Recruitment Privacy Notice

Last Updated: December 13, 2024

This notice sets out SALT’s policy on processing the personal data of job applicants or others seeking information about employment opportunities with us. In this notice, Salt Blockchain Inc. and/or its affiliates may be referred to as the “Company,” “we,” or “us.” The words “you” and “your” refer to the job applicant or other person whose data we process.

As part of our recruitment process, we collect and process personal data relating to job applicants, including special categories of data. It is our policy to handle your personal information responsibly and in accordance with the requirements of applicable data protection laws, including, among others, the European Union’s General Data Protection Regulation (GDPR) and applicable California law.

Nothing in this notice is intended to create an employment relationship between the Company and you, and it does not create contractual rights or obligations. It is also not intended to change or remove any rights or protections you have by law in the State or country in which you are located. This means that some of the ways in which we collect and use personal information or other details described in this notice may not be relevant in your jurisdiction.

If we extend you an offer for a position and you accept that offer from us, we will process further information from you in your capacity as a member of our workforce and will provide you with a workplace privacy notice as part of the onboarding process.

If you want further details of any of the terms of this privacy notice and the safeguards set forth herein, please contact us using the details in the “Contact Us” section or the contact information below.

The Personal Information We Collect

We collect a range of information about you as part of your job application and recruitment process. This may include:

your name, alias, postal address, contact details, including email address, telephone number and a photograph, SSN, driver’s license number, passport number
your signature, physical characteristics or description, state ID card number, bank account number
your date of birth, gender, marital status
details of your education background, qualifications, professional licenses and memberships, skills, experience, employment, and employment history, CV, interview notes, outcome of application
information about your current level of compensation, including benefits
whether or not you have a disability for which we need to make reasonable adjustments during the recruitment process, and other health information
information about entitlement to work in a jurisdiction, which may include visa status
passwords and security questions when you apply via our website
equal opportunities monitoring information, including information relating to characteristics of protected classifications under state or federal law, including race, color, national origin, gender, disability, age, citizenship status, gender identity, sexual orientation, marital status, military or veteran status, and political activities or affiliations
Internet or other electronic network activity information, including, but not limited to, information regarding your interaction with our website, and
any other information you provide us during the recruitment and application process.

In order to obtain employment, you will be responsible for the content of the information you provide to us and you must ensure it is legal, honest, truthful, accurate and not misleading in any way. You must ensure that the information provided by you does not contain material that is obscene, blasphemous, defamatory, infringing on any rights of any third party, or otherwise legally actionable by such third party. You understand that, in the event that your application is successful, you may be subject to disciplinary action and possible dismissal if the statements contained in the application form and supporting documents prove to be untrue or inaccurate.

How We Collect Personal Information

We collect this information as part of our recruitment and hiring processes in a variety of ways, including:

directly from you when you apply for a role or when you submit your personal information to us via our website or an alternative application form
from your passport or other identity documents, or through interviews or other forms of assessment
from third parties, such as recruitment agencies acting on your behalf or references supplied by former employers, information from employment background check providers and information from criminal records checks. We will seek information from third parties only once a job offer to you has been made and will inform you that we are doing so, and
data from partners and employees of the Company as a result of internal referrals or other information generated as part of our recruitment processes.

How We Use Personal Information

We use the information we collect in a number of ways, including:

to identify you and process your application
to manage the recruitment process, assess and evaluate your candidacy and decide whether or not to offer you a job
to contact you with communications about employment opportunities with us
to fulfill our legal and regulatory obligations, including reporting obligations and in connection with potential or actual legal or regulatory proceedings or investigations
to fulfill our contractual obligations
to communicate with you and provide information requested by you, and (where relevant) to repay approved expenses incurred as part of our recruitment processes
to contact references or individuals who may provide information to us about your employment history, or fitness for employment or engagement with us
to consider terms for entering into a contract with you (if you are made an offer)
to improve our website, including auditing and monitoring its use, to provide users with a customized experience, and to understand our website audience and demographics and their interests and content preferences
to determine if we need to make reasonable accommodations for candidates who are disabled and have need for such
to fulfill our obligations under diversity and equal opportunities regulations, and to monitor the effectiveness of our diversity efforts
to support and evaluate our personnel
in connection with the administration of events, financial planning and budgeting
to book travel, and
to obtain business-related information through surveys conducted by us and others.

Some of the information listed above is necessary for us to consider your suitability for the role and will be collected if you have been offered a position at the Company after you have accepted such offer, such as your qualification details or proof of identification. If you do not provide information that you are required to give us by law or as necessary to enter into a contract, we may not be able to employ or engage you. If you have concerns about this in a particular context, you should speak to your person of contact.

