Applicant Privacy Policy

1. Introduction

   Change.org, PBC (“Company”) values your trust and is committed to the responsible management, use and protection of personal information. This Applicant Privacy Policy (“Policy”) describes our practices in connection with all the information that we collect through the Careers section of our website (located at https://www.change.org/careers), our applicant tracking system, or through other online recruiting career sites (e.g. LinkedIn, Glassdoor, etc.) (“Careers Site”) and offline in connection with your application for employment, a job or internship with the Company or one of our affiliates. Personal information submitted elsewhere on the Company’s and its affiliates’ web sites will be used in accordance with our general online Privacy Policy.

   If you are a California resident, please see the California Addendum at the end of this Policy for further details on how we handle your information and how to exercise your rights.

2. Personal Information We Collect

   1. Information You Provide

   We collect information from you in connection with your application, which may include, but is not limited to:

   • Name, address, telephone number, e-mail address, and other contact information;
   • Username and password (if applicable);
   • Work authorization status;
   • CV, résumé, cover letter, previous work experience and education information;
   • Skills;
   • Professional and other work-related licenses, permits and certifications held (if applicable);
   • Information relating to references; and
   • Any other information you elect to provide to us (e.g. employment preferences, willingness to relocate, desired salary, awards, or professional memberships).

   As discussed in the “Diversity” section below, in certain cases we will ask optional questions about race/ethnic origin, gender, and disability of our applicants, for monitoring equal opportunity. Depending on location, the position within the Company, or other relevant factors, we may also inquire about criminal records. We will do so only where permitted by applicable law. Otherwise, we ask that you avoid submitting information which may qualify as “sensitive information” under applicable law, except where such information is legally required. Sensitive information includes race, religion, ethnicity, nationality or national origin, age, gender identity, sex life or practices or sexual orientation, marital status, medical or health information (including disability status), genetic or biometric information, biometric templates, political or philosophical beliefs, political party or trade union membership, veteran status, background check information, judicial data such as criminal records or information on other judicial or administrative proceedings.

   Any information you submit through the Careers Site must be true, complete, and not misleading. Submitting inaccurate, incomplete, or misleading information may lead to a rejection of your application during the application process or disciplinary action including immediate termination of employment. In addition, it is your responsibility to ensure that information you submit does not violate any third party’s rights; for example, you should not submit other’s copyrighted content or defamatory material regarding another.

   If you provide us with personal information of a reference or any other individual as part of your application, it is your responsibility to obtain consent from that individual prior to providing the information to us.

   2. Information from Other Sources

   As permitted by applicable law, we may collect information about you from other sources, which may include:

   • Background check report;
   • Reports in connection with your application;
   • Your references;
   • Prior employers and industry contacts;
   • Educational institutions you attended;
   • Career Sites; and
   • Internet search engines and online social media websites.

3. Use of Information

   We collect and process information about you for one or more of these reasons:

   • Because you voluntarily provide this information and consent for us to process it;
   • Because this information is necessary to take steps at your request prior to entering into an employment, job, or internship;
   • Because this information is of particular importance to us, and we have a specific legitimate interest under law to process it; or
   • To comply with a legal obligation.

   Where the collection or processing is based on your consent, you may withdraw your consent at any time to the extent permitted by applicable law.

   The information that you submit on the Careers Site will be used for the Company’s global personnel recruitment, management, and planning purposes, as permitted by applicable law:

   • To process your application. We will engage in these activities to manage our prospective contractual relationship with you, based our prospective contractual relationship with you;
   • To assess your capabilities and qualifications for a job. We will engage in these activities to manage our prospective contractual relationship with you, based on our legitimate interests;
   • To conduct reference checks. We will engage in these activities to comply with a legal obligation or based on our legitimate interests;
   • To respond to your inquiries and communicate with you about your application, and to send you information regarding the Careers Site and changes to our terms and policies. We will engage in these activities to manage our prospective contractual relationship with you;
   • To comply with or monitor compliance with any applicable law or regulation. We will engage in these activities to comply with a legal obligation or based on our legitimate interests;
   • To conduct background checks if we offer you a position. We will engage in these activities to comply with a legal obligation or based on our legitimate interests;
   • To preserve our other legitimate interests, for example, for the Company’s administrative purposes, aggregate management reporting, internal training, and as generally required to conduct our business within the Company and its affiliates; and
   • To include your information in future jobs similar to the one you have applied for, within two years of receiving your resume, based on our legitimate interest. The information about you will be added to the Company’s global applicant tracking system. If you do not wish us to do this, please contact us.

