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Applicant Privacy Notice

Last updated February 15, 2024
This Applicant Privacy Notice (“Privacy Notice”) describes the collection, use, retention, and sharing of your personal information when you apply for a position at CVRx, Inc. (“CVRx”, “we”, “us”, “our”). This Privacy Notice does not apply to third party sites or services outside of CVRx’s career’s page and application process.

PERSONAL INFORMATION WE COLLECT, WHY AND FOR HOW LONG

When you apply for a position at CVRx, we collect personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, to you when you:

  • Complete an application. When you apply for a position at CVRx, we collect from you your personal identifiers (name, email address, physical address, and telephone number), your professional or employment information (resume/CV, cover letter, non-compete or employment contract, and employment history), your educational information (college or university, level of degree, and your discipline) and any other information you choose to include with your application. We use this information to review your background and skills, to determine your qualifications for the role you are applying to, to communicate with you to coordinate the application process, e.g., set up interviews, and to confirm information related to your employment and education. For certain positions, we require you to provide us “Yes” or “No” responses involving your protected classifications (citizenship). We use this information to comply with legal requirements, such as determining if a visa is required, and to determine if we are legally allowed to employ you.
  • Conduct interviews. When you participate in an on-site interview with CVRx we collect from you your personal identifiers (name) and we collect automatically your visual identifiers (video recordings via CCTV systems). We use this information to ensure the security and safety of CVRx personnel and property and to verify your identity.
  • Information from references. When you provide references with your application, we will obtain from your references your professional or employment information (work skills) and will draw inferences from your references, such as their thoughts on how your skills might enable you to succeed in the position for which you have applied. We use this information to assess your suitability for the position for which you have applied.
  • Monitor work-related licenses and credentials. If you apply for a position that requires specific licenses and credentials, we collect from you, as well as from educational institutions, personal and professional references including your personal identifiers (name) and your professional information (licenses, credentials, employment history, educational history, resume/CV). We use this information to verify and manage your work-related licenses and credentials.
  • Verify your education. If you apply for a position that requires a verification of education, we collect from you, as well as from background check providers and education institutions, your non-public education information (verification of education level completed, verification of dates enrolled in educational institutions, certifications obtained, 2 report cards, transcripts). We use this information to verify your education for employment purposes.
  • Conduct a background check. When a background check is requested as part of the candidate review process, we will collect, from you, your personal identifiers (name, date of birth, and physical address) and sensitive identifiers (Social Security number). Social Security number is considered sensitive under the CPRA. We share this information with a background check provider in order to conduct a background check to verify your identity, credentials, and criminal history, and to facilitate the background check. For positions where a pre-employment drug test is required, we share your personal identifiers (name, date of birth, email address, telephone number, physical address) with a third-party drug screening provider to facilitate and arrange the screening. We will subsequently collect your health information (drug test results) from this provider. We use this information to confirm you adhere to CVRx’s drug policy and qualify to work with the health care providers and institutions with whom you are assigned to work, when applicable.
  • Interact with our Applicant Portal. We use Workable to manage our hiring process. Workable may automatically collect your personal information and your internet or other electronic activity information when you apply. You can learn more about how Workable processes your personal information by reviewing their Privacy Policy, Cookie Policy, and Terms of Use.
  • Interact with our Website. When you interact with our website, we collect your internet or other electronic network activity information automatically via cookies, pixels, and similar tracking technologies. Specifically, we use essential, analytics, and performance cookies to collect your usage and device information when you interact with website. We use this information to: (i) track you within the website; (ii) enhance the user experience on the website; (iii) conduct analytics to improve the website; (iv) prevent fraudulent use of the website; (v) diagnose and repair errors, and, in cases of abuse, track and mitigate the abuse, and (vi) conduct analytics of your behavior and use of the website. Third party analytics cookies may be considered sharing under the California Privacy Rights Act (“CPRA”).
    • Google Analytics. We use Google Analytics to collect information on your use of the website for the purpose of improving it. To collect this information, Google Analytics installs cookies on your browser or reads cookies that are already there. Google Analytics also receives information about you from applications you have downloaded that partner with Google. We do not combine the information collected through the use of Google Analytics with personal information. Google’s ability to use and share information collected by Google Analytics about your visits to our Job Portal or to another application which partners with Google is restricted by the Google Analytics Terms of Use and Privacy Policy. To prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser add-on, which can be accessed here.

We process your personal information for as long as necessary to achieve the identified purposes, to satisfy legal retention periods, and to protect our legitimate interests in keeping certain documentation. However, if you are hired, your information will become part of your personnel 3 file and subject to our Employee Privacy Notice. We may need to use and retain your personal information for longer than these reasons for purposes of:

  • Satisfying our legal obligations. For example, retaining your employee records (if hired) the purpose of accounting, dispute resolution and compliance with labor, tax and other financial regulations.
  • Meeting our safety and security commitments. For example, keeping our properties secure and preventing fraud.
  • Exercising or defending legal claims. We also may need to retain information for longer than the above periods in order to meet with legal process or enforceable governmental request, or to enforce our Terms of Use, including investigation of potential violations.

