European Candidate Privacy Notice

SeatGeek, Inc.

1. Introduction and Scope

SeatGeek, Inc. (“SeatGeek”, “we or us”) has issued this Privacy Notice (this “Notice”) on behalf of each of the SeatGeek Group companies operating in Europe. We respect the privacy rights of individuals and are committed to handling personal information responsibly and in accordance with applicable law. It is important that you read all of this Notice carefully as it sets out how we handle your personal information when you apply for a job or other role with us and the rights you have in connection with that information. The term “applicants” is used in this Notice to refer to anyone who applies for a job role, or who otherwise seeks to carry out work with or for us (whether on a permanent or non-permanent basis).

Where we refer to SeatGeek below, the reference is to the SeatGeek Group entity to which you have made an application (which will be the primary controller in relation to your personal information), as identified per country in the table below:

If you are in any doubt, or have any comments or questions about this Notice, please contact us using the contact details set out at Section 9 below.

2. Information We Collect and Why

Information that we collect automatically

You can visit the recruitment section of our website https://seatgeek.com/jobs/ (“Website”) and search for jobs without providing personal information. However, we do collect certain information automatically from your device when you visit our Website. For further information, please see the privacy notice that applies to the use of our Website https://seatgeek.com/privacy.

Personal Information collected from you

The types of personal information we collect and process when you apply for a role with SeatGeek includes (but is not limited to):

• Identification data and contact details – including your name, address, email address, phone number and other contact information, gender, date of birth, nationality/ies, national identifiers (such as national ID/passport, photos, social security number(s), or other tax ID numbers).
• Employment history – such as previous employers and job titles/positions.
• Background information – such as academic/professional qualifications, job qualifications, education, details included in your CV/résumé (which might include details of any memberships or interests constituting sensitive personal information), transcripts and employment references.
• Criminal background checks – where permitted by local employment and/or data privacy legislation, we may perform criminal background checks on candidates applying for positions where an individual’s criminal history and trustworthiness may be relevant. Where local employment and/or data privacy legislation prohibits us from performing such checks, we may request that you provide SeatGeek with a copy of a criminal history and/or background check as part of your application process.
• Details of your nominated referees (including their name, contact details, employer and job role).
• Details of your immigration/visa status, where applicable and permitted.
• Previous applications/roles (information relating to previous applications you have made to SeatGeek and/or any previous employment history with SeatGeek’s Group).
• Job application information (such as the roles for which you are applying, your job application and related documentation/communications, cover letters, information from interviews and phone screenings, compensation/benefits requests and relocation information).
• Other information you voluntarily provide throughout the process, including through assessments, exercises, and interviews.

As a general rule, we try not to collect or process any of the following during the recruitment process: information that reveals your racial or ethnic origin, religious, political or philosophical beliefs or trade union membership; genetic data; biometric data for the purposes of unique identification; or information concerning your health/sex life, or gender identity (“Sensitive Personal Information”), unless authorized by law or where necessary to comply with applicable laws.

However, in some circumstances, we may need to collect, or request on a voluntary disclosure basis, some Sensitive Personal Information for legitimate recruitment-related purposes: for example, information about your racial/ethnic origin, gender and disabilities for the purposes of equal opportunities monitoring, to comply with anti-discrimination laws and for government reporting obligations (we will not identify any person in such reports); or information about your physical or mental condition to consider accommodations for the recruitment process and/or subsequent job role. You may provide, on a voluntary basis, other Sensitive Personal Information during the recruitment process.

Personal information collected from other sources

We may, but do not always, collect some personal information (or in some circumstances Sensitive Personal Information) from other sources. For example:

• References you provide
• Other background information provided or confirmed by academic institutions and training or certification providers.
• Information collected through our recruitment platform which is administered and maintained by Greenhouse.
• Information collected from publicly available sources, including any social media platforms you use or other information available online.
• Criminal background check history from third-party sources.

In each case, SeatGeek will only collect and process this personal information where permissible and in accordance with applicable law.

