Candidate Privacy Notice

This Candidate Privacy Notice ("Candidate Privacy Notice") describes how Sigma Computing, Inc., its subsidiaries, and its affiliates (collectively "Sigma", "we", and "us") collect, use, and process your Personal Data in the context of our recruitment and hiring activities, and what choices you have around this activity. As used in this Candidate Privacy Notice, "Personal Data", means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. This Candidate Privacy Notice also includes additional information for specific jurisdictions, which is available in our Supplemental Notices.

Privacy Notice Contents.

Applicability of this Privacy Notice
Personal Data We Collect and Process
Sources of Personal Data
Our Uses of Personal Data
Our Uses of Sensitive Personal Data
Disclosure of Personal Data and Sensitive Personal Data
Data Retention
Rights And Obligations
International Data Transfers
Storage, Access, and Security
Use of Automations
Changes to This Privacy Notice
Contact Us
Supplemental Notices

1. Applicability of this Privacy Notice.

This Candidate Privacy Notice applies only to Sigma’s processing of Personal Data about job applicants, and other individuals who apply for jobs with Sigma or otherwise engage with Sigma’s recruitment and hiring processes ("Candidate", "you" or "your").

Our processing activities in connection with your use of or interaction with Sigma websites, such as Sigma’s Career Site (collectively "Sites"), including our use of cookies and similar technologies on our Sites, are not in scope for this Candidate Privacy Notice, and are covered instead by our Website Privacy Notice and Cookie Notice respectively. This Candidate Privacy Notice does not address, and we are not responsible for, the practices of any third parties, which have their own rules for how they collect and use your Personal Data. Links to third-party websites or services on our Site are not endorsements. This Candidate Privacy Notice does not form part of any contract of employment or engagement you may have with Sigma. Sigma’s processing of Personal Data is in all cases subject to the requirements of applicable national, federal, state, and local laws, and Sigma’s internal policies and procedures. To the extent this Privacy Notice conflicts with applicable laws in your location, the applicable law in your location shall control.

2. Personal Data We Collect and Process.

Personal Data that we collect and process may vary depending upon the circumstances, including the job role/position you applied for, the specific job qualifications and responsibilities, the job location, and the Personal Data you voluntarily provide (or that you authorize to be provided on your behalf). The types of Personal Data we collect and process include:

Identifiers and personal details, such as name, contact information (such as email address, phone number, current home address and previous home addresses), unique identifiers, government issued ID, work permit and/or visa information;
Employment, education, and professional information, such as employer details, job title, job duties/responsibilities, compensation, employment history, professional licenses and permits, memberships, certifications, skills, education history, transcripts, such as academic degrees;
Application and background information, including
◦ Information submitted as part of or inferred from your job application materials such as resume/CV, cover letter, social media profile, photo, and portfolio, information on webpages/websites you share with us in your job application;
◦ Information you provide regarding your referees and information your referrers provide about you; and
◦ Work preferences and expectations, like your current and desired salary and other terms relating to compensation and benefits packages, your willingness to relocate, other job preferences and whether you are subject to any prior employer obligations;
Assessment Information, such as
◦ Information collected during phone-screens, interviews, evaluations, take-home tests, live assessments, and other recruiting exercises ("Assessments");
◦ Outcomes of any Assessments you take or complete;
◦ Information voluntarily disclosed during Assessments; and
◦ Audio and visual recordings of Assessments, including and records during Assessments of your activities on the Third-Party Services, screen-captures, screen recordings, and usage information. (Sigma will not record or store any video or audio during Assessments or assessments that knowingly include your facial image or voice without your consent).
Information you make publicly available through job search or career networking sites, such as such as contact information, your education, and work experience information (e.g. when you share information via job search and professional career networking sites such as LinkedIn, as far as it is relevant to consider you for career opportunities).
Communication information, such as information provided in emails you may send or receive in connection with your application or recruitment process, and logs of communication between you and recruitment personnel, including email exchanges, phone calls, and other contact methods.
Geolocation Data, such as home address, city, postal code, and country of residence.
Information collected via technology, including links clicked, language preferences, IP addresses, device type, operating system and internet browser type, screen resolution, operating system name and version, language, plug-ins, and add-ons.
Premises related records, such as information about your access to our premises if you are invited to attend Assessments or other recruiting activities, including access records from our facility entry systems, your details on any temporary passes, your I.D. documentation and information captured our site security systems such as CCTV systems.
Sensitive Personal Data, such as
◦ Background and Screening Information, including information necessary to complete background, credit, criminal record, and/or other checks, when permitted by law, and information received during these checks;
◦ Government identifiers, such as social security number and government-issued photo ID such as a driver’s license or passport;
◦ Information related to your immigration and right-to-work status, including your nationality, citizenship, visa status, and right to work authorizations;
◦ Health-related information, including physical or mental disability and information relating to accommodations that you may request during the recruiting process; and
◦ Demographic information, such as gender, date of birth, racial or ethnic origin, trade union membership, sexual orientation, disability information, and veteran status, that you voluntarily provide us with.
Inferences drawn from the information above such as preferences, characteristics, predispositions, behavior, or attitudes based on other Personal Data collected about you.

