erasure, and Objection10. Changes to This Privacy Notice11. Contact Us

1. Introduction

Sharethrough is committed to protecting the privacy and security of your personal information. This Employee Privacy Notice (the “Privacy Notice”) describes how Sharethrough and its subsidiaries, affiliates, and related entities (collectively, “Sharethrough,” “we,” or “us”) collect and process personal information about you during the application and recruitment process, and about you during and after your employment. This privacy notice applies to employees located in the United Kingdom (“UK”), Europe and the United States, including those in California in accordance with the California Consumer Privacy Act of 2018 (“CCPA”). 

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2. Data Controller, Data Protection Officer, and Representative

Sharethrough and its subsidiaries, affiliates, and related entities are joint controllers of the personal information we hold about you before, during or after your employment. Sharethrough has appointed a Data Protection Officer (DPO) and a representative in the European Union.

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3. Information We Will Collect

Within the context of your role as an employee or prospective employee, we will collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”).

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4. Use of Personal Information

We only process your personal information where applicable law permits or requires it, including where the processing is necessary for the performance of our employment contract with you, where the processing is necessary to comply with a legal obligation that applies to us as your employer, for our legitimate interests or the legitimate interests of third parties, to protect your vital interests, or with your consent if applicable law requires consent.

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5. Data Sharing

We will only disclose your personal information to third parties where required by law or to our employees, contractors, designated agents, or third-party service providers who require such information to assist us with administering the employment relationship with you, including third-party service providers who provide services to us or on our behalf.

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6. Cross-Border Data Transfers

Where permitted by applicable law, we may transfer the personal information we collect about you to the United States, Canada and other jurisdictions that may not be deemed to provide the same level of data protection as your home country, as necessary to perform our employment contract with you and for the purposes set out in this Privacy Notice.

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7. Data Security

We have implemented appropriate physical, technical, and organizational security measures designed to secure your personal information against accidental loss and unauthorized access, use, alteration, or disclosure.

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8. Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes.

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9. Rights of Access, Correction, Erasure, and Objection

It is important that the personal information we hold about you is accurate and current.

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10. Changes to This Privacy Notice

We reserve the right to update this Privacy Notice at any time, and we will provide you with a new Privacy Notice when we make any updates.

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11. Contact Us

If you have any questions about our processing of your personal information or would like to make an access or other request, please contact us through your local human resources office (if you have one), or at the contact information below.

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