Privacy Policy

Effective: December 2025

Welcome to the website (the “Site”) of SimSpace Corporation (“SimSpace”, the
“Company”, “we”, “us”, and/or “our”). This Privacy Policy sets forth SimSpace’s policy on
how we collect, use, disclose, and retain your Personal Data.
“Personal Data”, as used in this Privacy Policy, means any information related to or
about an identified or identifiable natural person.
This Privacy Policy explains:

1. What Personal Data We Collect
2. Sources of Personal Data
3. Our Use of Your Personal Data
4. Our Disclosure of Your Personal Data
5. Retention of and Changes to Your Personal Data
6. Security for Your Personal Data
7. Marketing and Promotional Communications
8. Additional Information Specific to Your Region
9. Changes to this Privacy Policy
10.Contact Us

Scope of this Privacy Policy.
This Privacy Policy applies to the Personal Data of individuals (“you”, “your”, or “yours”)
collected by SimSpace, including the Personal Data collected when you visit Site
(https://simspace.com/, as it may be modified, relocated and/or redirected from time to
time), as well as when you use any of our services, communicate with us, or attend an
event hosted by SimSpace. This Privacy Policy also applies to Personal Data we may
collect from or about the corporate representatives of our customers, vendors,
suppliers, business partners, and others for the purposes of conducting our own
business, such as contracting and invoicing.

This Statement does not apply with respect to the Personal Data we collect by
SimSpace in our capacity as an employer, including the Personal Data of job applicants
or the Company’s current or former employees. SimSpace maintains separate policies,
as required by law, with respect to the Company’s handling of Personal Data as an
Employer.

Third-Party Sites: The Site may include links to, and plug-ins from, sites or applications
operated by third parties (“Third-Party Sites”). SimSpace does not control any ThirdParty Sites and is not responsible for any Personal Data they may collect; the
information collection practices of Third-Party Sites are governed by their own privacy
policies. If you choose to enter any Third-Party Site from this Site, please refer to that
site’s privacy policy to learn more about that site’s processing of your Personal Data.

Children’s Online Privacy Protection Act Compliance: We do not collect information from
anyone under 16 years of age. The products and/or services we provide, together with
our Site, are all directed to individuals who are at least 16 years old. If you are under the
age of 16, you are not authorized to use our Site.

1. WHAT PERSONAL DATA WE COLLECT
The types of Personal Data we collect will vary depending upon the reason that you are
interacting with us. When you interact with us through the Site, or contact us by email,
phone, or other means, we may collect the following Personal Data:

● Identifiers and Contact Information: including your name, mailing address, email
address, phone number, and login credentials (username & password) for a
SimSpace online account

● Professional Data: including your employer, job title and function, business
contact information (business email address, mailing address, and phone
number), and other information necessary to manage the relationship between
SimSpace and the Company you represent.

● Commercial Information: including records of products and services purchased
from SimSpace, and information related to SimSpace events which you have
attended or signed up for.

● Internet or Other Electronic Activity Information: including your IP address or
unique device identifier, as well as other information, such as browser
characteristics, language preferences, operating system details, referring URLs,
length of visits, or pages viewed. When you browse our Site, this also includes
cookies and other information collected through technology, described further
Below.

● Sensory or Surveillance Data: including voicemails and recordings of calls when
contacting us, including for customer support.

● Marketing and Communications Preferences: including products you are
interested in and marketing preferences, and information about your interactions
with, and responses to, our marketing communications.

● Communications Feedback or Other Information You Provide: including the
content of correspondence with us, social media interactions with our social
media presence, comments provided on feedback forms or surveys, or any
information you provide to us voluntarily.

If you provide us with Personal Data relating to other people (e.g., a colleague, a
business contact, etc.), we will handle that information in accordance with this Privacy
Policy. You are responsible for the accuracy of such information and for ensuring that
those people are informed that you provided their Personal Data to SimSpace and that
we will handle their Personal Data in accordance with this Privacy Policy.

Information We Collect Automatically. When you interact with the Site, we may
collect information automatically through cookies and other technologies to help
enhance our ability to serve you. For example, we use these technologies to help us to
better understand user behavior, for security and fraud prevention, and to tell us which
parts of our Site people have visited.

Cookies: Cookies are small files that the Site or our service providers transfers to your
computer’s hard drive through your web browser that enables the Site’s or service
provider’s systems to recognize your browser and capture and remember certain
information. If you are browsing our Site, we may also use cookies or similar
mechanisms to help us measure the number of visits, time spent, pages viewed and
other statistics about traffic to our Site.

