Privacy Policy

Applicant Privacy Notice

Last updated: December 24, 2024

Welcome to the SimSpace Careers Site (the “Site”). The Site serves as the centralized career application portal for SimSpace and its global corporate affiliates (collectively, “we”, “us”, or the “Company”) (headquartered at 320 Congress St. Boston, Massachusetts 02210, [email protected]). This Privacy Notice applies to the processing of job applicants’ personal data by SimSpace and its global entities during the recruiting process, and is designed to help you understand our practices surrounding the collection, use and disclosure of personal data.

This Privacy Notice addresses the following topics:

• Equal Employment Opportunity Statement
• Assistance for Disabled Applicants
• Your Consent
• Scope of This Notice
• Personal Information We Collect About You
• Categories of Sources of Your Personal Information
• How We May Use Your Personal Information
• How We May Disclose Your Personal Information
• Retention of Your Personal Information
• International Transfers of Your Personal Information
• Security For Your Personal Information
• How to Access, Correct, or Delete Personal Information in Your Account
• Jurisdiction-Specific Information
• Changes to this Notice
• Inquiries and Concerns

Equal Employment Opportunity Statement

The Company is an equal employment opportunity employer. The Company does not discriminate against any applicant or employee on the basis of race, color, sex, religion, national origin, age, disability, or any other consideration made unlawful by applicable federal, state, or local laws. The Company also prohibits harassment of applicants and employees based on any of these protected categories.

For U.S. Applicants: It is also the Company’s policy to comply with all applicable laws respecting consideration of unemployment status in making hiring decisions. The complies with the Americans with Disabilities Act (“ADA”), the ADA Amendments Act of 2008 (“ADAAA”) and applicable state law and considers reasonable accommodation measures that may be necessary for qualified applicants/employees to perform the essential functions of the job.

Assistance for Disabled Applicants

Alternative methods of applying for employment are available to individuals unable to submit an application through this Site because of a disability. Contact [email protected] to discuss modifications.

Your Consent

To submit your job application, you will be required first to upload your CV along and submit required information  within the job post. After providing the required information, you will need to click on “Read and accept data privacy statement”, review this Privacy Notice and then click “Accept”. By clicking “Accept”, you consent to the collection, use, disclosure, transfer across borders and other processing of your personal data as described below. Once you agree, your consent will continue to apply to our collection, use, disclosure, cross-border transfer and other processing of your personal data unless you revoke your consent by contacting us at [email protected].

If you click “Decline,” you will not be able to use the online application page to apply for global career opportunities within the SimSpace corporate group, and the Company may not be able to consider you for the position for which you are applying.

Scope of This Notice

This Privacy Notice applies only to information collected for recruitment purposes through the Site and from other sources. The other sources might include information that you provide other than through the online application page as well as information obtained, for example, from prior employers, other references, pre-employment screening providers, and educational institutions. This Notice does not apply to any other site or page that we own or operate. Our other sites have their own privacy policies.

Types of Personal Data We Collect

If you choose to apply for a position with us, the categories of personal data that we may collect about you through the Site and other sources are listed below. Please remember that you are responsible for providing information that is accurate, complete and up to date when you disclose information to us during the employment process.

• Identifiers: your first and last name, home address, phone number, mobile phone number or user/screen name as well as any personal information that you choose to include in messages you send through the third-party SMS Service provider we make available to you, email address, Internet Protocol (IP) address, Social Security number (if you reside in the U.S.) or national insurance number, and signature.
• Professional or Employment-Related Information: We may collect information on your resume/curriculum vitae (CV) and cover letter, employment history (e.g., dates of employment and position held), education history (e.g., degrees earned, certifications obtained), qualifications and skills, professional licenses or certifications as applicable, and information you disclose through your LinkedIn or other professional social media profile(s).
• Internet or Other Similar Network Activity: We may collect information regarding your interaction with the Site, including through the use of cookies, described further on our general Privacy Policy. If you visit our offices during the screening process and use our guest WiFi, we may collect information about that use, such as type of device used and start/stop time.
• Sensory or Surveillance Data: for example, voicemails, and footage from video surveillance cameras if you visit our offices during the screening process.
• Commercial Information: expense records for travel, food, and lodging for interviews or otherwise during the screening process.
• Medical Information: If you request an accommodation in connection with the hiring process, we may collect medical information related to that accommodation.
• Other Information Submitted During the Screening Process: (a) any personal information submitted as part of your response to questions in an application or interview; (b) your eligibility to work in the country where you reside or are applying to work in; and (c) your salary expectations and other preferences with respect to the position you are applying.