3. Sources of Personal Data.

We collect Personal Data about you from the following sources:

From you directly, such as when you send an email to Sigma, submit your job application, or during interviews. We may also collect Personal Data though systems and technology that you use as part of your application, including system usage data and service access logs;
From our third-party service providers that Sigma has contracted with for the facilitation of the recruitment and hiring process, such as job boards, recruitment platform, assessment platform providers, and pre-employment and background screening service providers ("Third-Party Services"). These Third-Party Services may collect your information from publicly available sources, from you directly, or through third parties they work with; and
From your referees and agencies such as recruitment agencies, staffing providers, professional references, previous employers, who have the rights or your consent to provide us with your information, including certain education and work experience, contact information etc.

4. Our Uses of Personal Data

We collect, use, and process your Personal Data described above for our recruitment and hiring processes, and our business purposes for collecting your Personal Data include:

4.1 To consider you for, and assess your suitability for, employment opportunities with Sigma, including

To receive, review and reply to your job application;
To schedule, conduct, and facilitate your participation in Assessments;
To recommend potential role or team matches based on your job application, and to suggest suitable opportunities for you at Sigma;
To check your references, and if you were referred, to inform the referrer of the status and final outcome of your application;
To verify the information, you or others provide;
To determine whether you are a suitable candidate, including by evaluating your job application materials and performance during Assessments;
To determine whether and when to make an offer of employment, including to prepare an offer letter, if your application is successful;
To conduct background checks and other pre-employment screening, where permitted by law; and
To determine immigration and work-authorization status and assess your eligibility to work for Sigma in the relevant location.

4.2 To communicate with you regarding your job application, including

To follow up with you regarding your current submitted application, and any relevant previously submitted applications;
To communicate with you regarding future opportunities at Sigma, and recommend potential role or team matches;
To respond to and manage accommodation requests for disabilities or health conditions, and make necessary adjustments, where permitted by or required by applicable laws;
To resolve any issues that you encountered during the recruitment process, or to collect, investigate, and resolve any complaints you make regarding the recruitment or hiring process;
To consider referrals regarding your candidacy; and
To respond to your requests or questions.

4.3 For compliance, fairness, and fraud prevention purposes, including

To comply with and monitor our compliance with applicable laws and regulations, such as ensuring equality of opportunity and diversity under applicable anti-discrimination laws;
To verify your identity and ensure compliance with the Sigma’s recruitment, hiring, and assessment related policies;
To investigate and prevent fraud, misrepresentation, use of unauthorized tools, and other unauthorized, unethical or illegal activity during the recruitment process;
To allow, investigate, and resolve a complaint under Sigma’s grievance, whistleblowing, anti-harassment or similar policies where your Personal Data is are relevant to the particular complaint;
To comply with lawful requests and legal process, such as responding to subpoenas or requests from government authorities;
To protect the rights and property of Sigma, its users, applicants, candidates, employees or the public as required or permitted by applicable laws;
To maintain the safety, integrity, and security of Sigma, its employees and other members of staff, and others as required or permitted by applicable laws; and
To enforce our legal rights and obligations, and for any purposes in connection with any legal claims made by, against or otherwise involving you.

