Job Applicant Privacy Notice

Effective as of April 26, 2024

NextRoll, Inc. (formerly AdRoll, Inc.) and its subsidiaries and affiliates (“we,” “our” or “us”) is an independent marketing technology company that offers intelligent, data-driven advertising and marketing services and solutions to help big and small companies accelerate their growth (“Services”).

Please note that this Privacy Notice only applies to data that we collect during our application and recruitment processes. To learn what data we collect when you visit our websites, please visit the NextRoll Website Privacy Notice. Additionally, to learn what data we collect when you visit the websites of our Advertisers, please visit the NextRoll Service Privacy Notice.

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Table of Contents

• What Data We Collect
• How We Use the Data We Collect
• Data Sharing
• Your Choices and Rights
• Information for European Territory Residents: Our Legal Basis and Your Rights
• Information for California Residents
• Information for Individuals Located in Brazil
• Data Retention
• Security
• International Transfers
• Changes to this Privacy Notice
• Contact Us About Questions

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We may collect the following categories of information during the job application and recruiting processes and use them for the purposes explained below.

Data You Provide To Us

• Identifiers and Contact information: This is your name, date of birth, mailing address, email address, phone number, and other similar contact data.
• Application Information: This is your resume, cover letter, Curriculum Vitae, work experience, education history, academic degrees, professional certifications, job-related skills, information that you make publicly available on websites or professional platforms (e.g., LinkedIn profile), citizenship status, work permit status, and, when applicable and permitted by applicable law, information required for background screenings, and background screening results.
• Sensitive Personal Information: This is information related to racial and ethnic origin, religious beliefs, trade union membership, and health and medical information, including disability status, where we have obtained your consent or the collection of such information is permitted by applicable law. We do not use or disclose sensitive personal information to infer individual characteristics or for any purpose other than to assess your information in connection with our recruiting and hiring practices or as otherwise permitted by law.
• Other Information: This is any other information you voluntarily provide to us in connection with your application for employment (e.g., compensation history), including that which you provide via email, during an interview, or as part of other forms of assessment.

Data We Automatically Collect From Your Device

• Cookies: This is a unique identifier that NextRoll assigns to you when visiting one of our sites so we can understand your online journey.
• Device Information: This is technical information about the device you use to access our sites such as your operating system. Additionally, in the case of mobile devices, your device type, unique advertising identifier (such as the Apple IDFA or Android Advertising ID) and any other unique identifier that may be assigned to the mobile device, such as an Android ID or UDID in older Apple phone models, or a non-cookie unique identifier used by Non-Cookie Technologies.
• IP Address: This is the IP address associated with the device you are using when visiting our sites.
• Location Data: This is non-precise information related to your geography derived from your device’s IP address. This does not reveal your precise geographic coordinates (i.e. your GPS latitude and longitude) - only country, state, city and zip/postal code and helps us to display information that is relevant to your general location.
• Browser Data: This is technical information about the browser you are using that is captured in order to serve you an ad that can be rendered on your device (for example, Chrome, Firefox, and Safari).

Data We Collect from Other Sources

• Third Party Sources: We may receive information about you from former employers, former academic institutions, employment screening agencies, background screening agencies, recruiting agencies, and other service providers that assist with our job application and recruiting processes (e.g., expense reimbursement services).
• Referrals from Individuals: We may receive contact information or application information (e.g., your resume and cover letter) from a friend or colleague who thinks you may be a qualified candidate for a job at NextRoll.
• Professional Networking and Recruiting Websites: We may receive publicly available information on websites or social media about you (e.g., if you apply to a NextRoll job through LinkedIn, where relevant for recruitment purposes and allowed by applicable law). We may also receive information about you from recruiting websites that are legally allowed to share your personal information with us (e.g., if you sign-up to be contacted by prospective employers on another website, the website may provide your personal information to us).

We use the data that we collect during the job application and recruitment processes for the purposes explained below.

• Assessing your application information to determine your eligibility for available jobs at NextRoll.
• Assessing your application information to determine your eligibility for future job opportunities at NextRoll.
• Using automated decision-making systems to analyze application information to assess your eligibility for a role against the role requirements or description and to improve our recruitment processes and experiences.
• Communicating with you throughout the recruitment process (e.g., scheduling interviews and providing you with updates about your job application).
• Contacting references with your consent.
• Conducting background screenings with your consent.
• Evaluating job application and recruitment lifecycle metrics to improve our recruitment and hiring processes (e.g., creating aggregated, de-identified and anonymized reports).
• Complying with legal and compliance reporting obligations (e.g., anti-discrimination laws).