Note on Sensitive Information: When you apply for a position, you may have the opportunity to provide information about your protected classification, i.e., gender, race/ethnic origin and/or veteran status in order for us to conduct equal opportunity monitoring to the extent permitted by applicable laws. The provision of this information is entirely voluntary. If you decline to provide this information, your application(s) will not be affected in any way. If you do choose to provide this information, you consent to our using it for equal employment opportunity monitoring purposes. This information will be held and stored anonymously and will not be used to evaluate your application for employment and also will not be used to infer any characteristics about you.

Except as described above, we will not request or otherwise collect information about your health, race or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, or sexual orientation or your genetic information or biometric information through the online application or during the application process unless the law, as an exception, requires us to do so.

Note on Verification and background checks: For certain positions, it will be necessary for SimSpace to verify the details you have supplied (for example, in relation to an applicant’s identity, employment history, academic qualification and professional credentials) and to conduct pre-employment background checks where legally permissible (for example, in relation to previous criminal convictions, financial standing, global watch lists, and sex offender registries). The level of checks will depend on the where you reside and your role, in particular whether you will occupy a regulated function, and will be conducted at as late a stage as is practicable in the screening process and often only after you have been selected for the position.

This Privacy Notice does not otherwise apply to the Company’s verification and screenings. As applicable, SimSpace will provide separate disclosures with further information about the checks involved, and will obtain any necessary consent prior to completing such screenings.

Categories of Sources of Personal Data

There are a variety of sources where we collect the personal data described above, mainly from you as the applicant. Additional information may be collected from: (1) our vendors and service providers, such as background screening providers (where permitted), and staffing agencies; (2) third parties and/or public sources such as LinkedIn, government records, and credentialling and licensing organizations; and (3) job references, including from previous employers.

How SimSpace Uses Personal Data

We will use the personal data that we collect about you for purposes of the hiring process, including:

Screening

• To evaluate your qualifications or suitability for employment with SimSpace
• To communicate with you
• For identification purposes
• For diversity and inclusion purposes
• To demonstrate your agreement to, or acceptance of, documents presented to you, g., pre-employment arbitration agreement, acknowledgment of employment application, offer letter
• To create a talent pool for future job openings
• For recordkeeping purposes
• To evaluate and improve the optimal candidate identification process

Monitoring, Security, and Compliance

• To monitor use of our facilities and information systems
• To conduct internal audits and investigations
• To protect the safety and security of Company’s facilities
• To administer Company’s whistleblower hotline
• To report illegal activity and prevent fraud

Other Related Purposes

• For travel and event planning
• To engage in crisis management
• To manage travel, and expense reimbursements
• To optimize your experience with third-party service providers
• To manage litigation and other legal disputes and inquiries involving the Company, and to meet legal and regulatory requirements;
• In connection with a corporate transaction, sale, or assignment of assets, merger, divestiture, or other changes of control or financial status of Company or any of its subsidiaries or affiliates; and
• To protect the rights, property, or safety of SimSpace, applicants, customers or others.

If you are not hired for the position for which you initially apply, we may use the personal data that we collect about you through the screening process to evaluate your suitability for future job openings, unless you indicate otherwise. Based on that evaluation, we may use your personal data to contact you to find out whether you are interested in applying for new job openings. If you do not wish to be considered for future job openings, you may contact us as described below.

The Company’s employees involved in the evaluation of your application and, if you are hired, in the administration of your employment relationship with the Company will have access to your personal data on a need–to-know basis.

Lawful Basis for Processing: Where applicable data protection law requires a lawful basis for collecting, using, and otherwise processing your personal data, SimSpace generally relies on your consent to do so. However, SimSpace may also rely on the following grounds as applicable:

• Where necessary for SimSpace to enter into a contract of employment with you
  • For example, to make informed decisions on recruitment and assess your suitability for the role, or to reimburse you for any agreed upon expenses incurred in the application process.
• Where necessary to comply with legal obligation
  • For example, to confirm your eligibility to work in the country you are applying for a position in, and to assess your suitability in connection with their engagement in a regulated role, where applicable.
• Where necessary for SimSpace’s legitimate interests
  • For example, to recruit and hire suitable personnel, and to improve our recruitment process and activities.