4.4 For Sigma’s Security, Business, Operational and Administration purposes, including

To maintain and monitor the security of the Sigma’s systems, applications, and networks, including to investigate and prevent suspicious activity;
To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted Personal Data;
To identify and address malicious, deceptive, fraudulent, or illegal actions;
For our business and internal management activities, such as for conducting or participating in audits, investigations, mergers and acquisitions, and as required for maintaining business operational and reporting documentation;
To maintain records of our recruitment and hiring process and interactions with you;
To prepare and perform management reporting and analysis related to recruiting metrics;
To create and submit reports as required by applicable law or regulation; and
To maintain and operate the relationship with Service Providers, and Sigma’s customers, including the disclosure of relevant vetting information in accordance with relevant requirements of regulated customers.

4.5 To manage, maintain, develop, and improve our recruitment and hiring process, including

To enhance the interview process by generating recordings, summaries and transcripts;
To analyze, develop, and improve our recruitment process, including by developing and conducting relevant trainings for hiring managers;
To conduct surveys, research, or benchmarking or collection of feedback on our recruitment and hiring process, Sigma, or our products; and
To research, analyze, develop, train, test, provide, maintain, and improve Sigma products, and services.

4.6 To otherwise communicate and engage with you, such as

To contact you from time to time, regarding relevant job openings, and to invite you to events we organize or sponsor; and
To send you alerts or recommendations about opportunities at Sigma or ask you for updates.

You can opt-out of these communications under Section 4.6 at any time, by clicking the unsubscribe links (or the equivalent in our communications), or by filling this form.

5. Our Uses of Sensitive Personal Data.

We use and process your Sensitive Personal Data to fulfill our lawful business purposes including:

To carry out our obligations, including in the field of employment, health and safety, social security and, where reasonably necessary, for the establishment or defense of legal claims.
In an aggregated manner to produce diversity statistics in order to support internal diversity initiatives and equal opportunity.
To verify your eligibility to work in a specific location, conducting background verifications (to the extent permitted by applicable laws) and other legally required verifications and screenings;
To provide you with requested accommodations and adjustments; and
To perform other services and/or actions that you specifically consent to or which are reasonably expected by an individual in the context of their candidacy for employment.

6. Disclosure of Personal Data and Sensitive Personal Data.

We disclose your Personal Data as described in this Section 6 and as described elsewhere in this Candidate Privacy Notice.

Service Providers. We may disclose your Personal Data to third-party service providers in order for those providers to perform business functions on behalf of Sigma, including to manage and operate our recruitment and hiring process, and as required the purposes described in Section 4 and Section 5, including job boards, recruiters, assessment platforms, and pre-employment screening providers (collectively "Service Providers").
Third Parties Designated by You. We may disclose your Personal Data to third parties that you designate to receive such information, such as your reference provider or recruitment agencies with whom you provided your Personal Data ("Designated Recipients").
Affiliates. We may disclose your Personal Data to our parent company, subsidiaries, joint ventures, or other companies under a common control ("Affiliates"), in which case we will require our Affiliates to honor this Candidate Privacy Notice.
Legal compliance. We may disclose your Personal Data to comply with our legal obligations, respond to a court order, adhere to administrative or judicial processes (such as a subpoena, government audit, or search warrant), or respond to lawful requests by public authorities (such as national security or law enforcement). The recipients of your Personal Data in accordance with this paragraph are referred to as "Law Agencies" in this Candidate Privacy Notice.
Corporate Restructuring. We will disclose or transfer your Personal Data in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. We will inform any buyer that your Personal Data may only be used in accordance with this Candidate Privacy Notice. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Candidate Privacy Notice.
Legitimate and Vital Interests. We may disclose your Personal Data where it is necessary for our legitimate interests, including, to establish, exercise or defend against potential, threatened or actual litigation, establish or defend our legal rights, and to investigate or assist in preventing any violation or potential violation of applicable law or our recruitment and hiring policies. We may also disclose your Personal Data where necessary to protect your vital interests or the vital interests of another person.
Other Disclosures. We may disclose your Personal Data to fulfill the purpose for which you provide it; for any other purpose disclosed by us when you provide it; or with your consent.

