Privacy Policy — Careers Portal
Last update Dec 9 2021.
Contents
- Scope of Policy
- What personal data do we process?
- For what other purposes do we process your personal data?
- Consequences of not providing personal data
- With whom do we share your personal data
- International transfers of your personal data
- Timely Processing
- Your data protection rights
- Links to other websites
- Changes to the Policy
- Contact us
New Enterprise Associates (New Enterprise Associates) and its affiliates (Affiliates and together, we, us, our) respect your privacy. This Data Protection Policy (the Policy) describes how we process your personal data and the rights you have in relation to your personal data.
New Enterprise Associates acts as controller for the processing activities described in this Policy. Contact details are set out in Section 10 of this Policy.
Where one of the Affiliates collects and processes personal data about an individual from the Careers Portal for the purposes identified in Section 3 below, this Affiliate will also act as a controller of the personal data.
Please read this Policy carefully in order to understand how we process your personal data.
1. Scope of Policy
This Policy applies to personal data we collect about individuals who (a) visit our Careers Portal and/or (b) otherwise interact with us in connection with our Careers Portal and/or a potential role with us.
This Policy does not apply to personal data collected by any third party, including through any application or content (including advertising) that may link to or be available from our Careers Portal. Nor does this Policy apply to any other of our websites.
This Policy should be read together with any additional notice that we may provide to you when we collect or otherwise process your personal data.
2. What personal data do we process?
We process the following types of personal data about you for the purposes set out in Section 3 of this Policy:
- contact information (e.g., name, home and business address, phone numbers and email addresses);
- demographic information (e.g., date of birth and nationality);
- employment and education history;
- social media profile information, including but not limited to LinkedIn profile information (including, your photograph); and
- any other personal data which may be voluntarily disclosed by you in connection with the Careers Portal.
We will collect this personal data directly from you i.e., via the Careers Portal. We may also collect personal data about you from third parties such as LinkedIn where you link this profile to the Careers Portal.
Cookies: As is now common with most websites, our Careers Portal uses cookies and may use other online tracking tools (e.g., web beacons) to automatically collect information about your IP address, your use of the Careers Portal, or other websites you may visit after ours. Cookies are small data files generated by a website and saved by your web browser. They are used to help users navigate websites efficiently as well as to provide information to the owner of the websites. To find out more about what cookies are used and how, please consult the cookies policy found here.
3. For what purposes do we process your personal data?
| Purpose(s) for processing | Legal bases for processing |
| Hosting on the Careers Portal | We have a legitimate interest to ensure that we consider suitable and qualified candidates (Article 6(1)(f), GDPR) |
| Managing the recruitment / application process, including assessing your skills, qualifications, and suitability for the role | We have a legitimate interest to ensure that we appoint a suitable and qualified individual to the relevant role (Article 6(1)(f), GDPR) To be able to manage and perform contracts with you (Article 6(1)(b), GDPR) |
| Making a decision about your recruitment / appointment, including the right to work | This is necessary to enter into a contract with you (Article 6(1)(b), GDPR) We have a legal obligation to do so (Article 6(1)(c), GDPR) |
| Maintaining records regarding the recruitment or application process | We have a legitimate interest to ensure that we maintain accurate and comprehensive records regarding the recruitment / application process (Article 6(1)(f), GDPR) We have a legal obligation to do so (Article 6(1)(c), GDPR) |
| Communicating with you during the recruitment / application process | We have a legitimate interest to ensure that we communicate promptly and effectively regarding the application / recruitment process (Article 6(1)(f), GDPR) |
| Carrying out audits and investigations, and to investigate and resolve complaints, grievances or misconduct | We have a legitimate interest to manage our business and to ensure that all investigations and proceedings are managed efficiently and effectively (Article 6(1)(f), GDPR) We have a legal obligation to do so (Article 6(1)(c), GDPR) |
| Preparing for and acting in relation to enquiries, investigations or proceedings, by governmental, administrative, judicial or regulatory authorities, including civil litigation | We have a legitimate interest to manage our business |
| In connection with a potential asset or stock acquisition of New Enterprise Associates or an Affiliate, or the outsourcing or insourcing of services provided by employees, providing reasonable diligence material to a third party or meeting any disclosure obligations as required by law | We have a legitimate interest to manage our business We have a legal obligation to do so (Article 6(1)(c), GDPR) |
| To comply with our legal obligations including, for example, to respond to data subject requests | We have a legal obligation to do so (Article 6(1)I, GDPR) |
You have a right to object to the processing of your personal data where that processing is carried out for our legitimate interests. Please note however that we may not be able to fulfil this request in all instances.