When you first visit our Site, you will have the option to select whether to accept or
reject different types of cookies, with the exception of those cookies which are strictly
necessary for a particular service. If you prefer, you can also choose to have your
computer warn you each time a cookie is being sent, or you can choose to turn off
cookies by adjusting your browser settings. You can find detailed information on how to
do so at: https://www.aboutcookies.org/. Like most websites, if you turn your cookies off,
some of the features on the Site may not function properly. In addition, your choices
regarding the use of Cookies may not apply to other websites or when you use a
different device. You can find more information about cookies and other technologies
used on our Site, including how to manage or delete cookies, by visiting SimSpace’s
Cookies Policy.

Analytics Providers: We use third parties, such as Google Analytics, to help us
understand how individuals access and use the Site, as well as help us understand
market trends and popularity of our services. As part of this process, we may
incorporate analytics and tracking technologies from these third parties into our own
Site, and some of our communications such as e-mails. Note however that we have
taken measures to restrict how these entities use the information collected through the
Site. You can learn more about how Google uses this information here.

Web Beacons: We include small graphic images or other web programming code,
called web beacons (also known as “pixel tags”, “web bugs”, or “clear GIFs”), on the
Site. The web beacons are minute graphics with a unique identifier. They are used to
track the online movements of web users. In contrast to cookies, which are stored in a
user’s computer hard drive, web beacons are embedded invisibly on web pages and are
about the size of the period at the end of this sentence. Rejecting cookies using browser
settings may not stop web beacons from tracking you.

Aggregated and Deidentified Information. In an ongoing effort to better understand
and serve our users, we often conduct research on its customer demographics,
interests, and behavior using aggregated or deidentified information. We may aggregate
and/or deidentify the Personal Data and other information provided to us, use it
internally, and disclose to third parties. Neither aggregated information nor deidentified
information is Personal Data.

● Aggregated information refers to information about a group of individuals from
which the individually identifiable information has been removed. An example of
aggregated information would be the statistic that 20 people used our website’s
contact form on a given day. This aggregate information does not identify you
personally. We may also disclose aggregated user statistics in order to describe
our services to current and prospective business partners, and to other third
parties for other lawful purposes.

● Deidentified information means information subjected to reasonable measures to
ensure that the deidentified information cannot be associated with the individual.
An example of deidentified information would be the data point that an
unidentified visitor first entered the Site through our main web page. We maintain
this information in a deidentified form, and do not attempt to reidentify it, except
where needed to ensure our deidentification process is working.

2. SOURCES OF PERSONAL DATA

We may collect Personal Data about you from the following sources:

● Directly from you: for example, when you use our Site, request information,
order, or use our products or services, register for or attend an event, or
otherwise communicate directly with us.

● From your employer or representative: We may collect Personal Data about you
from your employer or the company with which you are affiliated, to provide our
products and services.

● Affiliated companies: for example, when assisting other SimSpace’s subsidiaries
and affiliate companies in providing you with our products and services.

● Service providers and vendors: for example, analytics or IT providers.

● From automated technologies: for example, through cookies on our Site (as
described in more detail above), or recording technologies, such as during phone
calls with customer service.

● Public internet sources: for example, social media, public profiles, and other
public online sources.

3. OUR USE OF YOUR PERSONAL DATA

We use the Personal Data you provide to deliver the services you request, and for other
purposes in connection with running our business, including the following:

Providing Products and Services, including:

● To deliver our products and administer our services.

● To communicate with you.

● To improve our products and services, develop new products and services,
and conduct research on further improvements.

● To enhance your experience using our products and services and to
personalize your online experience.

Support and Marketing, including:
● For customer support.

● To respond to any requests, queries, suggestions, feedback, or comments
you may have.

● To send you marketing information about our services, including notifying you
of marketing events, new services or promotions, with your consent in
accordance with applicable law. This may include email and text message
(SMS) marketing, and other promotional communications about services or
opportunities that may be of interest to you.

● To inform you of any changes to the services, your account (if applicable),
this Privacy Policy, or any other policies or terms in relation thereto.

● To perform operations to maintain the services, including to conduct data
analysis, testing, and research; and to monitor and analyze usage and activity
Trends.

Monitoring, Security, and Compliance, including:

● To administer and protect our business and our Site (including
troubleshooting, analysis, testing, system maintenance, support, reporting
and hosting of data, and preventing fraud and abuse).

● To store, host, or backup (whether for disaster recovery or otherwise) our
services or any data contained therein.

● To protect the rights, property, or safety of Company, you, or others.

● 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.

● To report suspected criminal conduct to law enforcement and cooperate in
Investigations.

● To exercise Company’s rights under applicable law and to support any claim,
defense, or declaration in a case or before a jurisdictional and/or
administrative authority, arbitration, or mediation panel.

● To ensure compliance with applicable laws and regulatory obligations.