We process personal information on one or more of the following grounds:

for our legitimate business purposes, as described above and as generally applicable
to take steps with a view to entering into a contract of employment with you
for the establishment, exercise or defense of legal claims or proceedings
to comply with legal and regulatory obligations

Your information will be shared with individuals involved in the Company’s worldwide recruitment efforts. This includes members of the HR and recruitment team, interviewers involved in the recruitment process and partners/managers in the business area(s) relevant to your application.

We may also share your personal information with trusted third parties in accordance with contractual arrangements in place with them, including:

IT service providers
your appointed recruitment agent (if applicable), and
our own professional advisers and auditors.

If your application for employment is successful and we make you an offer of employment, we will then share your data with our employment background check providers to obtain necessary background checks (which may include contacting your former employers to obtain references for you).

We may share your information with a potential purchaser and their legal and financial advisors and others, as appropriate, as part of any actual or contemplated reorganization, restructuring, merger or sale, or other transfer of assets involving our brands or as part of a joint venture or other strategic partnership.

In some circumstances, we may also pass information to regulatory authorities, courts, tribunals, government agencies and law enforcement agencies. We may be required to disclose your information to comply with legal or regulatory requirements. Where possible, we will use reasonable efforts to notify you before disclosing your information, but we may be legally restricted from doing so.

This may involve a transfer of your information to another country that does not provide the same level of protection for your personal information. We will implement appropriate measures to ensure that your personal information nevertheless remains protected and secure in accordance with applicable data protection laws.

Protecting Your Personal Information

Data will be stored in a range of different places, including on your application record, in HR management systems and on other of our IT systems (including email). We use a variety of commercially reasonable technical and organizational measures to help protect your personal information from unauthorized access, use, disclosure, alteration or destruction consistent with applicable data protection laws.

Retaining Your Personal Information

We retain personal information of different types, or relating to different categories of people, for different periods, taking into account its business purpose. For example, information about individuals who have applied for employment with us will be retained for a shorter period than information about individuals who have actually worked for us.

The periods for which we retain information are based on the requirements of applicable data protection laws and the purpose for which the information is collected and used. We take into account legal and regulatory provisions which require information to be retained for a minimum period. We also consider the limitation periods for taking legal action and good practice in the legal industry.

If your application for employment is successful and you join the Company, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment.

Your Personal Information Rights

As a data subject, you have a number of rights. These rights are not available everywhere and may be limited by local laws. Depending on where you are located, you may have other rights regarding your personal information.

You may:

access and obtain a copy of your data on request,
require us to change incorrect or incomplete data,
require us to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing,
object to the processing of your data where we rely on legitimate interests as the legal ground for processing, and
ask us to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override our legitimate grounds for processing data.

Before responding to a request, we may need to ask for additional information and may send you an email to verify your identity or confirm that you submitted the request. We may also need additional information to verify that your authorized agent or representative has the authority to make a request on your behalf. We will respond to your request within the time period required under the law. If you have any unresolved privacy concerns that we have not addressed satisfactorily after contacting us, you may have the right to appeal our decision or contact your local data protection authority to lodge a complaint.

California Notice of Collection of Personal Information

The Company collects the categories of “personal information” cited in the section entitled “The Personal Information We Collect” above. We use this information as described in the section entitled “How We Use Personal Information” above. We retain your personal information as described in the “Retaining Your Information” section of this notice. You have certain rights and choices regarding your personal information as described in the section above titled “Your Personal Information Rights.” To the extent we use deidentified information, we will keep the information in the same form and not try to alter the information so it can be used to identify you.

Opt-out Rights and Non-discrimination. We do not sell your personal information covered by this notice, nor do we disclose your personal information for cross-context behavioral advertising. We will not unlawfully discriminate or retaliate against you for exercising your rights described here.

Some of the categories of personal information listed above are defined as “sensitive personal information.” We use sensitive personal information as necessary for the direct purposes relating to the recruitment and application process or other service relationship, as applicable and further as described in the section titled “How We Use Information”. We do not use sensitive information to infer characteristics about you.

What If You Do Not Provide Personal Data to Us?

You are under no obligation to provide data to us during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.

Contacting Us

If you have any questions on the matters covered in this notice, please contact us at [email protected] or (720) 575-2272.

Changes To Our Recruitment Privacy Notice

We may update this notice and make changes as our services or privacy practices change, or as required by applicable laws or regulations. This notice was last updated on the date set forth above.