When we disclose your Personal Data to third-parties who perform processing activities for or on behalf of Sigma, including Service Providers and Affiliates we require them to abide by contractual, technical, and organizational measures that address the safeguarding and proper use of your Personal Data, and ensure that your Personal Data is processed only to the extent that such processing is necessary, consistent with this Candidate Privacy Notice, and in accordance with applicable law.

7. Data Retention.

We retain your Personal Data only so long as reasonably necessary to fulfill the purposes for which it was collected, or as otherwise required by law. Specifically,

If you are successful in the recruitment process and are hired by Sigma, the Personal Data processed in connection with your application will become part of your employment record and will be retained in accordance with our standard employee data retention practices.
If you are unsuccessful in the recruitment process and we decide not to proceed with your candidacy, Sigma may retain your Personal Data for a reasonable amount of time, as permitted by law to (a) implement our cool-down period restrictions during which you may not apply for the same or similar roles with Sigma, (b) consider you for future roles with us, (b) comply with applicable laws and defend against potential claims, lawsuits, or disputes related to our recruitment decision, and (c) help us analyze and improve our recruitment and hiring processes.

We securely delete or anonymize your Personal Data, when retention of such data is no longer reasonably necessary, as described above. If you have any questions regarding our retention policies or wish to make specific requests regarding the retention of your Personal Data, please contact privacy@sigmacomputing.com. We will take commercially reasonable efforts to comply with your reasonable requests, and where we cannot comply with your requests, we will provide you with our reasons for such non-compliance without unreasonable and u delay.

8. Rights And Obligations.

8.1 Your Rights.

Depending on your region, and/or your residency, your local data protection and privacy laws may grant you rights with respect to your Personal Data (as further described in the Supplemental Notices). These rights differ based on the local laws that apply to you but could include one or more of the following:

Right to know (and/or access) the Personal Data that we hold about you, including access to duplicates of the Personal Data retained.
Right to correct your Personal data if it is inaccurate, outdated, or incomplete.
Right to request deletion of irrelevant Personal Data that we hold about you.
Please note: • If we delete your Personal Data, we may no longer be able to process and evaluate your application for a position at Sigma. • We may have an overriding lawful basis for retaining your Personal Data (e.g., we may have to retain your Personal Data pursuant to our legal obligations).
Right to limit processing, use, or disclosure of your Sensitive Personal Data;
Right to withdraw consent, where we have relied on your consent to process certain Personal Data;
Right to request suspension of processing your Personal Data in certain circumstances, including when you believe that the Personal Data we hold about you is inaccurate or unlawful;
Right to file a complaint with a supervisory authority;
In certain US states, you may also have a right to opt-out of sale, sharing, targeted advertising, profiling or cross-context behavioral advertising, and from automated decision making technologies

8.2 Exercising Your Rights.

To exercise your rights or to submit an appeal of a denial of your privacy rights, please contact us by

Emailing us at privacy@sigmacomputing.com
Using this link to submit your request.

8.3 Your Obligations.

Among other obligations, including without limitation the obligation to provide complete and accurate information in recruiting documents and processes, it is your responsibility to ensure that information you submit does not violate any third-party’s rights. You should keep your Personal Data on file with Sigma up to date and inform us of any significant changes to it.

8.4 Our Obligations.

We value your privacy and will not discriminate in response to your exercise of your privacy rights. We will take commercially reasonable efforts to confirm receipt of your request within 10 business days and will respond to your request within 30 to 45 calendar days (subject to the applicable privacy regulation in your region, and after requisite verification), unless we need additional time, in which case we will let you know. We may charge you a reasonable fee in instances that require a disproportionate effort, but we will advise you of any fee in advance. We may decline to process requests that are frivolous, unreasonably repetitive or burdensome, risk the privacy or impact the rights of others, or are extremely impractical.

8.5 Verification.

We may request certain information about you or your interactions with Sigma to verify your identity before we can respond to your requests to exercise your rights. This is done to protect your privacy and maintain security. We may require you to verify your name, region/country, location, email address, home address, and/or phone number in our records and provide information about your prior applications with Sigma (such as roles and positions for which you previously applied). In certain limited circumstances, we may require you to sign a declaration under penalty of perjury that you are the candidate whose Personal Data is the subject of the request.

