APAC Candidate Privacy Notice


This Brooks APAC Job Candidate Privacy Notice (“Notice”) describes how Brooks Sports, Inc. and our subsidiaries and affiliates (collectively, “Brooks,” “we” and/or “our”) collect, use, disclose, transfer and store (collectively, “process”) personal information about you as a job applicant or prospect in connection with our recruitment activities.

While this Notice is intended to describe the broadest range of our processing activities globally, those activities may be more limited in some jurisdictions based on local laws. For example, the laws of a particular country may limit the types of personal information we can collect or how we use that information. In those instances, we adjust our internal policies and practices to reflect the requirements of local law. The data controller in each case will be the Brooks entity to which the applicant submits his or her application, as specified below.

Table of Contents
I.          Applicability of Other Policies
II.        Information We Collect
III.       How We Collect Your Information
IV.       How We Use Your Information
V.        How We Disclose Your Information
VI.       Data Retention
VII.      Your Privacy Rights
VIII.    International Data Transfers
IX.       Data Controller
X.        Contacting Brooks
XI.       Notice Updates

  1. APPLICABILITY OF OTHER POLICIES

This Notice does not cover our processing of personal information collected from you as a Brooks customer or visitor of Brooks-affiliated websites. To learn more about our data collection practices in these cases, please see our Brooks Sports Privacy Policy. We also have a separate privacy policy that applies to individuals who currently work, or previously worked, for Brooks, which we make available to you if you are engaged for employment with us.

  1. INFORMATION WE COLLECT

We collect information in connection with your application to work with us. The categories of personal information we may process about you include:
  • Information you provide on our application forms, including your full name, username and password for our online recruiting systems, telephone number, personal email address, location, availability, employment history, qualifications, references, work authorization status, and how you heard about the job;
  • Information you provide to us in your resumé, cover letter, and any other files you choose to upload or share with us regarding your qualifications;
  • Information you provide to us during an interview or that we collect through the recruitment process (including work authorization status, willingness to relocate, information about family and dependents for relocation purposes, salary expectations, type of employment contract, interview notes, and results of any assessment);
  • Reference information and/or information received from background checks if you are offered a job (where applicable), including information about your criminal history and information provided by third parties such as past employers, educational institutions, and references; and
  • Information about your educational and professional background from publicly available sources (such as your LinkedIn profile).

Your decision to apply for a position and provide your personal information to us is voluntary. We will tell you if additional information is required to move forward with your application.

Sensitive Personal Information: In certain countries, where permitted by law and on a voluntary basis, we may ask questions about race or ethnicity, veteran status and disabilities for specific purposes, such as to accommodate a disability or illness and to comply with legal obligations relating to diversity and anti-discrimination. We may also ask for information related to citizenship or immigration status when necessary for visa purposes or right to work information. You are entirely free to decide whether to provide such information and your application will not be affected either way. Except as specifically requested, we ask that you avoid submitting information which may qualify as sensitive personal information under applicable law, including race, religion, ethnicity, nationality, age, gender identity, sexual life or sexual orientation, medical or health information, genetic or biometric data, political opinions, political party or trade union membership and judicial data such as criminal records.  

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

  1. HOW WE COLLECT YOUR INFORMATION
Most of the personal information we process is obtained directly from you, such as when you submit a job application or when we conduct a video or in-person interview. If you visit one of our premises for an in-person interview, we may collect audio and visual information through security cameras for safety purposes. We may also receive information about you from other sources, such as from your named references, persons who referred you for a position, from background checks (if applicable), recruiting agencies, third-party recruitment sources and websites and publicly available sources such as your LinkedIn profile.

When you visit our sites, including our careers website, we collect certain information automatically. To collect this information, we may use cookies, web beacons, and similar technologies to power certain functionality of the careers website and understand analytics and activity on the careers website (e.g., links clicked, time spent on pages).

  1. HOW WE USE YOUR INFORMATION

We use your personal information to evaluate a potential employment relationship with you and for other business purposes, including managing our business, keeping our systems secure and complying with legal obligations. Such uses include:
  • Managing our hiring and recruiting activities, including assessing your skills, qualifications and suitability for a particular role or opportunity;
  • Communication with you about the recruitment process and responding to your requests, inquiries and comments;
  • Verification of your information and completion of reference and/or background checks (where applicable) if we offer you a position;
  • Retention of records related to our hiring processes, including a record of the name of unsuccessful applicants, the date of their application and the reason that their application was not successful, to streamline future hiring processes;
  • Legal and compliance purposes, such as responding to suspected fraud, security incidents, or other illegal activity, protecting Brooks’ and others’ rights and property, exercising a legal claim, cooperating with law enforcement investigations and complying with applicable laws, regulations, legal processes or governmental requests;
  • As necessary and appropriate to provide reasonable accommodations;
  • Other uses with your consent, which you may withdraw at any time, such as to send you information about other Brooks positions which may be of interest of you; and
  • Other legitimate interests, including our interests in considering candidates for current and future employment opportunities and in managing and improving our recruitment and hiring process.
If we hire you, information we collect in connection with your application will become part of your employment record and used to manage the onboarding process and for other employment-related purposes in accordance with our internal employee privacy policy.
We must have a legal basis to process your personal data. In most cases the legal basis will be one
or more of the following:
(a) to comply with our contractual obligations to you or to take steps to enter into a contract
with you
(b) to comply with our legal obligations
(c) your consent
(d) to meet our legitimate interests, for example to conduct our recruitment processes
efficiently and fairly or to manage applications effectively. When we process personal
data to meet our legitimate interests, we put in place safeguards to ensure that our
legitimate interests do not override your privacy and other fundamental rights and
freedoms.
When we are required by local law to collect certain personal data about you, your failure to provide this data may prevent or delay the fulfillment of our legal obligations and may impact our ability to employ you. If we ask for your consent to process your personal data, you may withdraw your consent at any time by contacting privacy@brooksrunning.com.

  1. HOW WE DISCLOSE YOUR INFORMATION

Within Brooks Sports, Inc.: We may disclose your personal information to Brooks personnel and affiliates who need to know the information, including personnel in the recruiting, human resources and information technology departments, and in the department responsible for the position for which you are applying.

Service Providers and Contractors: We use service providers and contractors acting on our behalf and pursuant to our instructions to perform some of the activities described above. For example, we disclose certain information to service providers who facilitate our applicant tracking system, video interviews, travel booking and expenses, reporting and analytics and verification/background checking services. We also may disclose information about you to recruitment agencies working with us in relation to your recruitment.

Professional Advisors: We disclose information about you to our professional advisors, including accountants, auditors, lawyers, insurers and bankers if needed. We only permit these advisors to process your personal information for specified purposes and in accordance with our instructions and the provisions of this Notice and applicable law.

Other Third Parties: In limited circumstances, we disclose your personal information to other third parties, including (a) to comply with our obligations, to protect the rights and property of Brooks, our customers and the public, to cooperate with law enforcement investigations and to detect and respond to suspected illegal activity and threats to the health or safety of any person or of our systems or services, (b) in connection with, or during negotiations of, any merger, joint venture, sale of company assets, financing or acquisition of all or a portion of our business, assets or stock by another company (including in connection with any bankruptcy or similar proceedings) and/or (c) with your consent and at your direction.

We may also disclose aggregated or de-identified information, which cannot reasonably be used to identify you. Brooks processes, maintains and uses this information only in a de-identified fashion and will not attempt to re-identify such information except as permitted by law.

  1. DATA RETENTION

If your application for employment is unsuccessful (or you withdraw from the process or decline our offer), we will retain your information for a reasonable period of time beyond the end of the application process for the purposes described above, including complying with our legal obligations, resolving disputes and as necessary for our legitimate interests, such as to consider you for other current and future employment opportunities at Brooks. If you do not want us to contact you regarding other roles, please contact privacy@brooksrunning.com. After this period, we will delete your personal information in accordance with applicable laws and regulations.
If your application for employment is successful, personal information gathered during the recruitment process will be retained during your employment in accordance with our internal personnel privacy policy and retention policies.

  1. YOUR PRIVACY RIGHTS

Depending on where you reside, you may have the right to access, correct/rectify, or delete certain personal information we have about you. You may also have the right to object to and restrict certain processing of your personal information. We may verify your request by asking you to provide certain information. Certain information may be exempt from such requests pursuant to applicable data protection laws.

You can contact privacy@brooksrunning.com to exercise your rights in relation to your personal information. We will respond to your request consistent with applicable law.



  1. INTERNATIONAL DATA TRANSFERS

Due to the global nature of our business, Brooks may transfer your personal information across international borders, consistent with applicable data protection laws, including to the United States.

  1. DATA CONTROLLER
 
  • If you apply to a position in Vietnam, Brooks Sports Vietnam Limited Liability Company will be the data controller of your personal information.
  • If you apply to a position in Shanghai, Run Happy Shanghai Sports Goods Trading co., Ltd. will be the data controller of your personal information.
  • If apply to a position in Taiwan, Brooks Sports, Inc. will be the data controller of your personal information.
  • If you apply to a position in Dongguan, Dongguan Brooks Sports Trading Co., Ltd. Will be the data controller of your personal information.
  • If you apply to a position in Indonesia, Brooks Sports, Inc. will be the data controller of your personal information.
 
  1. CONTACTING BROOKS

If you have questions regarding this Notice or your privacy rights, please contact us at privacy@brooksrunning.com

  1. NOTICE UPDATES

We may change this Notice from time to time. The effective date of this Notice is noted in the header at the top of this page. If we make material changes to this Notice, we will provide additional notice about the updates to this Notice, such as by adding a statement to our careers website.