Where SimSpace requires your personal data to enter into an employment contract with you, or where SimSpace is required under applicable employment, social security, social protection or other laws applicable to SimSpace, the provision of such personal data is mandatory. Where you do not provide your personal data to SimSpace, then SimSpace would be unable to enter into a contract with you or may need to withdraw the offer of employment for certain roles, such as regulated roles. All other provision of your personal data is optional. If you do not provide the relevant personal data necessary to that circumstance, the consequences may also be explained to you at that time.

Additional information regarding specific processing of personal data may be notified to you locally or as set out in applicable policies. Before collecting your sensitive personal data, we will, when required by applicable law, provide you with a separate notice and, if the collection is not required by applicable law, request your explicit consent whenever legally required to do so.

How We Disclose Your Personal data

SimSpace will not sell, lease, or license your personal data to any third party. There are limited circumstances where we may disclose your personal data we collect about you, most notably:

• To Service Providers, such as service providers under contract with us to help maintain and manage our databases, or to assist in the recruiting process. Service providers will be permitted to use your personal data only for the purpose(s) for which it was disclosed to them and in accordance with the SimSpace’s instructions. Service providers generally will be located only in the United States or in the country where you are applying for a position;
• Corporate Affiliates, such as SimSpace’s subsidiary entities, for recruitment, recordkeeping, and/or reporting purposes;
• Legal Violations, when we believe your actions violate applicable law, or threaten the rights, property, or safety of SimSpace or others;
• Required by Law, such as when we respond to subpoenas, court orders, or other legal processes; or
• Corporate Transactions, in the event that a SimSpace business is sold or integrated with another business, to a purchaser or, in due diligence, to prospective purchasers, subject to a confidentiality agreement.

SimSpace will make such disclosures only as permitted by applicable data protection laws.

How Long We Retain Your Personal Data

If you are hired or engaged: SimSpace will retain your personal data only for as long as it is needed for legitimate interest in accordance with applicable law, for the purposes of the recruitment process and, once this process is finished, for an appropriate period, so as to be able to deal with any legal claims linked to the application process. After this period, SimSpace will take steps to delete your personal data or hold it in a form that no longer identifies you. If you become a SimSpace employee, personal data you provide will become part of your employee file and may be used later for the management of the employment relationship.

If you are not hired or engaged: SimSpace will retain your personal data for an appropriate period, unless (a) you indicate that we may maintain the information on file until you ask us to delete the information, or (b) a shorter or longer retention period is legally required. We may also retain your information in order to keep you in mind for future recruitment or engagement processes. If you prefer that your details are not kept on file, please contact Talent Operations at [email protected].

Security For Your Personal Data

We want you to feel confident about providing your personal data through the online application page, so we have implemented a security program to keep information that is transmitted to our systems protected from unauthorized access. Your submissions of information to our secure server are protected by Hypertext Transfer Protocol Secure (“HTTPS”) and Transport Layer Security (TLS) technology, utilized by many popular browsers to safeguard transmissions. This technology allows us to use encryption tools to protect personal data transmitted between your computer and our server. After we have received your information, access to it is limited to employees with a need to know.

While we strive to protect your personal data, we cannot guarantee the security of any information that you submit through the online application, and you do so at your own risk.

How to Access, Correct, or Delete Your Personal Data

If you would like to access the information that you have submitted; wish to request that we update, modify, or delete your information; or if you have any questions about this Privacy Notice, please contact [email protected].

Opt out of SMS communications by texting “STOP” or “QUIT” to the 10-digit long code phone number used to message you. We reserve the right to send you certain communications relating to the third-party SMS service, such as announcements and administrative messages, without offering you the opportunity to opt-out of receiving them.

Children

The SMS Service is not intended for children under 13, and SimSpace does not knowingly collect information from children under the age of 13. Children aged 13 or older should not submit any Personal Information without the permission of their parents or guardians. By using the SMS Service, you are representing that you are at least 18, or that you are at least 13 years old and have your parents’ permission to use the service.