8.5 Agent Requests.

You may authorize someone to make a privacy rights request on your behalf (an authorized agent). Authorized agents will need to demonstrate that you’ve authorized them to act on your behalf or must demonstrate they have power of attorney pursuant to applicable probate law. Sigma retains the right to request confirmation directly from you confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent’s identity. An authorized agent is prohibited from using your Personal Data, or any information collected from or about you, for any purpose other than to fulfill your requests, for verification, or for fraud prevention.

9. International Data Transfers.

Sigma’s global organizational structure requires the global transfer of Personal Data to Sigma’s Affiliates, Sigma’s business partners, and other third parties as described in Section 6 of this Candidate Privacy Notice. Your Personal Data may be transferred to, stored, and processed in a country other than the one in which it was provided. Sigma will ensure that appropriate or suitable safeguards are in place to protect the transferred Personal Data and that transfer is in compliance with applicable data protection laws.

For transfers of Personal Data from territories other than EEA and UK, and to the extent required by applicable laws, we have implemented data transfer agreements and/or obtained your consent, to securely transfer your Personal Data to territories other than the one in which it was provided your Personal Data or your home country.
For transfers of Personal Data from the EEA, and the UK to third parties (such as Service Providers) outside of these territories, we implement appropriate data transfer mechanisms, as further described in the Supplemental Notice for EEA/UK Candidates.
For transfers of Personal Data between Sigma legal entities, we have implemented data transfer agreements with appropriate safeguards, such as the Standard Contractual Clauses approved by the European Commission and the UK International Data Transfer Addendum (as applicable) to enable the transfer of the Personal Data. Additionally, Sigma Computing, Inc. is certified under the Data Privacy Framework Program (DPF) as further described in our Website Privacy Notice.

If you have any inquiries or complaints about the handling of your Personal Data, please contact us in accordance with Section 13 of this Candidate Privacy Notice.

10. Storage, Access, and Security.

We maintain an automated record of your Personal Data in certain recruitment and hiring applications (such as Greenhouse, LinkedIn, CoderPad etc.). Sigma has implemented appropriate technical, physical and organizational measures designed to provide industry standard security appropriate to the risk. Access to your Personal Data is restricted to those individuals who need such access for the purposes listed in Section 4 and Section 5. All Sigma personnel who are permitted to access Personal Data are bound by and required to abide by contractual, technical, and organizational measures that address the safeguarding and proper use of your Personal Data and are also regularly provided with privacy related training.

11. Use of Automations.

We may process your Personal Data using artificial intelligence, machine learning, and other automated tools (collectively "Automations") to sort through candidate and application information, help us make decisions about your candidacy, and to identify other roles/positions for you within Sigma. While Automations may be used to aid Sigma personnel in summarizing, scoring, and/or ranking job applications and materials related thereto, the Automation recommendations ("Automation Results") do not substantially replace human decision making. Automation Results are not treated as binding and are used as reference or guidance only. Sigma ensures that there is human review of any Automation Results substantially relied on in making any decisions regarding your candidacy. You may contact us in accordance with Section 13 to request further information about how these Automations work, and may also request that your application be reviewed without substantial reliance on Automations.

12. Changes to This Privacy Notice.

We reserve the right to change this Candidate Privacy Notice at any time. The "Last Updated" heading in this Privacy Notice indicates when it was last revised. Any changes will be posted on this page with an updated revision date. It is your responsibility to periodically review this Candidate Privacy Notice to remain informed about our collection, processing and sharing of your Personal Data. We may, in our sole discretion, provide you communications, including via email, about changes to our Candidate Privacy Notice; however, such communications do not abrogate or otherwise limit your responsibility to periodically review the Candidate Privacy Notice to determine whether any amendments have been made hereto.

13. Contact Us.

If you have any questions about this Candidate Privacy Notice or our privacy practices, or would like to access the information it contains in a different format please contact us at privacy@sigmacomputing.com or write to us at: Sigma Computing, Inc., 116 New Montgomery St. Suite 700, San Francisco CA 94105

14. Supplemental Notices.

Additional information for Candidates residing in certain jurisdictions is available in the following Supplemental Notices: