Careers at Accredible

Accredible HR PRIVACY NOTICE

Effective Date: July 1, 2022

Welcome to Accredible!

Regardless of whether you’re a current Accredible team member, or you’re applying to be part of our team, it’s important to us that you’re aware of personal information ("PI”) we collect, how we use that information, and how you’re empowered to opt-out, correct, delete, or change that information.

This Privacy Notice applies to all applicants and prospective employees (collectively, “Applicants”) and current and former employees, officers, directors, contractors, agents contingent and other personnel (collectively, “

Workers”) of Accredible, and their emergency contacts and beneficiaries, whose PI is collected and processed by us in the course of our business. The terms “Accredible,” “we,” “us,” and “our” in this policy apply to all companies in the Accredible family of companies, which includes EdInvent, Inc. dba Accredible, its affiliates, and subsidiaries. The terms “you,” and “your” in this policy apply to Applicants and Workers, as applicable.

1. COMPLIANCE

We are committed to complying with all data privacy laws in the jurisdictions in which we collect PI of Applicants and Workers. This notice is a general guide to how we treat the PI of Applicants and Workers and their emergency contacts and beneficiaries. You should be aware that data privacy laws can vary in different jurisdictions where we operate and have employees. As we are an international business with offices in the U.S., it is possible that your information will be shared, processed, and kept in a country different from where you live. To help keep your PI safe, we keep informed of local laws and take best efforts to follow those. Where local laws are stricter than the protections described in this notice, we work to apply specific privacy practices in those locations to comply with those stricter requirements. Where local laws are less strict than these policies, the protections described in this notice will apply. No matter the jurisdiction, we will never sell your PI.

2. WEB ACCESSIBILITY

We are committed to achieving meaningful accessibility to this notice for all

Applicants, Workers, emergency contacts and beneficiaries, including those with disabilities. We do this based on accessibility guidelines developed by the World Wide Web Consortium (W3C). This notice is available in Portable Document Format (PDF), and we try and ensure it is produced using the latest version of Acrobat (file conversion software for PDFs), which is the most accessible technology currently available for this type of document. To improve viewing of the PDF version, please download the latest free version of

Adobe Reader.

Since we recognize that even this version does not work for everyone, if you are prevented from accessing this notice, please contact us for assistance and we will do our best to provide an alternative accessible format. Applicants, Workers

, and their emergency contacts and beneficiaries with disabilities, may make an alternative format request by contacting legal@accredible.com.

In order to respond in a manner most helpful to you, please note the nature of your accessibility concern, the format you prefer, this web address, and the best way to contact you.

3. WHAT INFORMATION WE COLLECT

We collect your PI when you apply for a job at Accredible through voluntary submission directly to us, through third-party job posting sites or through recruiters. We collect additional PI during your application process, when you are hired and during your employment. Apart from information you provide, Accredible may also collect information automatically from you or from others.
a. Applicants. The PI we collect when you apply for a job and during your application process may include:

General HR Information. This might include your name, alias, postal address, phone number, unique personal identifier, online identifier, email address, date of birth, age, passport number, driver’s license number, Social Security number or other government-issued identification number, immigration status, employment history, education information and records, professional qualifications, salary information, information that may be recorded on a resume/CV or application form (such as education history, education records such as grades and transcripts, and employment history), language abilities, records of personal property, business or professional licenses, insurance information, motor vehicle records, and contact information of third parties in case of an emergency.
Demographics. Where permitted by law, we may also ask for optional information like race, national origin, disability, marital status, sex, ethnicity, gender, or military and veteran status to help us achieve our diversity goals.
Evaluation Information. We may also receive or collect information to help evaluate your application, such as information you choose to disclose during the interview process.
Your Communications with Us. If you contact us for any reason (for example, to inquire about benefits or ask about a job opportunity), we will receive your information, including whatever information you use to contact us.
Surveys. From time to time, we may ask you to participate in optional surveys to help inform our decision-making and to ensure that your views are represented and considered.If you decide to participate, you may be asked to provide certain information, which may include PI.
Legal Information. We also collect contractual information, such as information necessary to comply with legal and contractual obligations, exercise legal and contractual rights, and initiate or respond to legal claims. Audiovisual or Other Sensory Data. We may collect audio and video recordings of interviews.
Inferences Drawn from Other PI. We may collect inferences drawn from other PI such as your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Information from Other Sources. We may collect or receive information about you from other sources, including third-party services and organizations, to supplement information provided by you. For example, where permitted by law, we may conduct background and credit checks on you prior to your employment with Accredible.