SMS Terms of Service

• When you opt-in to the service, we may send you SMS messages to notify you of any updates to your application status and to engage in discussion throughout your application process.
• You can cancel the SMS service at any time. Just text “STOP” to unsubscribe. After you send the SMS message “STOP” to us, we will send you an SMS message to confirm that you have been unsubscribed. After this, you will no longer receive SMS messages from us. If you want to opt-in again, just reply START to the phone number you unsubscribed to and we will start sending SMS messages to you again.
• If you are experiencing issues with the messaging program you can reply with the keyword “HELP” for more assistance, or you can get help directly at [email protected].
• Carriers are not liable for delayed or undelivered messages.
• As always, message and data rates may apply for any messages sent to you from us and to us from you. Message frequency may vary. If you have any questions about your text plan or data plan, it is best to contact your wireless provider.

Jurisdiction-Specific Information, Including Data Rights

• California
• All locations Outside of the United States
• Additional Jurisdiction-Specific Information

California:

This section applies only to individuals who reside in the state of California in the United States (“California residents”) and only to personal data subject to the California Privacy Rights Act (CPRA).

California Notice at Collection: SimSpace collects the categories of personal data identified in the “Types of Personal Data We Collect” section, above, for the purposes identified in the “How SimSpace Uses Personal Data” section, above, and retains personal information for the period described in the “How Long We Retain Your Personal Data” section, above. We do not, and will not, sell your personal data or disclose it to third parties for cross-context behavioral advertising. We also do not collect or process sensitive personal data for the purpose of inferring characteristics about you.

Additional Information Regarding Disclosures of Personal Data: The CPRA requires that we provide you with the following information about disclosures of your Personal Data to third parties for “business purposes”, as that term is defined in the CPRA:

• Service providers: We may disclose to service providers any of the categories of personal data we collect for the business purpose of performing services on Company’s behalf and, in particular, for the specific purposes described in the “How SimSpace Uses Personal Data” section, above.
• Auditors, lawyers, consultants, and accountants engaged by us: We may disclose to service providers any of the categories of personal data we collect to these services providers or contractors for the business purpose of auditing compliance with policies and applicable laws, in addition to performing services on the Company’s behalf.

• Affiliated companies: We may disclose to service providers any of the categories of personal data we collect to other companies within SimSpace’s corporate group for the business purposes of (a) auditing compliance with policies and applicable laws, (b) helping to ensure security and integrity, (c) debugging, (d) short-term transient use, (e) internal research, and (f) activities to maintain or improve the quality or safety of a service or device.

No sales or sharing: SimSpace does not sell or “share” (disclose for cross-context behavioral advertising) your personal data in connection with the applicant relationship. In addition, we have no actual knowledge that we sell or share the personal data of individuals of any age in connection with the applicant relationship, including the personal data of children under 16.

Your California Privacy Rights: Subject to applicable exceptions, California residents have the following rights under the CPRA:

• Right to Know: You have the right to submit a verifiable request for specific pieces of your personal data and for information about Company’s collection, use, and disclosure of categories of your personal data.
• Right to Delete: You have the right to submit a verifiable request to delete personal data that Company has collected from or about you.
• Right to Correct: You have the right to submit a verifiable request to correct inaccurate personal data about you maintained by the Company, taking into account the nature of the personal data and the purposes of processing the personal data.

Non-Discrimination: SimSpace will not unlawfully discriminate against you for exercising your privacy rights under the CPRA.

How to Exercise Your California Privacy Rights: SimSpace will respond to request to know, delete, and correct in accordance with applicable law if it can verify the identity of the requestor. You can exercise these rights in the following ways:

• Call 1-888-582-7822
• Email [email protected]
• Complete the request form available here

How We Will Verify Your Request: If you submit a request, we match personal data that you provide us against personal data we maintain in our files. The more risk entailed by the request (e.g., a request for specific pieces of personal data), the more items of personal data we may request to verify your identity. If we cannot verify your identity to a sufficient level of certainty to respond securely to your request, we will let you know promptly and explain why we cannot verify your identity.

Authorized Agents: You may designate an authorized agent to exercise your right to know, to correct, or to delete. If an authorized agent submits a request to know, correct, or delete on your behalf, the authorized agent must submit with the request a document signed by you that authorizes the authorized agent to submit the request on your behalf. In addition, we may ask you to follow the applicable process described above for verifying your identity. You can obtain an “Authorized Agent Designation” form by contacting us at [email protected].