3. Purposes for Processing Personal Information

We collect and use this personal information primarily for recruitment purposes – in particular, to determine your qualifications for employment and to reach a hiring decision. This includes assessing your skills, qualifications and background for a particular role, verifying your information, carrying out reference checks or background checks (where applicable) and to generally manage the hiring process and communicate with you about it.

If you are offered a role at SeatGeek and accept that offer, we will also process Personal Information such as your name and email address in order to create necessary internal accounts, for example your account on Workday. The information collected during the recruitment process will form part of your ongoing staff member record and will be processed in accordance with our Employee Privacy Notice.

4. Information We Provide to Others

We may make certain personal information available to third parties who provide services relating to the recruitment process to us, including:

• Data storage, shared services and recruitment platform providers, IT developers and support providers and providers of hosting services in relation to our careers website, e.g. Workday, Greenhouse and Amazon Web Services;
• Third parties who provide support and advise us in relation to legal, financial, audit, management consultancy, insurance, and health and safety issues.

We may also disclose personal information to third parties on other lawful grounds, including:

• Where you have provided your consent;
• To comply with our legal obligations, including where necessary to abide by law, regulation or contract, or to respond to a court order, administrative or judicial process, including, but not limited to, a subpoena, government audit or search warrant;
• In response to lawful requests by public authorities (including for tax, immigration, health and safety, national security or law enforcement purposes);
• As necessary to establish, exercise or defend against potential, threatened or actual legal claims;
• Where necessary to protect your vital interests or those of another person; and/or
• In connection with the sale, assignment or other transfer of all or part of our business.

5. Transfer of Personal Information Abroad

We may transfer your Personal Information outside of the EU/EEA/UK, to countries that do not offer an equivalent level of protection. Regardless of where your Personal Information is transferred, we shall ensure that relevant safeguards are in place to afford your Personal Information adequate protection.

To ensure that your Personal Information is sufficiently protected, we will only transfer Personal Information to a recipient outside the EEA pursuant to a data transfer mechanism recognized by law as a lawful basis for such transfer, such as transferring Personal Information to a recipient: (i) in a country that is deemed to provide an adequate level of protection for Personal Information; or (ii) that has executed with the SeatGeek a data transfer agreement incorporating the EU’s standard contractual clauses. Further details regarding the relevant safeguards can be obtained from us on request.

6. Legal Bases for Processing Personal Information

Under European data protection law, our legal bases for processing your personal information as part of the recruitment process include:

• Our legitimate interests (as summarized above in Section 3) (which are not overridden by your data protection interests or fundamental rights and freedoms, particularly taking into consideration the safeguards that we put in place, for example, those outlined in Section 4 above);
• To comply with applicable immigration and/or employment laws and regulations;
• To take steps prior to entering an employment contract with you, where you are considered for employment;
• In circumstances where you have made the data public;
• Where we have your consent to do so. Where we have requested your consent to process your personal data, you have the right to withdraw your consent at any time;
• To protect the rights and interests of SeatGeek, our employees, applicants and others, as required and permitted by applicable law.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). SeatGeek will ask for your consent if it intends to perform or request criminal background checks on you.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided in Section 9 below.

7. Retaining and Deleting Your Personal Information

Personal information will be stored in accordance with applicable laws and kept as long as needed to carry out the purposes described in this Notice or as otherwise required by applicable law. Generally, this means your personal information will be retained:

• In accordance with the retention periods set out in SeatGeek’s Employee Privacy Notice (where you become our employee);
• For a period of up to thirty (30) days (where permitted by applicable law) after confirmation that your application was unsuccessful (to allow us to consider you for other suitable openings within SeatGeek in the future) unless you request that we delete your application by contacting us using the contact details set out at Section 9 below;
• Criminal background check results for unsuccessful candidates will be deleted at the end of the recruitment process.

8. Your Privacy Rights

You may exercise the rights available to you under applicable data protection laws as follows:

• If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided below. You can also manually request deletion of your data through our iCIMS portal.
• You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided below.
• If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

9. Contact Details

If you have any questions about this Notice, your personal information, or your rights please contact:

Privacy Office
privacy@seatgeek.com

OR

SeatGeek, Inc.
Privacy Office
902 Broadway, 10th Floor
New York, NY 10010
United States