Effective Date: August 28, 2024
Introduction
This Applicant Notice explains how the Company and its affiliates, collect, handle and use personal data we collect relating to job applicants (“Applicant Notice”). Where we refer to “we” or “our” or “us” we are referring to the Company and its affiliates, and where we refer to “you” or “your” we are referring to job applicants. In the event that you become an employee of the Company you will be provided with a separate privacy Employee Notice.
Information We Collect
Information You Provide Us
The Company collects and processes certain information, including personal data, about you that you may provide to us for recruitment purposes to the extent permitted under local law, including:
Contact information (such as your name, address, email address, and telephone number);
Your qualifications, education skills, work experience and employment history;
Your remuneration including benefit entitlements;
Other content you provide (such as references, transcripts, photographs, videos, articles, and comments);
Information about your entitlement or eligibility to work;
Certain demographic information, such as age, date of birth, gender;
Interview records and interview test results; and
Information from public profiles.
We may collect this information in a variety of ways, including:
Through application forms (online and electronic), CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment;
Through CVs or resumes, obtained from recruiters who submit it to us on your behalf; and
Through third parties, such as references supplied by former employers. We will seek information from third parties generally once a job offer to you has been made and will inform you that we are doing so.
Special Categories of Personal Data
We also collect and process special categories of personal data in particular health data, including whether or not you have a disability for which the organization needs to make reasonable adjustments during the recruitment process, and other special categories of personal data such as racial or ethnic origin.Depending on the role that you apply for, and only if we offer you a contract of employment, we will also process criminal records and information regarding criminal offences or proceedings if revealed in a background check. For roles involving the processing of financial information, we are also obliged to seek information about your credit history.
Information We Collect By Automated Means
When you visit our ‘Careers at Ripple’ website, we obtain certain information by automated means, such as cookies, web beacons, web server logs and other web tracking technologies. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. We may use these automated technologies to collect information about your equipment, browsing actions, and usage patterns. The information we obtain in this manner may include your device IP address, identifiers associated with your devices, types of devices connected to our services, web browser characteristics, device characteristics, language preferences, referring/exit pages, clickstream data, and dates and times of visits to our Careers Site.The information we collect through cookies and similar technologies helps us (1) remember your information so you will not have to re-enter it; (2) understand how you use and interact with our website; (3) measure the usability of our website and the effectiveness of our communications; and (4) otherwise manage and enhance our website and help ensure it is working properly. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. You can also opt-out of receiving cookies by adjusting your browser settings. Please note, however, that without cookies you may not be able to use all of the features of our website.
Legal Bases for collection and use of your personal data:
At all times, we intend to collect and process your personal data in accordance with applicable data protection laws. This means that we collect and process personal data for one of the following legal reasons, apart from in exceptional circumstances where we may rely on other legal bases permitted by law, such as where we consider that the processing is in your (or another’s) vital interests.The legal bases include:
In limited circumstances (for either ordinary or special categories of personal data), where we have your free and explicit consent. In principle, we do not rely on your consent for processing data. However, in limited circumstances we may approach you for your consent to allow us to process certain personal data. If we do so, we will provide you with full details of the data that we would like and the reason we need it, so that you can carefully consider whether you wish to freely consent. We will also inform you about the fact that you can revoke your consent at any time and how you should do that. You should be aware that withholding your consent will never have an impact on your potential employment with us or will otherwise negatively affect you. You may revoke your consent at any time as set forth in the “YOUR RIGHTS” section below;
Processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract (for example, to draft your employment contract, to manage benefits in connection with your potential employment, to liaise with your pension provider, etc.);
Processing is necessary for compliance with a legal obligation to which we are subject;
Processing is necessary for the performance of a task carried out in the public interest; and
Processing is necessary for the purposes of our or a third party’s legitimate interests (for example to secure, defend and develop our business and people and to make strategic and corporate responsibility decisions that we deem necessary), except where such interests are overridden by your interests or fundamental rights and freedoms.