b. Workers. In addition to the PI collected for Applicants, the PI we collect when you are hired and during your employment may include:

Applicant Information. We may also collect from Workers upon hiring and during employment similar information collected from Applicants, and we may supplement, update, or add to this information from time to time.
Payroll Information. We collect information required for payroll which may include your bank account number, routing number, and other details.
Health Information. We may collect sensitive PI such as details of health and disability, health insurance information, mental health, or medical or maternity leave. There may also be instances where current health and safety laws, particular modes of travel or certain events/gatherings require us to collect details regarding your COVID-19 tests and vaccination status. As a remote first company, we do not require Covid-19 testing or vaccination as a condition of employment.
Performance Information. We may collect information to help evaluate your performance, such as information provided by you during performance reviews. We may also collect job assignments, work schedule, hours worked, accomplishments and awards, training and development information, discipline and counselling information, opinions, evaluations, and information provided to us from other Workers as part of this review process.
Posting on Intra-Company Sites. We may offer intra-company accessible sites, pages, messaging channels, blogs, or forums for Workers to communicate and collaborate with each other, like Discord or Slack (“Intra-Company Sites”). We and other individuals who use the Intra-Company Sites may collect the information you submit or make available through these sites. If you choose to make content available on any public area of the Intra-Company Sites, such content will be visible to other Workers and not subject to the privacy protections set forth here in this notice.
Surveys and Promotions. In that same vein of building bonds and community at Accredible, we also frequently run optional Worker surveys, promotions, and contests. It’s possible that you may be asked to provide certain information to participate, which may include PI.
Personal Information about Dependents or Other Family Members. We may collect information about your dependents under the age of 18 or other family information if you voluntarily provide such information in connection with the enrollment and administration of benefits, or for other human resource purposes involving such dependents.
Audiovisual or Other Sensory Data. We may collect audio and video recordings of training sessions or other Accredible meetings. We may also collect audio and visual information such as photographs used for identification purposes and might also use those photos to promote Accredible.
Device Information. Like most companies, when you use company issued devices or access/login to company sites, accounts or messaging channels from a personal device, we receive data like your internet protocol (IP) address, your location based on your IP address or activities, identifiers associated with your computer or device, cell phone-related information, activity logs, browsing history, search history, information regarding your interaction with a website, and other information about activities you engage in while working with us.
System Monitoring. To ensure that our hardware and software is working optimally, the company devices issued to you, and Accredible’s accounts, information technology systems and networks you use, may be monitored and reviewed by us to ensure they’re used appropriately and to determine what IT upgrades may be necessary. Should it become necessary, Accredible can also access and review electronic files, messages, and emails sent or stored on its information technology systems and hardware. To the maximum extent permitted by law, you have no expectation of privacy while at Accredible premises or using Accredible information technology systems, networks, and electronic communication tools. To underscore this point, Workers should know that they may not have access to every file, network, and programs – this is because we need to maintain confidentiality and protect our team members.

4. WHY WE COLLECT THIS INFORMATION

We use and disclose your PI primarily for the purpose of managing our relationship with you, along with other purposes to operate our business. These uses include:

determining employment eligibility and if you are a good fit for our team (e.g., verification of references and qualifications, administering background checks where permitted bylaw);
administering payroll and benefits as well as processing employee work-related claims(e.g., worker compensation, insurance claims) and leave of absence requests;
keeping you safe, establishing emergency contacts, and providing efficient resources(e.g., responding to emergencies and providing HR support);
preventing wrongdoing and unauthorized access to our IT, communications systems and network (e.g., IT security, IT administration, record activity, system monitoring and access logs);
responding to HR-related questions and supporting our HR operations generally (e.g.,administration, communication, running diversity and inclusion initiatives, worker safety, absence management, helpdesk, IT support services);
establishing employee training, reviewing work performance and determining performance requirements and disciplinary actions or termination;
complying with the laws and regulations (e.g., labor and employment laws, health and safety, tax, anti-discrimination laws, fraud prevention), disclosing to affiliated organizations for administrative tasks, Worker monitoring for safety or management, for the establishment, exercise, or defense of legal claims, and performing internal and/or external or governmental compliance investigations or audits; and
other legitimate purposes reasonably required for day-to-day operations, such as accounting, financial reporting, business planning, employee management, compiling internal directories, such as employee directories and research purposes.

5. WITH WHOM WE SHARE YOUR INFORMATION

We take care to ensure your PI is only disclosed to those who really need it in order to perform their tasks and duties, and to third parties who have a legitimate purpose for accessing it.

