3E Candidate Privacy Notice

3E Company Environmental, Ecological and Engineering, LLC and its affiliates (“3E,” “we,” or “us”) respects your concerns about privacy. This Global Candidate Privacy Notice (“Candidate Privacy Notice”) outlines how we, acting as a data controller, collect, use, disclose and otherwise process the personal data of our job applicants and candidates who interact with 3E online or offline during the application and recruitment process. This Candidate Privacy Notice applies to job applicants only, but supplements and should be read together with 3E’s Privacy Notice. The 3E affiliate to which you applied is the data controller of your personal data.

This Candidate Privacy Notice describes the categories of personal data we collect, how we use your personal data, how we secure your personal data, when we may disclose your personal data to third parties, and when we may transfer your personal data outside of your home jurisdiction. This Candidate Privacy Notice also describes your rights regarding your personal data that we hold about you and how you can request access to, correction of, object to or restrict processing of, portable copies of, and erasure of your personal data.

We will only process your personal data as described in this Candidate Privacy Notice unless otherwise permitted or required by applicable law.

1. How We Obtain Information About You

We may collect personal data directly from you, as an applicant for employment, internship, or other contractor position, or we may receive personal data from third parties, such as when you:

Fill out a candidate application form on our website or job application portal;
Sign-up to receive e-mail or text job alerts on the Careers pages of our website;
Attend a recruitment event we have organized;
Communicate with us (for example, on a social media platform like LinkedIn or by sending us an email); or
Participate with a background, employment or reference check, subject to your consent where required by applicable law.
Provide your information to a recruitment agency we work with, or to another 3E employee who refers you to us.

2. Information We Collect

3E may collect, store and process the following categories of personal data in connection with the job application and recruiting process: Personal contact information such as name, title, address, telephone numbers and personal email addresses.
Work history and other relevant experience including information contained in a resume, CV, cover letter, or job application.
Education information including degrees awarded, transcripts, professional certifications, and other information provided in support of your job application.
Compensation history, but only where permitted by applicable law.
Information collected during interviews or phone screenings, where permitted by applicable law.
Details regarding the type of employment sought, desired salary, job preferences, and other information related to compensation and benefits.
Information relating to any previous applications you may have made to 3E and/or any previous employment history with 3E.
Reference information and information received from background checks, where applicable, including information provided by third parties, such as recruiters.
Sensitive and/or demographic information during the application or recruitment process, such as gender, information about your citizenship or nationality, medical or health information and/or your racial or ethnic origin, to the extent permitted under applicable law.
Any additional personal details that you otherwise voluntarily provide to us.

Each form on our Site varies in the information required and collected. In some cases, an asterisk (*) indicates the required information on a form. You may choose to provide additional information within fields that are not required. The provision of full and complete information in support of a job application is necessary for selection purposes. Failure to provide any of the data may affect the processing of your application.

3. How We Use Personal Data

3E will use your personal data for the purposes of carrying out its application and recruitment process, which includes:

Assessing your skills, qualifications and interests against our career opportunities;
Verifying your information and carrying out reference checks and/or conducting background checks (where applicable) if you are offered employment;
Communications with you about the recruitment process and/or your application(s), including in appropriate cases, informing you of other potential career opportunities at 3E;
Creating and/or submitting reports as required under any local laws and/or regulations, where applicable;
When requested by you, assisting you with obtaining an immigration visa or work permit where required;
Making improvements to 3E’s application and recruitment process; and
Complying with applicable laws, regulations, legal processes, or enforceable governmental requests.

We will also use your personal data when it is necessary to protect, exercise or defend legal or property rights of 3E, our customers, applicants, candidates, employees, or the public as required or permitted by law.

If you are located in the EEA, the United Kingdom, or Switzerland, we collect and process your information where it is necessary in order to take steps, at your request, prior to our potentially entering into a contract of employment with you. We may also seek your consent to process your personal data in specific circumstances, or process it where necessary to comply with a legal obligation or for purposes connected to legal claims. If we use your information to improve our application or recruitment process, we do so on the basis that it is in 3E’s legitimate interest to ensure we recruit the best possible candidates.

4. Who May Have Access to Your Personal Data

Your information may be shared with 3E’s affiliates and subsidiaries in the United States and other jurisdictions for the purposes set forth in this Candidate Privacy Notice.
3E may use service providers that perform recruitment-related services on our behalf including for the purposes of the reference and/or background checks. These service providers may be located outside the country in which you live or the country where the position you have applied for is located.
3E may disclose personal data about you if we are required or permitted to do so by law or legal process, for example, due to a court order or a request from a law enforcement agency, or to prevent against harm to rights, property or safety of 3E, our users, applicants, candidates, employees or the public, or as otherwise required by law, or in connection with an investigation of suspected or actual fraudulent or other illegal activity
In the event we take part in or are involved in a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).

5. Data Transfers

We may transfer the personal data that we collect about you to recipients in countries other than the country in which the personal data originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the personal data. When we transfer your personal data to recipients in other countries (such as the U.S.), we will protect that personal data as described in this Notice.

If you are located in the EEA, the United Kingdom or Switzerland, 3E has certified to the EU-U.S. and Swiss-U.S. Data Privacy Frameworks for the transfer of personal data from the EEA and Switzerland, as well as the UK extension for the transfer of personal data from the United Kingdom to the United States, as described further in our Data Privacy Framework Notice. To learn more about the EU-U.S. and Swiss-U.S. .Data Privacy Frameworks, and the UK extension, please visit www.dataprivacyframework.gov/s/. To view 3E’s certification, please visit www.dataprivacyframework.gov/s/partipant-search.

6. How Long We Keep Your Personal Data

If you are offered and accept employment with 3E, the personal data we collected during the application and recruitment process may become part of your employment record and we may use it in connection with your employment consistent with our employee personal data use and privacy policies.

If you apply for a job at 3E and your application is unsuccessful (or you withdraw from the process or decline our offer), 3E will generally retain your information for a period after your application, as permitted by applicable law. We retain this information to (i) consider you for other current or future jobs at 3E (ii) to meet record-keeping requirements; or (iii) for potential use in legal proceedings. If you do not want us to retain your information, or you wish to revoke your prior consent to be considered for other roles at 3E, please contact privacy@3eco.com. Please note, however, that we may retain some information if required by law or as necessary to protect ourselves from legal claims.

7. Your Rights and Choices

If you are located in the EEA, UK, or Switzerland, you may have the following rights in relation to personal data that we hold about you. This may include the right to request access or to update or review your information, request data portability, request that it be deleted or anonymized, or object to or restrict 3E from using it for certain purposes. If you wish to exercise your data subject access rights, please contact privacy@3eco.com. We will respond to any requests in accordance with applicable law, and so there may be circumstances where we are not able to comply with your request. If you are in the EEA or the UK, you may also contact our Data Protection Officers, whose contact information may be found at the end of this notice.

Depending on your country of residence, you may also raise questions or concerns you have regarding your personal data with your local data protection authority.

8. Updates to Our Notice

We may update this Candidate Privacy Notice periodically and without prior notice to you to reflect changes in our personal data practices or relevant laws. We will post the updated version and indicate at the top of the notice when it was most recently updated.

9. Our Data Protection Officers and How to Contact Us

If you have any questions about this Notice, any issue relating to your personal data, or if you would like to make a request relating to your personal data, please contact privacy@3eco.com, or our Data Protection Officers in the following jurisdictions:

Our EU Representative
By e-mail at: privacy@3eco.com

In writing at:
3E Europe GmbH
Attention: 3E – Candidate Privacy Notice
Bergheimer Str. 3
88677 Markdorf, Germany

Our UK Representative
By e-mail at: datarequest@datarep.uk (quoting “3E” in the subject line)

In writing at:
DataRep
Attention: 3E – Candidate Privacy Notice
107-111 Fleet Street,
London, EC4A 2AB, United Kingdom

US State Law Requirements

Some U.S. state privacy laws, such as the California Consumer Privacy Act (“CCPA”), require specific disclosures for state residents. This Notice is designed to help you understand how 3E handles your information. In the sections above, we explain (1) the categories of personal data 3E collects and the sources of that information; (2) how 3E uses personal data; (3) when 3E may disclose that information; and (4) how 3E retains information. 3E does not sell or “share” (as defined in the CCPA) your personal data.

As of January 1, 2023, if you are a resident of California, the CCPA also provides the right to request information about how 3E collects, uses, and discloses your information. And they may give you the right to access and correct your information, and to request that 3E delete that information. Finally, 3E provides the right to not be discriminated against for exercising these privacy rights.

If you have questions or concerns related to your rights under the CCPA, or would like to exercise your rights, you (or your authorized agent) may contact 3E at privacy@3eco.com. The CCPA also requires a description of data practices using specific categories. This table uses these categories to organize the information in this policy.