   If we hire you, personal information we collect in connection with your application can be incorporated into our human resources system and used to manage the new-hire process; any such information can become part of your employee file and used for other employment-related purposes.

   Providing personal information to us through the Careers Site is voluntary. However, if you do not provide sufficient information, the Company may be unable to consider your employment application or, if you are hired, your subsequent promotion, transfer, or relocation.

4. Disclosure and Transfer of Information

   We share personal information with affiliates that are involved in evaluating candidates for a given position. Change.org, PBC will remain responsible for personal information that is jointly used with affiliates.

   We will limit access to personal information to personnel with a business need to know the information for the purposes described in this Policy, including senior or executive personnel and personnel in the recruiting, legal, human resources, and information technology departments, as well as in the department responsible for the position for which you are applying.

   We also share personal information with our third-party service providers to facilitate services they provide to us, including hosting and operating our applicant tracking system, recruiting assistance, benefits and payroll processing, and background check processing.

   Disclosing your personal information can include transferring personal information to other countries, including the United States or any other country in which we or our service providers have operations.

   If you are located in the European Economic Area (the “EEA”) this may include countries outside of the EEA. Some of these countries are recognized by the European Commission as providing an adequate level of protection according to EEA standards (the full list of these countries is available here.) As for transfers to other countries, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your information. You may obtain a copy of these measures by contacting us.

5. Others Uses and Disclosures of Information

   We also use and disclose your personal information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

   • To comply with applicable law.
   • This can include laws outside your country of residence.
   • To respond to requests from public and government authorities.
   • These can include authorities outside your country of residence.
   • To cooperate with law enforcement.
   • For example, when we receive law enforcement requests and orders.
   • For other legal reasons.
   • To enforce our terms and conditions; and

   To protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others.

   • In connection with a sale or business transaction.
   • We have a legitimate interest in disclosing or transferring your personal information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

6. Data Retention

   We also use and disclose your personal information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

7. Passive Information Collection: Cookies and Similar Technology

   We and our service providers use “cookies” and similar technologies. Please see our Privacy Policy for more information.

8. Choices and Access

   If you register on the Careers Site, you may, depending on the particular career site, access, review, and change your personal information stored therein by logging into the Careers Site and updating your account information. The updated profile may be used as the default the next time you apply for a job using your account online. To change personal information that you have already submitted for consideration for a specific position, please re-submit your application for that position and indicate the changed personal information. We encourage you to promptly correct your personal information if it changes or is inaccurate.

   You may, where permitted by applicable law, request to review, correct, update, restrict, suppress or delete your personal information; request that we cease using your personal information as permitted by applicable law; or request a copy or portability of your personal information. Please make your request by contacting us. We will respond to your request consistent with applicable law.

   In your request, please make clear what personal information you would like to access or have changed, whether you would like to have personal information that you have provided to us suppressed from our database or otherwise let us know what limitations you would like to put on our use of your personal information.

   For your protection, we only implement requests with respect to the information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. Please note that certain personal information may be exempt from such requests pursuant to applicable data protection laws or other laws and regulations.

9. Additional Information for Individuals in the EEA and Canada

   If you are located in the EEA or Canada, you also may:

   • Contact us with any questions about this Policy.
   • Contact our data protection officer or privacy officer responsible for your country or region, if applicable. For more information, please contact us.
   • Lodge a complaint with a data protection authority for your country or region, or in the place of the alleged misconduct.

10. Security

    We seek to use reasonable organizational, technical, and administrative measures to protect personal information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please contact us immediately.

    The Company hereby disclaims, as far as permitted by local laws, any liability for itself and its affiliates and contractors for any personal information we collect in connection with your application that is lost, misused, illegally accessed, disclosed, altered, or destroyed or not timely delivered to our Careers Site.

11. Links to Third-Party Websites

    This Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Careers Site links. The inclusion of a link on the Careers Site does not imply endorsement of the linked site or service by the Company or our affiliates.

12. Diversity

    We are an equal opportunity employer, which means we offer equal treatment to all applicants. The Company does not discriminate, either directly or indirectly, on protected grounds: race, colour, sex, gender identity, sexual orientation, nationality, national origin, ethnic origin, religion, beliefs or creed, age, disability, marital status, veteran status, or genetic information in any area of recruitment.

13. Law Applicable to Job Application

    The Careers Site allows you to apply for jobs world-wide, as a benefit of the Company’s centralized global recruitment function. This Careers Site is operated from the United States. Accordingly, any personal information you submit to the Careers Site will be collected in the United States and will be subject to U.S. laws. However, if we share your personal information with an affiliate located in another country in its capacity as a potential employer, the affiliate will handle your personal information in accordance with this Policy. Any hiring or other employment-related decisions will be made by the hiring affiliate in accordance with the laws of the country where the job will be located.

14. About Children

    The Careers Site is not intended for minors under the age of 18.

15. Current Personnel of the Company

    If you currently work for the Company or one of our affiliates, you must be eligible to apply for a different position within the Company to use the Careers Site. If you accept such a position, your benefits programs and Human Resources policies may change. Please consult the HR manager for the new position concerning application eligibility, benefit programs, and HR policies applicable to that position.

    The Careers Site is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to local law or regulation.

16. Changes to the Policy

    We reserve the right to amend this Policy at any time in order to address future developments of the Company, the Careers Site or changes in industry or legal trends. The “Last Updated” legend at the top of this Policy indicates when this Policy was last revised. Any changes will become effective when we post the revised Policy on the Careers Site.

17. Contact Us

    If you have questions or requests, please feel free to contact us at applicantdata@change.org. Because email communications are not always secure, please do not include sensitive information in your emails to us.

CALIFORNIA ADDENDUM

This California Addendum applies to California residents and supplements the information provided above in the Applicant Privacy Policy.

Collection and Disclosure of Personal Information

The following chart details which categories of personal information we collect and process, as well as which categories of personal information we disclose to third parties for our operational business and hiring and recruitment purposes, including within the 12 months preceding the date this Policy was last updated.