In the case of special categories of data, we may rely on the following additional legal bases:
In limited circumstances, that you have given explicit consent to the processing (see above);
Processing is necessary for the purposes of carrying out the obligations and exercising rights in the field of employment law and social security law so far as permitted by local law;
Processing relates to personal data which you have manifestly made public;
Processing is necessary for the establishment, exercise or defence of legal claims;
Processing is necessary for reasons of substantial public interest, on the basis of local law; and
Processing is necessary for the purposes of preventive or occupational medicine, for the assessment of your working capacity, medical diagnosis, on the basis of local law or pursuant to a contract with a health professional and subject to safeguards provided by law.
How We Use Your Information
We process your Personal Data for the purpose of administrating your application process. More specifically, we use your Personal Data:
To administer and manage your application process; carry out our human resources functions and activities and in order to take pre-contractual steps at your request;
To evaluate your education and working skills, qualifications and your suitability in connection with your selected job opening and/or for available positions;
To take measures to verify that the information you have provided is true and accurate, such as reference checks;
To conduct (criminal and credit) background checks to the extent authorized by law and as required for your role;
To keep your record for future hiring needs, including for the purpose of contacting you regarding possible employment;
To deal with legal disputes and to establish, exercise and defend (potential) legal claims;
For monitoring equal employment opportunities; and
To comply with applicable (employment) laws and regulations, in particular health and safety and anti-discrimination legislation.
How We Store Your Information
Your personal data will be stored in a range of different places, including on your application record, in our Human Resources management systems and on other IT systems (including email). We are subject to legal duties to take good care of personal data and apply security measures which are consistent with its sensitivity.
How We Share Your Information
Your information may be shared for the purposes of the recruitment exercise. This includes members of the Company’s Human Resources department and the Recruiting team, interviewers involved in the recruitment process, managers in the business area with a vacancy, and IT staff if access to the data is necessary for the performance of their roles.If your application for employment is successful, we will then contact your former employers to obtain references for you, and depending on the role that you have applied for, with employment background check providers (as permitted by local law) to obtain necessary background checks.We also may disclose personal data about you: (1) if we are required to do so by law or legal process; (2) for the purposes of, or in connection with, any legal proceedings, or otherwise for the purposes of establishing, exercising or defending any legal rights; (3) to law enforcement authorities or other government entities based on a lawful disclosure request; or (4) when we believe disclosure is necessary or appropriate to prevent harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.We reserve the right to transfer personal data we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation). Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use personal data you have provided to us in a manner that is consistent with this Applicant Notice. Following such a sale or transfer, you may contact the entity to which we transferred your personal data with any inquiries concerning the processing of that information.
Transfer Personal Data To Other Countries
We transfer your personal data to countries outside the United Kingdom, the European Economic Area (“EEA”), or Switzerland, including, but not limited to the United States, where our Human Resources Department and Recruiting team is located, and where our Human Resources management systems and on other IT systems (including email) are located.If we transfer your personal information out of the European Economic Area, United Kingdom, or Switzerland and are required to apply additional safeguards to your personal information under European data protection legislation, we will do so. Such safeguards may include applying the European Commission-approved standard contractual data protection clauses or other appropriate legal mechanisms.
Personal Data Sub-Processors
We use the following sub-processors to store and manage job applicant records:
Third-Party Service or Vendor | Service | Location |
Greenhouse | Job Applicant Tracking System | United States |
Navan | Travel and Expense Service Provider | United States |
Avigilon | CCTV Security Provider | United States |
Envoy | Visitor Registry Service Provider | United States |
Our Commitment to the EU-U.S. Data Privacy Framework Principles, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework Principles
Ripple Labs Inc. and Ripple Services Inc. complies with the EU-U.S. Data Privacy Framework Principles, the UK Extension to the EU-U.S. Data Privacy Framework and the Swiss-U.S. Data Privacy Framework Principles (collectively, the “DPF Principles”). Ripple has certified to the U.S. Department of Commerce that it adheres to the DPF Principles with regard to the processing of personal data received from the European Union, United Kingdom and Switzerland in reliance on the DPF Principles. Ripple is committed to protecting your personal information and continues to comply with these frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom, and Switzerland to the United States. If there is any conflict between the terms in this Privacy Policy and the DPF Principles, the DPF Principles shall govern. To learn more about the DPF Principles program, and to view our certification, please visit https://www.dataprivacyframework.gov/.In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Ripple commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK individuals and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact Ripple at hr@xn--rpple-m3a.net or at our U.K. mailing address at:Ripple Labs Inc.