Note on Deidentified Information: At times, SimSpace converts personal data into deidentified information using reasonable measures to ensure that the deidentified information cannot be associated with the individual (“Deidentified Information”). SimSpace maintains Deidentified Information in a deidentified form and does not attempt to reidentify it, except that Company may attempt to reidentify the information solely for the purpose of determining whether its deidentification processes ensure that the information cannot be associated with the individual.

All locations outside of the United States

The data controller of your personal data is the SimSpace entity to which you are applying for employment. Contact details for each SimSpace entity can be found here.

International Transfers of Personal Data:

If you are applying for a position with us from outside the U.S., the personal data that we collect about you in the recruitment process will be transferred to, and stored on, our servers, located in the U.S., and on servers maintained by our service provider hosting the Company’s Applicant Tracking System in the U.S. Authorized SimSpace employees may have access to your personal data as part of the recruitment process. These employees may use and disclose your personal data only for recruitment purposes, and must handle that information in accordance with this Privacy Notice and applicable information protection laws and guidance. The data protection laws where these companies are located may be less stringent than the laws of your home country.

If you reside in the European Union (“EU”) or the United Kingdom (“UK”), we have taken steps to ensure an adequate level of protection for your transferred personal data through Standard Contractual Clauses (the “SCCs”) to which SimSpace, its U.S. subsidiaries and its subsidiaries in the EU and the UK are parties. You may obtain a copy of the SCCs by submitting a request to [email protected]. If you reside in other countries with restrictions on cross-border data transfers, such as Singapore, we will confirm that necessary data transfer requirements, if any, have been satisfied, including, where legally required, ensuring an adequate level of protection for the transferred personal data via contract, or by obtaining your consent to the cross-border data transfer.

For Residents of Japan Only: For transfers to of personal data to SimSpace entities located in other countries, the applicable information with respect to personal data requirements can be found here at: https://www.ppc.go.jp/enforcement/infoprovision/laws/.

No Automated Decision-Making: Company will not use applicants’ personal data submitted through the Site for automated decision-making, including profiling, that produces legal effects or similarly significantly affects applicants.

Your Rights Regarding Your Personal Data:

To the extent provided by applicable law and subject to any relevant exceptions, you may be able to exercise the following rights regarding your personal data:

• Request access to your personal data maintained by SimSpace.
• Request that SimSpace update, correct, or delete your personal data, i.e., to rectify personal data that is incomplete or inaccurate or to erase your personal data.
• Withdraw your consent to the processing of your personal data, at any time, where you previously consented to the processing of your personal data. If SimSpace requests your consent to process your personal data and you do consent, you may use the contact information below to withdraw your consent. Any withdrawal shall not affect the lawfulness of processing based on your consent before its withdrawal, and SimSpace will continue to retain the information that you provided us before you withdrew your consent for as long as allowed or required by applicable law.
• Request restriction of Processing of your personal data in certain situations, such as while a dispute concerning the accuracy of personal data is being resolved.
• Request data portability: Subject to certain limitations, the right to data portability allows you to obtain from SimSpace, or to ask us to send to a third party, a copy of your personal data in electronic form that you provided to SimSpace in connection for recruitment purposes or with your consent.
• Object to the Processing of your personal data: You have the right to object to the processing of your personal data based solely on SimSpace’s legitimate interests.
• Request more information about the collection and use, and disclosure of your personal data.

How to exercise these rights: For further information regarding your rights, or to exercise any of your rights, please contact [email protected]. The Company will respond to such requests in accordance with applicable data protection law.

Right to Lodge a Complaint: If you believe that your personal data has been processed in violation of applicable data protection law, you may also have the right to lodge a complaint with the data protection authority where you live, where you work, or where you believe the violation occurred.

Additional Jurisdiction-Specific Information:

If you reside in any of the following countries, please read the relevant country-specific information below:

European Union: EU residents can find contact information for your data protection authority here: https://edpb.europa.eu/about-edpb/board/members_en.

United Kingdom: UK residents can find contact information for your data protection authority here: https://ico.org.uk/.

Updates To This Privacy Notice

This Notice will be updated periodically. If we make a material change to this Notice, we will inform you by posting a notice on this Site. Those changes will go into effect on the effective date posted in the revised notice. Please check periodically for changes to this Notice, and especially before you provide any personal data to us.

Contact Us

If you have any questions about this Notice or wish to contact SimSpace for any reason in relation to our personal data processing, please contact [email protected].