BEATSTARS EUROPEAN APPLICANT AND PERSONNEL PRIVACY NOTICE

Last updated: April 14, 2023

BeatStars Inc. (“BeatStars”) is deeply committed to personnel privacy. This European Applicant and Personnel Privacy Notice. (“Notice”) describes what information BeatStars collects about its Applicants and Personnel and also explains the rights and the choices you have relating to your personal data and how to exercise those rights.

If after reading this document you have any further questions or would like additional information, please feel free to contact us at people-operations@beatstars.com.

Scope

This Notice applies to the processing of personal data of current and former employees, officers, directors, temporary employees, contractors, consultants, (together “Personnel”), and applicants for employment (“Applicants”), working in Europe, including in the European Union or European Economic Area countries, the UK (collectively “Europe”).

This Privacy Notice supersedes any Notice that covers in whole or in part the scope of this Notice unless specifically stated otherwise.

BeatStars, 4301 W. William Cannon Dr. Ste. B150 #408, Austin, Texas 78749, is the controller of your Personal Data as defined below.

Categories of Personal Data that BeatStars collects

Any information that can directly or indirectly identify an individual, or that relates to the personal characteristics of an identified individual, is considered “Personal Data.” The categories of Personal Data that BeatStars processes about Applicants or Personnel are:

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General Category of Information	Specific Categories of Data
"Identification, Contact and Basic Biographical Information"	"Full legal name, preferred name/nickname, gender, citizenship/nationality/immigration status, home address, country of residence, professional and personal phone and mobile numbers, national/government ID number and/or national identity card details, social security number, passport number, photograph, professional and personal email address, date of birth/age, place of birth, marital status, racial/ethnic origin, religious beliefs, emergency contact information and additional family member or dependent data (to the extent necessary for administering health benefits or other benefits), insurance, social media information, military status and signature."
Education and Qualifications Information	"Job application details (e.g. application form, CV, interview notes, references), previous work history, professional memberships, qualifications/certifications and awards, education level degrees/diploma(s), academic transcripts, graduation name, reference or background checks, salary/wage expectation, languages, if referred by a BeatStars employee, name of that employee."
Employment Information	"Personnel number (Work ID/BeatStars ID), employee contract and any amendments to it, contract type (fixed term, temporary, permanent, full/part time status), business unit/division, job title/role, job description/type of work, responsibilities and experience, projects, areas of expertise, career interests, preferred location, mobility and relocation interests, line/reporting manager, evaluation and performance data/performance rating, hours of work, timesheet or attendance data, holidays, annual leave information, start date, end date, reasons for separation, exit interview and comments, records of training participation and completion, history of discipline (if any), union membership (if any and where required/permitted by law)."
Compensation and Payroll Information	"Bank account information, compensation data, salary, payroll information, bonus payments, tax identification numbers and details, social security deduction data, records of expenses for reimbursement (including any credit card or bank card data in expense records)."
Health and Benefits Information	"Benefits and entitlements data, pension membership, pension join date and entry, pension contributions, life insurance beneficiaries, medical and health information, disability status, sexual orientation status, pregnancy status (for maternity/paternity leave), information about medical leave of absence and worker’s compensation claims, health & safety related information and reporting."
"Company Equipment, Credit Card, Travel Information"	"Data related to equipment, material, tools and furniture granted by BeatStars, Company credit card transaction history and expenditures, information concerning employee travel related to work."
Automobile and Driving Information	"Where relevant to your job: driving license number, driving record/driving citations, vehicle license plates and/or other vehicle identifiers, information about a company car if you are provided with one."
Information Technology Data	"Network and computer User-ID(s) / username, email metadata and contents of emails sent to/from BeatStars email addresses, contents of documents stored or transmitted on BeatStars’s systems, records of employee chat messages and communications (including the content of the messages), network activity logs (which contain data concerning traffic on BeatStars’s networks and websites visited—excluding the Personnel WiFi network—and traffic to/from BeatStars’s networks from external networks), information logged by BeatStars-owned computers, the device identifier of personal mobile devices that are registered to access BeatStars’s email and external computing services."
Grievance Information	"When an individual reports a grievance: the identity, position and contact details of the employee submitting the grievance, the persons who are the subject of the grievance, the persons handling the grievance and any witnesses; and to the extent they relate to an identifiable individual: the facts reported, additional facts, details and evidence gathered during the investigation of the grievance, the results of the investigation, any decisions taken as a result of investigation into the grievance."
Criminal History	Data related to one’s criminal history or criminal convictions

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BeatStars’s purposes and legal bases for using Personal Data

We hold and process your Personal Data in general for human resources management but more precisely for the following primary purposes:

hiring and recruitment, background checks (where legally authorized), work references (where you authorize us either to receive and/or provide a reference), on-boarding, off-boarding, verification of right to work and government compliance;
time and attendance, workforce and corporate planning, organization of staff, leave management;
performance management, supervision, career planning, talent management, succession;
compensation and benefits administration, health and workers compensation administration and management, remuneration and payroll administration, pension management, mobility;
training, employee education and development;
management of BeatStars properties, managing workplace health, safety & security, IT security and management, maintenance, management of corporate credit cards and employee expenses, management of company equipment and cars;
employee relations and management including grievance, complaints, harassment, discrimination, misconduct, disciplinary issues;
whistleblowing and legal compliance, theft or loss prevention, fraud detection, quality control.

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Most of the processing of your Personal Data is performed under GDPR Art. 6(1)(b), on the basis of a contractual necessity to process your data (e.g. processing of your financial information to pay your salary, processing your work history information as preparation for entering into an employment contract with you, processing performance and evaluation information to ensure that both parties are fulfilling their contractual obligations) or are performed under GDPR Art. 6(1)(c), to enable BeatStars to comply with a legal obligation (e.g. social security data, pension data, health & safety).

In limited cases, not covered by these bases, BeatStars may process your Personal Data under GDPR Art. 6(1)(f) to pursue a legitimate interest (e.g. planning, talent management, engagement, Personnel wellbeing, learning and development).

To whom BeatStars discloses Personal Data

We share Personal Data with external service providers who we rely on or with whom we cooperate such as Greenhouse, which hosts our employee application process, payroll agencies, training providers, consultants, insurer and health and safety services. These trusted business partners will be given limited access to your Personal Data as is reasonably necessary to deliver the services they are engaged to provide. They are required by law or where appropriate contractually obligated to process any Personal Data collected from you, including on our behalf, in a manner that is consistent with Privacy Laws or this Privacy Notice. Service providers that processes your Personal Data on our behalf will also commit to implement reasonable security measures.

BeatStars discloses Personal Data to applicable governmental and tax authorities.

In some instances, BeatStars may need to disclose Personal Data to the police or judicial authorities, or other government regulators, or third parties, where required by law or in order to protect and defend our rights and interests and those of third parties, including to manage and respond to legal claims or disputes, and to otherwise establish, defend or protect our rights or interests, or the rights, interests, health or safety of you or others, or to comply with a judicial proceeding, court order, legal process or other lawful requests.

BeatStars may disclose your Personal Data in the event of a merger, acquisition or other business transaction, including for purposes of planning, due diligence and implementation of commercial transactions (e.g., mergers, acquisitions, asset sales or transfers, bankruptcy or reorganization or other similar business transactions).

International Data Transfers

BeatStars transfers Personal Data to the United States. Such transfers are made based on Standard Contractual Clauses approved by the Commission of the European Union to allow the transfer of your Personal Data to the United States and ensure processing in accordance with applicable laws and regulations and with this Notice.

Data retention

Your Personal Data will be retained only as long as required for the purposes for which these have been collected and in compliance with any legal obligations.

Your rights regarding your Personal Data

If you are in a European Union or European Economic Area country (including the UK), you have the right to access your Personal Data being processed by us. This right is limited to the extent that it affects the right and freedom of others or there are other reasons that may prevent disclosure of information (e.g. confidentiality, legal professional privilege, where disclosure may compromise a whistleblowing investigation, etc). Further, you have the right to demand the correction or removal of any incorrect, incomplete or irrelevant data or the portability of your relevant data. You also have a right to restrict processing or to object to any processing which we would have grounded on our legitimate interest as set out under (III).

You can exercise these rights by contacting us by means of a written request, dated, signed and addressed to BeatStars Inc. 4301 W. William Cannon Dr. Ste. B150 #408, Austin, Texas 78749. Should you not receive a satisfactory answer to your request, please note that you have the right to lodge a complaint with a supervisory authority (see a complete list here: https://edpb.europa.eu/about-edpb/board/members_en).

Changes to this Privacy Notice

We will review and update this Notice regularly in accordance with our data protection obligations. We may amend, update or supplement the Notice from time to time (e.g. to reflect new legal and/or technical developments). We will circulate any new or modified Notice when it is adopted.

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