Incidental Purposes: We may also use your Personal Data for incidental purposes
related to or in connection with the above, or for any other purpose disclosed to you
prior to or at the time at which the Personal Data is collected, or for which you provide
prior consent.

4. OUR DISCLOSURE OF YOUR PERSONAL DATA

SimSpace does not sell your Personal Data. There are certain circumstances in which
we may disclose your Personal Data including to the following categories of third parties
for the following purposes:

● Business Transfers: As we develop our business, we might sell or buy
businesses or assets. In the event of a corporate sale, merger, reorganization,
dissolution, or similar event, Personal Data may be part of the transferred assets.

● Related Companies: We may disclose your Personal Data with SimSpace’s
subsidiaries and affiliate companies (“Related Companies”) for purposes
consistent with this Privacy Policy, for example, to provide you with our products
and services or to provide you with information about their products and services.

● Service Providers: SimSpace sometimes hires other companies to perform
certain business-related functions on behalf of SimSpace, or assist with meeting
contractual and legal obligations. Examples of such functions include mailing
information, maintaining databases, and processing payments. When we employ
a Service Provider to perform a function of this nature, we only provide them with
the information that they need to perform their specific function, and in
accordance with the Company’s instructions.

● Professional Advisers and Related Third Parties: For example, we may disclose
Personal Data to lawyers to assist us with legal compliance, auditors,
accountants, or consultants to assist us in providing services to you or in
otherwise conducting our business.

● Legal Requirements: SimSpace may disclose your Personal Data if required to
do so by law or in the good faith belief that such action is necessary to (i) comply
with a legal obligation, (ii) protect and defend the rights or property of SimSpace,
(iii) act in urgent circumstances to protect the personal safety of users of the Site
or the public, or (iv) protect against legal liability.

5. RETENTION OF AND CHANGES TO YOUR PERSONAL DATA

We retain your Personal Data for the duration of our relationship with you, and as
needed to provide products services to you (for example, to communicate with you
about your account or your receipt of our services). We will retain Personal Data longer
as necessary to comply with legal, administrative, or procedural requirements, for
example, a litigation hold.

You can correct, update, or remove your Personal Data if it changes by updating your
account. You can delete your account through your account preferences.

If you choose to delete Personal Data from your account or you delete your account
entirely, please note that we may not be able to completely remove your Personal Data
from our systems in certain circumstances, including to comply with legal,
administrative, or procedural requirements. All of your Personal Data that we keep will
continue to be subject to the terms of this Privacy Policy to which you have previously
Agreed.

6. SECURITY OF YOUR PERSONAL DATA

SimSpace takes reasonable steps to protect the Personal Data provided via the Site
from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.
However, no Internet or e-mail transmission is ever fully secure or error-free. In
particular, e-mail sent to or from this Site may not be secure. Therefore, you should take
special care in deciding what information you send to us via e-mail. Please keep this in
mind when disclosing any Personal Data to SimSpace via the Internet.

7. MARKETING AND PROMOTIONAL COMMUNICATIONS

You have the right at any time to prevent us from contacting you for marketing
purposes. You can opt-out of promotional communications by following the unsubscribe
instructions provided in each promotional email that we send to you. We may continue
to send you administrative emails; for example, periodic updates to our Privacy Policy,
even if you indicate that you no longer wish to receive promotional emails from us.

8. ADDITIONAL INFORMATION SPECIFIC TO YOUR REGION

A. Individuals Who Reside in Certain U.S. States

This Section provides additional information for individuals who reside in U.S. states
with comprehensive data protection laws (collectively, “Applicable State Privacy Laws”),
to the extent that our collection and handling of Personal Data is subject to these laws.
These include residents of California, Nebraska, Texas, as well as any other states with
similar laws and regulations applicable to SimSpace, as enacted or amended from time-to-time.

Notice at Collection: SimSpace collects the categories of Personal Data identified in
Section 1, above, for the purposes identified in Section 3, above, and retains Personal
Data for the period described Section 5, above. We do not, and will not, sell your
Personal Data or disclose it to third parties for targeted advertising or cross-context
behavioral advertising. We also do not collect or process sensitive Personal Data for the
purpose of inferring characteristics about you.

No sales or sharing: SimSpace does not sell your Personal Data or disclose it to third
parties for targeted advertising or cross-context behavioral advertising (“sharing”), and
we have no actual knowledge that we sell or share the Personal Data of individuals of
any age, including the Personal Data of children under 16.

Your Privacy Rights: Subject to any applicable limitations and exceptions, you have the
following rights under Applicable State Privacy Laws:

● Right to Access/ Right to Know: You have the right to information about
whether we process your Personal Data, to have access to such data, and
certain details about how we use it. If you are a resident of California, you have
the right to information about Company’s collection, use, and disclosure of
categories of your Personal Data. In addition, in lieu of a right to access, you
have the right to submit a verifiable request to know specific pieces of your
Personal Data obtained from or about you.