Categories of Personal information	Disclosed to Which Categories of Third Parties for Operational Business Purposes
Identifiers, such as name, alias, postal address, unique personal identifiers, email address, account name, online identifiers, and government-issued identifiers (e.g., Social Security number, driver’s license)	Our affiliates; service providers that provide services such as recruiting, talent acquisition, employment screening and background checks, consulting, expense management, IT, and other services; professional advisors such as lawyers; public and governmental authorities, such as regulatory authorities and law enforcement
Personal information as defined in the California customer records law, such as name, contact information, signature, passport number; education and employment information	Our affiliates; service providers that provide services such as recruiting, talent acquisition, employment screening and background checks, consulting, expense management, IT, and other services; professional advisors such as lawyers; public and governmental authorities, such as regulatory authorities and law enforcement
Protected Class Information, such as characteristics of protected classifications under California or federal law, such as sex, age, gender, race, disability, citizenship, military/veteran status, gender identity and expression, primary language, and immigration status	Our affiliates; service providers that provide services such as recruiting, talent acquisition, employment screening and background checks, consulting, IT, and other services; professional advisors such as lawyers; public and governmental authorities, such as regulatory authorities and law enforcement
Commercial Information, such as travel information and expenses	Our affiliates; service providers that provide services such as travel arrangements and expense management, IT, and other services; public and governmental authorities, such as regulatory authorities and law enforcement
Internet or network activity information, such as access and usage information regarding our website or online application portal, timestamp information, and access and activity logs	Our affiliates; service providers that provide services such IT, and other services; public and governmental authorities, such as regulatory authorities and law enforcement
Geolocation Data, such as approximate location of devices used to access our website or online application portal, derived from IP address	Our affiliates; service providers that provide services such IT, and other services; public and governmental authorities, such as regulatory authorities and law enforcement
Audio/Video Data. Audio, electronic, visual and similar information, such as photographs and audio and video recordings	Our affiliates; service providers that provide services such as recruiting, talent acquisition, employment screening and background checks, consulting, IT, and other services; professional advisors such as lawyers; public and governmental authorities, such as regulatory authorities and law enforcement
Education Information subject to the federal Family Educational Rights and Privacy Act such as student transcripts, grade point average, grades, academic standing and disciplinary records, confirmation of graduation	Our affiliates; service providers that provide services such as recruiting, talent acquisition, employment screening and background checks, consulting, IT, and other services; professional advisors, such as lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners
Employment Information. Professional or employment-related information, such as work history and prior employer, information from reference checks, work experience, qualifications, training and skills, work authorization, CV, résumé, cover letter, professional and other work-related licenses, permits and certifications held, and publicly accessible information posted on your professional social media accounts	Our affiliates; service providers that provide services such as recruiting, talent acquisition, employment screening and background checks, consulting, IT, and other services; professional advisors, such as lawyers; public and governmental authorities, such as regulatory authorities and law enforcement; business partners
Sensitive Personal Information. Personal Information that reveals an individual’s Social Security, driver’s license, state identification card, or passport number; account log-in; racial or ethnic origin, religious or philosophical beliefs, citizenship, immigration status, or union membership; and Personal Information collected and analyzed concerning an individual’s sexual orientation	Our affiliates; service providers that provide services such as recruiting, talent acquisition, employment screening and background checks, consulting, IT, and other services; professional advisors, such as lawyers; public and governmental authorities, such as regulatory authorities and law enforcement

We may also disclose the above categories of personal information to a third party in the context of any reorganization, financing transaction, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

We do not “sell” or “share” your personal information, including your sensitive personal information, as defined under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (collectively, the “CCPA”). We have not engaged in such activities in the 12 months preceding the date this Policy was last updated. Without limiting the foregoing, we do not “sell” or “share” the personal information, including the sensitive personal information, of minors under 16 years of age.

Purposes for the Collection and Use of Sensitive Personal Information

We may use sensitive personal information for purposes of performing services for our business, providing services as requested by you, and ensuring the security and integrity of our business, infrastructure, and the individuals we interact with. This includes, without limitation, receiving and processing your job application, evaluating your suitability for the position(s) you are applying for, conducting background checks, analyzing and monitoring diversity, making you an offer (subject to our discretion), fulfilling administrative functions, complying with law, legal process, or requests from governmental or regulatory authorities, and exercising or defending legal claims. We use and disclose Sensitive Personal Information only for those purposes permitted under the CCPA.

Individual Requests

You may, subject to applicable law, make the following requests:

1. You may request that we disclose to you the following information:
1. The categories of personal information we collected about you and the categories of sources from which we collected such personal information;
2. The business or commercial purpose for collecting personal information about you; and
3. The categories of personal information about you that we otherwise disclosed, and the categories of third parties to whom we disclosed such personal information.
2. You may request to correct inaccuracies in your personal information.
3. You may request to have your personal information deleted.
4. You may request to receive the specific pieces of your personal information, including a copy of the personal information you provided to us in a portable format.

We will not unlawfully retaliate against you for exercising your CCPA rights. To make a request, please contact us at applicantdata@change.org. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the personal information subject to the request. We may need to request additional personal information from you, such as the email address you used as an applicant and the role you applied for, in order to verify your identity and protect against fraudulent requests. If you make a request to delete, we may ask you to confirm your request before we delete your personal information.

Authorized Agents

If an agent would like to make a request on your behalf as permitted by applicable law, the agent may use the submission methods noted in the section entitled “Individual Requests.” As part of our verification process, we may request that the agent provide, as applicable, proof concerning their status as an authorized agent. In addition, we may require that you verify your identity as described in the section entitled “Individual Requests” or confirm that you provided the agent permission to submit the request.