To run our business, we may share your information with other Workers, Accredible affiliates and subsidiaries, contractors, consultants and service providers who require the PI to help us establish, manage or terminate your employment with Accredible, including parties that provide products or services to us or on our behalf, parties that collaborate with us to provide services to you, or to law enforcement if we’re served with a court order, a subpoena, receive a valid legal request, or we reasonably believe it is necessary to protect the rights or safety of you or the team. For example, we may engage third parties such as employee benefit plan providers, payroll support services and employee travel management services. In some cases, these parties may also provide certain IT and data processing services to us so that we can operate our business. When we share PI with these parties, we typically require that they i) use or disclose that PI only as instructed by Accredible and in a manner consistent with this Privacy Notice, and/or ii) enter into contracts with us to ensure they respect the confidentiality of your PI and have appropriate data security measures in place. If you post content to Intra-Company Sites or our public-facing sites, other Workers or parties may have access to the information you post.While we expect all Workers to use professional judgment and treat other Workers fairly, we are not responsible for practices of the individuals who view and use such information.

Additionally, if we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another entity, your PI may be transferred as part of such an event. Any such acquirer or successor of Accredible may continue to use your PI as described in this notice, unless you consent otherwise.

6. YOUR RIGHTS TO YOUR INFORMATION

In accordance with applicable law, you may have certain rights to your PI. In particular, the right to access, correct, or delete the personal data Accredible holds about you.

Right to Access. This is the right to request confirmation of whether we are processing your PI and request access to or a copy of the information we hold about you.
Right to Correct. This is the right to ask us to correct information we hold about you if it is inaccurate, untrue, or incomplete. It is important that the information contained in our records is both accurate and current.
Right to Delete. This is the right to ask us to delete information we hold about you, subject to certain exceptions prescribed by law. You can also ask that we delete personal data that you believe is inaccurate or no longer relevant in this same way.

In addition to being able to access, update, and delete your PI, you may also have other data protection rights. These rights may include:

The right to object to our use of your PI;
The right to restrict how we use your PI;
The right to withdraw consent if we collected and processed your PI based on your consent. Note: Withdrawing your consent will not affect the lawfulness of any processing we carried out prior to your withdrawal, nor will it affect processing of your personal data carried out in reliance on other lawful grounds other than consent; and
The right to request a copy of your PI an electronic format or ask us to send that information to another company (the ‘right of data portability’);

If you would like to exercise any of these rights, please use the contact details provided in the“Contact Us” section below. To protect your privacy, Accredible will take steps to verify your identity before fulfilling your request. In certain cases, we may not be able to comply with a request, such as when providing access might infringe someone else’s privacy rights or impact our legal obligations. However, all requests will be processed and evaluated in accordance with applicable laws. If you are a Worker or Applicant who lives in the European Economic Area, Switzerland, the United Kingdom, or Brazil, you may have the right to lodge a complaint with a supervisory authority if you believe our processing of your PI violates applicable law.

7. HOW WE PROTECT YOUR INFORMATION

We use appropriate technical and organizational security measures to protect the security of your PI both online and offline including the implementation of access controls, implementation of firewalls, network intrusion detection and use of anti-virus software. We work hard to ensure that your information is kept secure and in accordance with this Privacy Notice. That said, no system is 100% secure. While we strive to protect your PI, we cannot guarantee unauthorized access or a data breach will never occur and are not liable for any such unauthorized disclosure.If that does happen, we’ll work with you and provide help consistent with the provisions of this Privacy Notice. If you have any questions about the security of your PI, please contact us using the contact details provided in the “Contact Us” section below.

8. RETENTION OF YOUR INFORMATION

We will retain and use your PI as necessary to fulfil the purpose for which it was collected, comply with our legal obligations, resolve disputes, and enforce our agreements, including to conduct audits, ensure we comply with applicable laws, carry out HR operations, etc. Once we’ve fulfilled these purposes, we endeavor to safely and securely destroy, and delete the data we’ve collected about you.

9. THIRD-PARTY WEBSITES/APPLICATIONS

Various resources and sites at Accredible may contain links to third party websites/applications and other websites/applications may reference or link to Accredible. These third-party services are not controlled by us, and their privacy practices may differ from those of Accredible. We encourage Applicants and Workers to read the privacy policies of any website you interact with.We do not endorse, screen, or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

10. UPDATES TO THIS PRIVACY NOTICE

We may revise this Privacy Notice from time to time due to changes in applicable laws or regulations or because of changes to our privacy practices made in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you as required by applicable law.You understand and agree that you will be deemed to have accepted any such updated PrivacyNotice if you do not object prior to the date such new Privacy Notice takes effect. We encourage you to periodically review this page for the latest information on our privacy practices.