● 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.

● Data Portability: Except for residents of California, you have the right to request
that we provide you, or send to a third party, a copy of your Personal Data in
electronic form that you provided to us.

Non-Discrimination: SimSpace will not unlawfully discriminate against you for exercising
your privacy rights under Applicable State Privacy Laws.

How to Exercise Your Privacy Rights: SimSpace will respond to requests access/know,
correct, delete, or of data portability 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 make a request on your
behalf. If an authorized agent submits a request 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].

B. Individuals Who Reside outside of the United States

If you reside outside of the United States, including in Australia, the European Union
(“EU”), Japan, Singapore, the United Arab Emirates, or the United Kingdom (“UK”), the
following also applies to you:

Identification of the Data Controller:

The data controller of your Personal Data is SimSpace Corporation, which is the parent
corporation of the SimSpace corporate group, and the SimSpace corporate group
member, if any, with which you conduct business directly. SimSpace Corporation is
located at 320 Congress St. Suite 7, Boston, Massachusetts, 02210 in the United
States.

Legal Grounds for Processing Personal Data:

Where applicable data protection law requires a legal ground for processing Personal
Data, SimSpace relies on the following grounds for processing as applicable:

● Performance of a Contract: SimSpace process your Personal Data as necessary
for the performance of the sales or service contract with the entity that you
represent, for example, when processing your orders and payments and to take
steps, at your request, before entering into a contract with you, for example, by
providing you with quotes for products and services.

● Required by Law: SimSpace may process your Personal Data as necessary to
comply with applicable law, such as to comply with mandatory reporting obligations
or to respond to a subpoena or court order.

● Legitimate Interests: SimSpace may process your Personal Data as necessary
to pursue the Company’s legitimate interests, including the following:

o Internal administration of the Site and related functions

o Network and information security

o Fraud prevention

o Reporting suspected criminal acts

o To protect the rights, property or safety of SimSpace, our users, or others

● Consent: Where none of the lawful grounds for processing listed above applies
or where applicable law requires consent, we rely on your consent to process
your Personal Data. By submitting your Personal Data to SimSpace and/or
affirmatively indicating your consent through that process, you consent to the
use, disclosure, and transfer of your Personal Data as described in this Privacy
Policy. For information about withdrawing your consent, please see further
Below.

You are not required to submit any Personal Data to us by contract, by the law
applicable to you, or for any other reason. However, if you choose not to submit your
Personal Data to the Site or otherwise not to consent to the processing of your Personal
Data, we may not be able to provide you with the products, services, or other benefits
made available through the Site.

International Transfers of Personal Data:

Due to the global nature of our business and for the purposes described above, we may
transfer Personal Data to parties located in countries other than the one where you
reside, including to parties located in the United States. For example, we may transfer
Personal Data internationally to our subsidiaries, affiliates, service providers, business
partners and governmental or public authorities in another country in connection with
the provision of our products and services to customers. The laws of these countries
may provide a different level of protection for Personal Data than the country where you
Reside.

Before transferring Personal Data across borders, we will take steps to ensure an
adequate level of protection for the transfer whenever required by applicable law to do
so. If you reside in the EU or the 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.

No Automated Decision-Making: SimSpace will not use the Personal Data collected for
automated decision-making, including profiling, that produces legal effects or similarly
significantly affects individuals.

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.

● Japan: You can find more information about the laws of third countries applicable
to the handling of Personal Data, by clicking the relevant country or jurisdiction
listed on this page: https://www.ppc.go.jp/enforcement/infoprovision/laws/.

● Singapore: If you have questions concerning this Privacy Policy or regarding the
handling of your Personal Data, you may contact the Company’s data protection
officer, Greg Kaether at [email protected]

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

9. CHANGES TO THIS PRIVACY POLICY

The Site and our business may change from time to time. As a result, it may be
necessary for us to make changes to this Privacy Policy. We reserve the right to update
or modify this Privacy Policy at any time and from time to time without prior notice.
Please review this policy periodically, and especially before you provide any Personal
Data. This Privacy Policy was last updated on the date indicated below. Your continued
use of the Site after any changes or revisions to this Privacy Policy shall indicate your
agreement with the terms of such revised Privacy Policy.

10.CONTACT US

If you have any questions or would like further clarification about the Site, any of our
products or services, or this Privacy Policy, please e-mail us at [email protected] or
write to 2200 North Alafaya Trail, Suite 500, Orlando, FL 33827.

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 2200 North Alana’s Trail, Suite 500, Orlando, FL 33827, [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:

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].

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