1 Angel Court, 16th Floor
London, EC2R 7HJ
United KingdomIn compliance with the DPF Principles, Ripple commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF in the context of the employment relationship.Ripple is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). Under certain circumstances you may request arbitration by the Data Privacy Framework Arbitration Panel for resolution of any claimed violations of the Principles not resolved by any of the other EU-U.S. DPF mechanisms. For more information, please visit https://www.dataprivacyframework.gov/s/article/A-Scope-dpf?tabset-35584=2. In cases of onward transfer to third parties of personal information received pursuant to the DPF Principles, Ripple shall remain potentially liable.
How We Protect Your Information
We are committed to protecting the security of your information. We maintain appropriate administrative, technical and physical safeguards designed to protect the personal data you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
How Long We Retain Your Data
If your application for employment is successful, relevant personal data gathered during the recruitment process will be transferred to your Human Resources file (electronic and paper copies). At this stage, your personal data will be processed in accordance with our Employee Notice.If your application is unsuccessful, we may keep your personal data on file for 12 months in the UK, Switzerland and Iceland and for 15 months in Ireland from the date that you are notified of your unsuccessful application in case there are future employment opportunities for which you may be suited. We will use your personal data for this purpose in light of our legitimate interests in staffing vacancies. If you do not wish for us to keep your data, please contact us (see below for our contact information).
Your Rights
You have the following rights with regards to your personal data, subject to local law, as set out below:
Right to Access
You have the right to request certain information and to access personal data that we hold and to request a copy of your data.
Right to Correction and Deletion:
We will take steps to maintain correct personal data. We encourage you to keep us up to date in order to ensure that changes in personal circumstances (for example, change of address, etc.) are reflected in our database. You have the right to request correction of any inaccurate personal data relating to you or to request deletion of any irrelevant personal data we hold about you.
Right to Restrict Personal Data Usage:
You have the right to restrict our use of your personal data in certain circumstances.
Right to Data Portability:
In certain circumstances, you may be entitled to receive your data in a structured, commonly used and machine-readable format, and also to require us to transmit it to another data controller where this is technically feasible.
Right to Object
In certain circumstances, you may be entitled to object to our processing of your data.
Right to Withdraw Consent:
In the event your personal data is processed on the basis of your consent, you have the right to withdraw consent at any time by sending an email to hr@xn--rpple-m3a.net specifying your request, without affecting the lawfulness of processing based on consent before its withdrawal.
Right to Lodge a Complaint:
In compliance with the DPF Principles, Ripple commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF in the context of the employment relationship.You have the right to lodge a complaint with a supervisory authority in your country of residence if you believe that the organization has not complied with this Applicant Notice or your data protection rights. For the UK, you can contact the Information Commissioner’s Office at 01625 545740 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF. If you are in Europe, you can find your local supervisory authority here.Please note that we may need to retain certain personal data for record keeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. For further information regarding your rights, or to exercise any of your rights, please contact us at hr@xn--rpple-m3a.net.
CCTV (Closed Circuit Television) / Surveillance
We have installed CCTV systems in some of our premises used by members of the public, visitors to our office, and our employees. The principal purpose of the CCTV system is for the prevention and detection of crime, and to ensure the safety of employees, visitors and members of the public.Images captured by CCTV will not be kept for longer than necessary. However, on occasions there may be a need to keep images for longer, for example where a crime is being investigated. We will only disclose images and audio to other authorized bodies who intend to use it for the purposes stated above. You have the right to see CCTV images of yourself and be provided with a copy of the images.
Automated Decision-Making
Recruiting processes are not based solely on automated decision-making.
Contact Us
To submit questions regarding this Applicant Notice, or to exercise your rights you can contact us by emailing us at hr@xn--rpple-m3a.net or at our U.K. mailing address at:
Ripple Labs Inc.
1 Angel Court, 16th Floor
London, EC2R 7HJ
United Kingdom