11. CONTACT US

If you have any questions related to this Privacy Notice or to correct, update, amend or request that we remove your PI, please feel free to reach out to us by emailing legal@accredible.com or by contacting our People Operations (Human Resources) Department.

For our current Workers, there are some tools available for you to access, view and update the PI that we hold. If your PI is not accessible using these self-help tools or you have a different request or concern, please contact your local HR team.

Pinpoint Privacy Policy

Accredible (“we”, “us”) are committed to protecting and respecting your privacy. This Privacy Notice sets out the basis on which the personal data collected from you, or that you provide to us, will be processed by us in connection with our recruitment processes.

For the purpose of the General Data Protection Regulation (“GDPR”) the Data Controller is Accredible.

We use Pinpoint, an online software product provided by The Infuse Group Ltd (t/a Pinpoint Software), to assist with our recruitment process. We use Pinpoint to process personal information as a data processor on our behalf. Pinpoint is only entitled to process your personal data in accordance with our instructions

Where you apply for an opportunity posted by us, these Privacy Notice provisions will apply to our processing of your personal information, in addition to our other Privacy Notice which is available on our website.

Your Personal Information

Information we collect from you

We collect and process some or all of the following types of information from you:

Information that you provide when you apply for a role. This includes information provided through an online application, via email, in person at interviews and/or by any other method.
In particular, we process personal details such as name, email address, address, date of birth, qualifications, experience and any information relating to your employment history, skills and experience that you provide to us.
If you contact us, we may keep a record of that correspondence.
Details of your visits to our careers website including, but not limited to, traffic data, location data and other communication data, the site that referred you to our careers website and the resources that you access.

Information we collect from other sources

Pinpoint provides us with the facility to link the data you provide to us with other publicly available information about you that you have published on the Internet – this may include sources such as LinkedIn and other social media profiles.

Pinpoint’s technology enables us to search various databases, which may include your personal data, to find possible candidates to fill our job openings. Where we find you in this way we will obtain your personal data from these sources.

Uses made of your information

Lawful basis for processing

We rely on legitimate interest as the lawful basis on which we collect and use your personal data. Our legitimate interests are the recruitment of staff for our business.

Purposes of processing

We use information held about you in the following ways:

To consider your application in respect of a role for which you have applied.
To consider your application in respect of other roles.
To communicate with you in respect of the recruitment process.
To enhance any information that we receive from you with information obtained from third party data providers.
To find appropriate candidates to fill our job openings.
To help Pinpoint improve their services.

Automated decision making / profiling

We may leverage Pinpoint’s technology to help us select appropriate candidates for us to consider based on criteria we have identified. The process of finding suitable candidates is automatic, however, any decision as to who we will engage to fill the job opening will be made by our team.

How we store your personal data

Security

We take appropriate measures to ensure that all personal data is kept secure including security measures to prevent personal data from being accidentally lost, or used or accessed in any unauthorised way. We limit access to your personal data to those who have a genuine business need to view it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted through any online means, therefore any transmission remains at your own risk.

Where we store your personal data

The data that we collect from you and process using Pinpoint’s Services will be transferred to and stored at one of several datacentre locations in Amsterdam (Netherlands) and may be synchronised to one of several datacentre locations in London (United Kingdom) for backup and redundancy purposes. By submitting your personal data, you agree to this transfer, storing or processing.

How long we keep your personal data

We retain all candidate data for a period of 48 months from the time of application. Your personal information will be deleted on one of the following occurrences:

Deletion of your personal information by you via the Manage Your Data tool or
Receipt of a written request by you to us.

Your rights

Under the General Data Protection Regulation you have a number of important rights. In summary, those include rights to:

access to your personal data and to certain other supplementary information that this Privacy Notice is already designed to address
require us to correct any mistakes in your information which we hold
request the erasure of personal data concerning you in certain situations
request access to the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
object at any time to processing of personal data concerning you for direct marketing
object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
object in certain other situations to our continued processing of your personal data
otherwise restrict our processing of your personal data in certain circumstances
claim compensation for damages caused by our breach of any data protection laws.

If you would like to exercise any of those rights, please either:

utilise the Manage Your Data tool provided or
contact us using our contact details below, ensuring we have enough information to identify you, proving your identity and address and confirming which information to which your request relates

How to complain

We hope that we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred.