Applicant Privacy Notice

 

APRIL 12, 2023

 

EDGEWISE Therapeutics Inc. and its subsidiaries and affiliates (collectively, “Edgewise”, “we”, “us” or “our”) takes the protection of personal data seriously.  This Applicant Privacy Notice (the “Notice”) informs candidates and job applicants (“you” or “Applicants”) about the Processing of your Personal Data by Edgewise.  

 

1. What is covered by this Notice

 

This Notice applies to the Processing of Personal Data in the context of your application for a job at Edgewise.  “Personal Data” is any information relating to you as an identified or identifiable individual and “Processing” is any operation (or set thereof) which is performed on that Personal Data.

Within the category of Personal Data, there are “special categories of personal data”, which require a greater degree of protection while Processing.  This includes data on physical and mental health, racial or ethnic origin, political opinions, trade union membership, religious beliefs, sexual life and genetic and biometric data.

 

2. Personal Data that Edgewise Processes about Applicants

Edgewise may collect the following categories of Personal Data, either directly from Applicants, or from other sources including benefits providers, background check agencies, and third parties such as past employers:

 

1.  Contact details (business and personal), including name(s), physical address, phone number(s) and email

2.  Demographic information, including date and place of birth, nationality, gender, marital/ civil status, language, and citizenship/visa information.

3.  Identity information, including social security number, national insurance number, passport number, driver’s license number or other national ID as permitted by law.

4.  Job application information including your application form, CV, references, educational and professional qualification, desired compensation, previous employers, rehiring information, promotion information, lateral move information and position changes.

5.  Assessment information including recordings of video interviews and results of online assessments.

6.  Social media presence.  If you include a professional social media link or identifier in your application, we may retrieve information about your professional social media presence from such social media site.

 

We will only collect and process special categories of personal data (including data regarding criminal convictions and offenses) where this is necessary and relevant for the position you are applying to, and where authorized by law.

 

3. Purpose and Legal Bases for the Data Processing

Edgewise Processes Applicant Personal Data for the following purposes:

 

1.  Evaluating job applications, including registering your application, assessing your job application in view of a potential recruitment, communicating with you about your application.

2.  Background screening, including screening of educational and professional background prior to employment.

3.  Future recruitment, including maintaining a database of job candidates in order to be able to contact potential candidates if any future job opportunities match their profile.

4. Compliance, including complying with applicable legal requirements, industry standards, and our policies, and performing audits.

5. Protecting our rights, including responding to legal claims made against us or otherwise defending our rights and interests to the extent permitted by law.

 

If you are located in the European Economic Area, Switzerland or the United Kingdom (“Europe”), Edgewise only processes your Personal Data when we have a lawful basis to do so, including when:

• Necessary to enter into or to perform our agreement with you;

• You have consented to the use of your Personal Data;

• We have a legal obligation to use your Personal Data, for example to comply with tax and accounting obligations; or

• Edgewise or a third party has a legitimate interest in using your Personal Data. We only rely on our or a third party’s legitimate interests to Process your Personal Data when these interests are not overridden by your rights and interests.

 

Edgewise may also Process “special categories of personal data” but only where that Processing is required by law (such as trade union membership), where it is in the public interest (such as data on race or ethnicity for equal opportunity measures) or where you have made that data manifestly available to Edgewise.  In limited circumstances, Edgewise may seek your explicit consent to process such data.  In these cases, you are free to grant or refuse your consent.  Your employment will not be made conditional upon your granting of consent.

 

4. How we share your Personal Data

For the purposes set out in Section 3 above, Edgewise may share your Personal Data with other parties, including with:

 

• our affiliates and other entities within our group;

• our service providers who perform services on our behalf such as payroll providers, HR service providers, IT companies or service providers, cloud processors, security companies, e-learning platforms, and other service providers appointed by Edgewise from time to time.  We limit the personal data provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to maintain the confidentiality of such information;

• as required by law or when we believe that disclosure is necessary to protect the interests, rights, property, or safety of Edgewise, its employees or others, or to comply with a judicial proceeding, court order, or governmental or regulatory request or legal process served on us; and

• To an acquirer, successor, or assignee of our company as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets;

 

5. Applicant’s Personal Data Rights

If you are located in Europe, you have several rights and choices with regard to our use of your Personal Data:

 

• Request access to and receive information about the Personal Data we maintain about you, to update and correct inaccuracies in your Personal Data, to restrict or to object to the processing of your Personal Data, to have the information anonymized or deleted, as appropriate, or to exercise your right to data portability to easily transfer your Personal Data to another company.  In addition, you may also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.

• Withdraw any consent you previously provided to us regarding the processing of your Personal Data, at any time and free of charge.  We will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal.

 

Those rights may be limited in some circumstances by local law requirements.

You may exercise these rights at any time by contacting us as described at the end of this Notice.  

 

6. Data Transfers

We may transfer your Personal Data to the United States, where we are headquartered.  The United States laws governing data collection and use may differ from those in your country.  When we transfer personal data outside of Europe, we implement appropriate safeguards in accordance with applicable data protection laws.

 

7. How long we store your Personal Data

We take measures to delete your Personal Data or keep it in a form that does not permit identifying you when it is no longer necessary for the purposes for which we Process it, unless we are required by law to keep this information for a longer period.  When determining the retention period, we take into account relevant criteria, such as the position you applied for, whether the application was successful, expected future job openings matching your profile, mandatory retention periods provided by law, and the relevant statute of limitations.

 

8.  Security

We maintain administrative, technical and physical safeguards designed to protect the Personal Data you provide or we collect against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

 

9. Contact Us

Unless otherwise indicated, Edgewise is the entity responsible or “data controller” for the data processing described in this Notice.

 

If you have questions about this Notice, please contact us via email at jmoore@edgewisetx.com, the Data Protection Officer at privacy@edgewisetx.com or via regular mail at:

1715 38^th Street

Boulder, CO 80301 USA

 

For the purposes of the EU General Data Protection Regulation (“GDPR”) and the UK General Data Protection Regulation (“UK GDPR”) we are the data controller. Our representative in the European Economic Area and United Kingdom are as follows:

​​​​​​​

European Economic Area   The DPO Centre Europe Ltd.   Address: Alexandra House, 3 Ballsbridge Park, Dublin, D04C 7H2 Phone number: +353 1 631 9460 Email: dpo@dpocentre.com

United Kingdom   The DPO Centre Ltd.   Address: 50 Liverpool street, London, EC2M 7PY, UK Phone number: +44 203 797 6340 Email: dpo@dpocentre.com

 

If you wish to lodge a complaint about how we process your Personal Information, please contact us at privacy@edgewisetx.com. We will endeavor to respond to your complaint as soon as possible.