HOW WE SHARE YOUR PERSONAL INFORMATION

A. General Sharing

CVRx shares personal information in the following instances:

  • Within CVRx. We share applicant personal information among our hiring decisionmakers and their functional support (i.e. human resources department, senior management, and hiring managers) to assess applications and make hiring decisions. Access to applicant personal information is limited to those on a need-to-know basis.
  • In the event of a corporate reorganization. In the event that we enter into, or exploring entering into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we would share personal information with third parties, including the buyer or target (and their agents and advisors) for the purposes of exploring, facilitating, and/or completing the transaction. We will also share personal information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings.
  • For legal purposes. We share your personal information when we are legally required to do so, such as in response to court orders, governmental/regulatory bodies, law enforcement or legal process, including for national security purposes. We may share your information with our legal advisors or auditors to establish, protect, or exercise our legal rights or as required to enforce our terms of service or other contracts or to defend against legal claims or demands. We also share this information with third parties as necessary to: detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person; to comply with the requirements of any applicable law; or to comply with our legal obligations.
  • With your consent. Apart from the reasons identified above, we may request your permission to share your personal information for a specific purpose. We will notify you and request consent before you provide the personal information or before the personal information you have already provided is shared for such purpose. You may revoke your consent at any time and may do so by contacting us via email at [email protected].

B. Sharing in the Preceding Twelve (12) Months

For Business Purposes. In the preceding twelve (12) months, CVRx has disclosed the following categories of personal information for a business purpose to the following categories of third parties:

  • Service providers. We have disclosed applicant personal identifiers, sensitive information, educational information, professional or employment information, and internet or other electronic network activity information with service providers that assist us with the application process. These service providers include our background check provider, drug testing provider, cloud provider, recruitment providers, talent acquisition providers, and IT support providers.
  • Government entities. We have disclosed applicant personal identifiers, sensitive identifiers, and professional or employment information with government entities to comply with federal, state, and local laws.

C. Sale of Personal Information

CVRx does not sell applicant personal information. CVRx has shared your internet or other electronic network activity information collected via cookies and other tracking technologies with third parties. Such sharing may be deemed a sale under CPRA.

RIGHTS OF CALIFORNIA APPLICANTS

The California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”) (collectively, “CPRA”) entitles California residents to certain rights. If our processing of your personal information is subject to the CPRA, you are entitled to the following rights:

  • Right to Access/Know. You have the right to request what personal information we have collected, used, disclosed, and sold about you, unless doing so proves impossible or would involve disproportionate effort. You may only make a request for access twice within a 12- month period.
  • Right to Deletion. You have the right to request the deletion of your personal information that we collect or maintain, subject to certain exceptions. For example, if we are required by law to retain the information that you are asking to be deleted, we would not be able to delete the information until we are legally permitted to do so.
  • Right to Correct. You have the right to request correction of any inaccurate personal information that we collect or maintain.
  • Right to Opt-Out of Sale/Sharing. You have the right to opt-out of the sale or sharing of your personal information to third parties. CVRx does not have actual knowledge that it sells or shares personal information of minors under the age of sixteen (16) years. We only sell or share personal information under CPRA via cookies. Our use of third-party cookies may be deemed a sale or sharing under the CPRA.
  • Right to Non-Discrimination. You have the right to not receive discriminatory treatment if and when you exercise your rights to access, delete, opt out, correct, or limit use of sensitive personal information under the CPRA.
  • Right to Limit Use of Sensitive Personal Information. You have the right to limit the use of your sensitive personal information when such use goes beyond that which is 5 necessary for the application process or certain other permissible purposes like fraud, customer service or quality control. Sensitive personal information includes Social Security number, driver’s license number, biometric information, precise geolocation, and racial and ethnic origin. However, CVRx does not process sensitive personal information in a manner which gives rise to this right.

To exercise your privacy rights, you may submit a request by contacting us via email at [email protected] or via telephone at 763-416-2857. For requests submitted by email, please use Subject Line: California Applicant Request. For both methods, you will need to provide us with the following information: your full name, your physical address, your telephone number, your email address, the date for when you applied to CVRx, what position you applied, and which of the above consumer rights you are exercising. We use this information to verify you are the person about whom we collected the personal information and describe your request with sufficient detail to allow us to properly evaluate and respond to it. In doing so, we will take steps to verify your request by matching information provided by you with the information we have in our records. If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information.

Only you, or a person that you authorize to act on your behalf may make a request related to your personal information. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation that you are authorized to act on behalf of that individual.

INFORMATION SECURITY

We implement appropriate technical and organizational security measures, such as access controls and encryption and 24-7 threat monitoring, to protect the personal information that we collect and maintain from unauthorized access, destruction, use, modification, or disclosure. However, no security measure or modality of data transmission is 100% secure, and we are unable to guarantee the absolute security of the personal information we have collected from you.

CHANGES TO THIS PRIVACY NOTICE

CVRx reserves the right to update or modify this Privacy Notice at any time without prior notice. If we do, we will post the changes to this site, and will indicate the date the changes go into effect. We encourage you to periodically review this Privacy Notice to stay informed. If we make changes that materially affect your privacy rights, we will notify you by prominent posting on CVRx’s website, and obtain your consent, if required.

CONTACT US

If you have any questions about this Privacy Notice or need to access this Privacy Notice in an alternative format due to having a disability, please contact us via email at [email protected] or via telephone at 763-416-2857.