We may disclose data about you:

• With our Service Providers: We contract with companies who help with parts of our job application and recruitment operations (e.g.,recruiting, IT, and reimbursement services).
• With our Subsidiaries and Affiliates: These entities will only process your data for the purposes already explained in this Job Applicant Privacy Notice. Our subsidiaries are NextRoll Limited (Ireland), AdRoll Limited (UK) and NextRoll Pty Limited (Australia).
• In connection with legal proceedings: When we are under a legal obligation to do so, for example to comply with a binding order of a court, or where disclosure is necessary to exercise, establish or defend the legal rights of NextRoll, our customers or any other third party.
• In connection with a sale of our business: If a third party acquires some or all of our business or assets, we may disclose your information in connection with the sale (including during due diligence in preparation for the sale).

Your choices and rights concerning the data that we collect during the job application and recruitment processes may vary depending on where you reside and applicable laws. You can change or limit the data that we collect during the job application and recruitment processes as explained below.

Access: During the recruitment process, you can request access to your job application by emailing talentops@nextroll.com.

Correct: You can request that we correct inaccuracies related to your job application by emailing talentops@nextroll.com.

Delete: You can request that we delete the data related to your job application by emailing talentops@nextroll.com. We will delete the data related to your job application unless we are required to retain it by law or for legitimate business purposes.

Complaints: You have the right to complain to a data protection authority about our collection and use of your personal information. If you are unsatisfied with our response to your complaint, you have a right to raise questions or complaints with your local data protection authority at any time.

Withdrawal of Consent: Where we rely on your consent to process the data that we collect during the job application and recruitment processes, you have the right to withdraw consent at any time. This will not affect the lawfulness of processing prior to the withdrawal of your consent. At any time, you can request that we stop using your data for recruiting purposes.

Identity Verification and Authorized Agents: Only you, or a person that you authorize to act on your behalf, may make a verifiable request regarding the data related to your job application.

We cannot respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; and (ii) confirm the personal information relates to you.

We will only use personal information provided in a verifiable request regarding data related to your job application to verify the requestor’s identity or authority to make the request.

Legal Basis: Under European data protection law, our legal basis for collecting and processing your personal information will depend on the information collected and the context in which we collect it. During the job application and recruitment processes, we will collect data regarding your job application based on consent. We will retain data related to your job application based on our legitimate interest.

Privacy Rights:

• Candidates in the European Union can object to the processing of their personal information, ask us to restrict processing of their personal information or request portability of their personal information.
• Where consent to the use of personal information has been obtained, it can be withdrawn at any time with future effect. Please note that withdrawing consent will not affect the lawfulness of any processing we conducted prior to the withdrawal or processing personal information under other legal bases.
• If you believe we are using your personal information in a way that is inconsistent with this Job Applicant Notice, you may notify us of your complaint at any time. You also have the right to complain to a data protection authority about our collection and use of your personal information.

If you are located in a European Territory, NextRoll Limited is the data controller of your information. To contact NextRoll Limited please email support@nextroll.com or write to us at the following address:

NextRoll Limited
Attn: Legal
Floor 3, Block 3
Miesian Plaza
Dublin 2, Ireland
D02 Y754

The California Consumer Privacy Act provides California residents with specific rights regarding their personal information. This section describes the rights of California residents and provides information on how to exercise those rights.