4. Consequences of not providing personal data
If you do not provide certain information when requested which is necessary for us to comply with our contractual or legal obligations, we may not be able to consider your application and/or process your application successfully.
5. With whom do we share your personal data
We disclose and/or make available your personal data to:
- third-party service providers such as, providers of IT hosting and security services;
- professional advisors (e.g., accountants, lawyers or other consultants) and independent public accountants and auditors;
- third parties that are considering acquiring or that acquire all or part of our assets or stock, or that succeed us in carrying on all or part of our business or services provided to or by us; and
- regulators and other governmental agencies.
6. International transfers of your personal data
The Careers Portal is hosted by a third party in the US. We may also, for the above listed purposes, transfer your personal data to other recipients as referred to above, that are located in countries outside the EEA and UK (including in the U.S.) Some of these countries may be considered by the European Commission and/or the UK Government as not providing an adequate level of data protection.
Your personal data will only be transferred from the EEA and the UK to a recipient in a country that is not considered to provide an adequate level of data protection when the transfer is made in compliance with applicable data protection and privacy laws (e.g., by entering into standard contractual clauses (SCCs) with the recipient, relying on the recipient'ls Binding Corporate Rules, or by relying on a derogation such as, where the transfer is necessary for performance or a contract or the establishment or defence of legal claims).
You can request further information in relation to international transfers and/or a copy of the SCCs by contacting us as described in Section 10 below.
7. Timely Processing
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for (as described in Section 2 above). To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. We also consider the applicable legal requirements and the extent to which it is necessary to process the personal data. In exceptional cases (e.g., in pending litigation matters or where the law requires us to) your personal data may need to be kept for longer periods of time.
8. Your data protection rights
It is important for us to maintain accurate and up to date records of your personal data. Please inform us of any changes to or errors in your personal data as soon as possible by contacting New Enterprise Associates (as described in Section 10 below) and/or the relevant Affiliate (as described in Section 1 above).
You have the following rights with regard to personal data which we process about you, which may be subject to limitations and/or restrictions:
- You have the right to request access to the personal data we process about you.
- You have the right to request us to rectify any personal data that might be incorrect, as well as the right to request us to restrict the processing of your personal data.
- You may request to receive a copy of your personal data that you provided to us, in a structured, commonly used and machine-readable format.
- You have the right to request that we erase your personal data.
- You have the right to withdraw consent to the processing of your personal data at any time.
We will respond to your request in writing, or orally if requested, as soon as practicable and in any event not more than within one month after receipt of your request. In exceptional cases, we may extend this period by two months and we will tell you why. We may request proof of identification to verify your request. For more details in relation to your rights, including how to exercise them, please contact New Enterprise Associates (as described in Section 10 below) and/or the relevant Affiliate (as described in Section 1 above).
You also have the right to lodge a complaint with the competent data protection authority.
9. Other Websites
Our websites may provide links to other third party websites which may operate independently from us and may have their own privacy notices or policies, which we advise you to review. To the extent any linked websites or apps are not owned or controlled by us, we are not responsible for their content.
10. Changes to the Policy
We will review and update this Policy as required to keep current with rules and regulations, new technologies and security standards. We will post those changes on the Careers Portal or update the “last updated” date of the Policy. If we make a material change to this Policy, you will be provided with appropriate notice in accordance with applicable legal requirements.
11. Contact us
For any privacy issues, questions or complaints concerning the application of this Policy or to exercise your rights as described in Section 8 above, you may contact New Enterprise Associates in the first instance by writing to us at:
1954 Greenspring Drive Suite 600 Timonium, MD 21093 United States
Email:
Phone: (410) 842-4000
Alternatively, you may contact the relevant Affiliate (as described in Section 1 above).