CATEGORIES OF INFORMATION WE COLLECT

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer (personal information). In particular, we have collected personal information in the following categories from consumers within the last 12 months:

Category	Examples	Collected
A. Identifiers	Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, e‐mail address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information (Some personal information included in this category may overlap with other categories.)	YES
C. Protected classification characteristics under California or federal law	Age (40 years of age or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information)	YES
D. Commercial information	Records of personal property and products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	NO
E. Biometric information	Genetic, physiological, behavioral, and biological characteristics or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data	NO
F. Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement	YES
G. Geolocation data	Physical location or movements	NO
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information	NO
I. Professional or employment‐related information	Current or past job history or performance evaluations	YES
J. Nonpublic education information per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records	NO
K. Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	NO
L. Sensitive personal information	Social security number, driver’s license, state identification card, passport number, financial account information, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, union membership, or the contents of email transmitted to 3E; and personal information collected and analyzed concerning a job applicant’s health.	YES

DISCLOSURE OF PERSONAL INFORMATION FOR BUSINESS PURPOSES

In the preceding 12 months we have disclosed the above categories of personal information and sensitive personal information for business purposes, including administrative purposes, to our service providers and contractors, including those for recruiting, benefits and human resource policy administration, web analytics, data processing, auditing, and other administrative purposes. The service providers and contractors are obligated not to disclose or use personal information outside of the business relationship with us or for purposes not permitted in their contract with us.

USE AND DISCLOSURE OF SENSITIVE PERSONAL INFORMATION

We do not use or disclose sensitive personal information except in connection with those business purposes permitted under Section 1798.121 of the CCPA, including to perform services on behalf of our business.

SUPPLEMENTAL INFORMATION FOR RESIDENTS OF CALIFORNIA

(1) Right to Know

You have the right to request that we disclose certain information to you about our collection and use of your personal information. Once we receive and confirm your verifiable consumer request, we will disclose to you:

(a) The categories of personal information we have collected about you;

(b) The categories of sources from which the personal information was collected;

(d) The categories of third parties to whom we disclose personal information; and

(e) The specific pieces of personal information we have collected about you (subject to exceptions and restrictions set forth in California privacy law regulations regarding disclosure of certain personal information).

(2) Right to Delete Personal Information

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers and contractors to delete) your personal information from our records, unless an exception applies (for example, if we are required by law to retain that information). If your request is denied, the response we provide to your verifiable consumer request will explain the reason for denying your request.

(3) Right to Correct Inaccurate Personal Information

You have the right to request that we correct inaccurate personal information that we maintain about you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will correct (and direct our service providers and contractors to correct) inaccurate personal information that we maintain about you, unless an exception applies. If your request is denied, the response we provide to your verifiable consumer request will explain the reason for denying your request.

(4) Right to Opt-Out of the Sale or Sharing of Personal Information

We do not sell or share (as defined under the CCPA) personal information that we collect from you and therefore do not provide a method to opt-out from such activities.

(5) Right to Limit Use of Sensitive Personal Information

We do not use or disclose sensitive personal information that we have collected from you for purposes other than those business purposes permitted under Section 1798.121 of the CCPA and therefore do not provide a method to limit such activities.

Our Verification Process

Upon receipt of your request, we will provide directions on identity verification requirements which will include submission of pieces of personal information that we can match to our records. Once you provide such information and assuming we are able to verify your identity by matching the information you provided to our records, we will begin to gather information to respond to your request. For requests to correct, we may require you to provide additional documentation to rebut any of our own documentation that the personal information that you are requesting to correct is accurate.

No later than 10 business days after receiving your request, we will confirm receipt of the request and provide information about how we will process the request. We will endeavor to respond to a verifiable consumer request within 45 calendar days of its receipt. If we require more time (we may take up to 45 additional days), we will inform you of the reason and extension period in writing. If we cannot verify the request within the 45 calendar days, we may deny the request. If we deny your request, we will inform you of the reason for its denial.

Authorized Agents

You may use an authorized agent to submit a request to know, request to delete, or request to correct on your behalf. The authorized agent can submit such requests on your behalf by contacting us at privacy@3eco.com.

When you use an authorized agent to submit a request to know, request to delete, or request to correct, we may require the authorized agent to provide proof that you gave the agent signed permission to submit the request. We may also require you to do either of the following: (1) verify your own identity directly with us; or (2) confirm directly with us that you provided the authorized agent permission to submit the request.

Contact Information

If you have any questions or concerns about our privacy policies or information practices, including, but not limited to, the ways in which we collect and use your personal information, or your choices and rights regarding such use, or if you wish to exercise your data subject access rights, please do not hesitate to contact: privacy@3eco.com. This Privacy Notice may be found on www.3eco.com