Keeper Candidate Privacy Notice

This notice explains how Keeper Security processes your personal data during recruitment. Depending on the role and location, the Controller of personal data (the organization responsible for determining why and how personal data is processed) will be Keeper Security Inc. (US), Keeper Security EMEA Ltd. (Ireland), or Keeper Security APAC K.K (Japan).

1. Data We Collect

Information You provide:

• Contact details, CV/resume, cover letter
• Employment history, qualifications, work eligibility
• Application responses and uploaded documents

Information We generate:

• Interview notes, assessments, communications
• Scheduling information

Information From Others:

• Recruiter/referral information who submit your profile
• References (with your consent, before final offer)
• Public professional profiles
• Background verification (post offer)

Voluntary Diversity and Equal Opportunity Information

• We may ask you to voluntarily provide diversity information including race/ethnicity, gender, disability status and veteran status (US). Providing this information is optional and Keeper collects this data in order to comply with EEOC and similar requirements

2. How We Use Your Data

• Assess your application and suitability
• Manage interviews and recruitment workflow
• Consider you for other/future roles (we may seek your consent to keep your information on our systems beyond the retention period specified)
• Comply with employment law obligations

3. Legal Basis

• Legitimate Interests (recruitment management, security and integrity of the hiring process)
• Contracting steps (for progressed candidates)
• Legal and regulatory compliance obligations; explicit consent where required

4. Who We Share Information With

Internal:

• HR, hiring managers, interviewers*, IT support for system administration

*Note - diversity and equal opportunity data is not shared with hiring managers.

Third Parties:

Service providers who assist with:

• Applicant tracking, recruitment systems and assessment providers
• Background verification vendors (post offer)
• Recruitment agencies (where applicable)
• Tools to support communication, collaboration and to securely store your data

Keeper ensures that all our third parties are contractually bound to protect your personal data with adequate safeguards in place.

5. International Transfers

Your data may be accessed by Keeper entities globally as needed for the purposes of hiring and decision making. We protect any such data transfer between Keeper entities using appropriate safeguards under applicable data protection laws.

6. Security

We implement appropriate technical and organizational measures to protect your data, consistent with our industry leading security standards.

7. Retention

We keep your data for 24 months from your last application activity, then delete or anonymize it.

Exceptions:

• You opt into our talent database for further retention by providing consent (extended retention)
• You're hired (transfers to employee records)

8. Your Rights

You have the following rights and can contact us at the email below to exercise them:

• Access, correct, or delete your data, subject to applicable law and retention requirements
• Object to or restrict processing
• Withdraw consent (where applicable)
• Request data portability
• Lodge a complaint with your data protection authority

If you become an employee, your rights regarding your employee record are governed by our internal Employee Privacy Notice and certain data will be retained as required under relevant laws such as employment or tax law.

When you request access to your personal data, some information may be redacted if it includes the personal data of other individuals or information that we must protect in order to preserve their privacy rights.

9. Automated Decisions

Keeper does not make hiring decisions using solely automated processing.

10. Contact - Candidates can send privacy questions to: privacy@keepersecurity.com