Right to Know and Data Portability Rights: You have the right to request that we disclose the following regarding our collection and use of your personal information over the past 12 months:

• The categories of personal information we collected about you;
• The categories of sources for the personal information we collected about you;
• Our business or commercial purpose for collecting or selling that personal information;
• The categories of third parties with whom we share that personal information;
• The specific pieces of personal information we collected about you (otherwise known as a data portability request); and
• Two separate lists where we have sold or disclosed your personal information for a business purpose:
  • Sales: identifying the personal information categories that each category of recipient purchased; and
  • Disclosures for a business purpose: identifying the personal information categories that each category of recipient obtained

Right to Delete: You have the right to request that we delete any of your personal information that we collect from you and retain, subject to certain exceptions. Upon receiving a verifiable request regarding data related to your job application, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relations with you or otherwise perform our contract with you;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity or prosecute those responsible for such activities;
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights or exercise another right provided by law;
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
• Comply with a legal obligation; and
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to Correct: You have the right to request that we correct inaccurate personal Information that is maintained about you, taking into account the nature of the personal information and the purposes of the processing of the personal Information. Upon receiving a verifiable request regarding data related to your job application, we will use commercially reasonable efforts to correct your personal information and direct our service providers to do the same, unless an exception applies.

Exercising Right to Know, Data Portability, Right to Deletion, and Right to Correct: To exercise the right to know, data portability and deletion rights described above, please submit your request to us by either:

• Calling us at 1-833-611-1920; or
• Emailing us at talentops@nextroll.com.

The Brazilian Data Protection Law, the Lei Geral de Proteção de Dados Pessoais provides individuals located in Brazil with specific rights regarding their personal information. This section describes the rights of individuals located in Brazil and provides information on how to exercise those rights.

Privacy Rights: You have the right upon express request to:

• Access your job application;
• Delete any of your personal information that we collect from you and retain, subject to certain exceptions.
• Confirm the existence of processing;
• Correct inaccurate, incomplete, or out-of-date information related to your job application;
• In certain situations, object to the use of your personal information, requiring the anonymization, blocking, or elimination of your data or the exportation of your personal information to another controller;
• Obtain information about the service providers that we share your data with to carry out the job application and recruitment processes; and
• Withdraw consent, where consent to the use of personal information has been obtained. Please note that withdrawing consent will not affect the lawfulness of any processing we conducted prior to the withdrawal or processing personal information under other legal bases.

If you are located in Brazil, NextRoll, Inc. is the data controller of your information. To contact NextRoll, Inc., send an email to support@nextroll.com or write to the following address:

NextRoll Inc.
A/C Legal
2300 Harrison St.
2nd Fl.
San Francisco, CA 94110

We will not keep your personal information for longer than is necessary to fulfill the purposes for which it is collected. If you apply to a job and are not offered the job, generally we keep most of your personal information for the duration of the recruitment process plus an additional 14 months, unless you authorize us to retain your information for longer to be considered for potential future job opportunities. If you would like to request that we delete data related to your job application, you may do so as set forth in the Your Choices and Privacy Rights section of this Notice. If you are offered and accept a job at NextRoll, the information that we collected as part of the recruitment process will become part of your employment record and retained according to our data record retention policies.

We apply technical, administrative and organizational security measures to protect the data we collect against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access, in particular where the processing involves the transmission of data over a network, and against other unlawful forms of processing.

We may transfer the information we collect about you to countries (including the United States of America) other than the country where we originally collected it during the job application and recruitment processes. In general, these countries will be the countries in which we or our service providers operate.

Those countries may not have the same data protection laws as your country. However, when we transfer your information to other countries, we will protect that information as described in this Job Applicant Privacy Notice and take steps, where necessary, to ensure that international transfers comply with applicable laws.

For example, when we transfer your information from a European Territory (as defined below) to our parent company in the United States, we do so under the European Commission's Standard Contractual Clauses. When we transfer your data outside of a European Territory to Advertising Partners (or vice versa), we do so under lawful data export mechanisms which may include Standard Contractual Clauses and Binding Corporate Rules.

We may update or modify this Job Applicant Privacy Notice at our discretion at any time. When we make changes to this Privacy Notice, we will post the updated notice online and update the notice’s effective date. Please review this Applicant Privacy Notice periodically.

If we are required by applicable law to obtain your consent to any material changes before they come into effect, then we will do so in accordance with law.

If you have any questions about this Job Applicant Privacy Notice or our privacy practices, or want to appeal NextRoll’s decision as a Controller with regard to a request regarding your job application, you can contact support@nextroll.com.

If you wish to escalate your inquiry after contacting the support team, you are welcome to contact our Data Protection Officer at dpo@nextroll.com or by writing to the following address:

Address:
Lucid Privacy Group
Attention: NextRoll Data Protection Officer
1050 Page Street
San Francisco, CA 94117
USA