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California Applicant Privacy Notice

Effective Date: December 23, 2022

1. General information

Freudenberg Medical, LLC (“Freudenberg” or “we”) is providing this California Applicant Privacy Notice to describe our collection of regulated personal information (“Information”) from job applicants. Please note that this Notice describes our collection and handling of your personal information in your role as an applicant; your rights as a consumer or business partner are separately addressed in our United States General Privacy Policy.

2. Categories of applicant Personal Information we collect and retain

During your application process, we will collect and process personal information about you and other individuals whose personal information you have provided to us. We collect your personal information from a variety of sources but mainly directly from you. You may provide this information directly to our personnel, through identification documentation, by your participation in HR processes, through e-mails you send to us, or through verbal communication that we record electronically or manually. In addition, we also may obtain information about you from your references or other sources. The types of personal information that we may collect and Process about you include the below, to the extent it qualifies as personal information under California law:

  • Personal identifiers, including your full name, Social Security number or other government-issued identification numbers, personal e-mail address, personal phone number, signature, driver’s license number or state identification number, race, sex/gender, date of birth, age, postal address, unique personal identifier (employee identification number), marital status/civil partnership status, date of hire, geolocation, preferred language, resume, ethnic background, work authorization status, birth location, birth country, and/or nationality. We collect this in conjunction with employment applications and retain it if you are employed by us. We may also collect it in the course of your employment.

  • Background and personal history, including your educational background and educational records; employment history; disability, military, or veteran status; requests for family care leave; ongoing education and training courses; requests for disability leave; information on products and services purchased; ancestry information; behavioral information; attitude information; abilities; and/or preferences.

  • Information about third parties, including the names, addresses, e-mail addresses, and telephone numbers. By providing us with the personal information of a third party, you agree that you have the requisite consent and/or permission to share such information with us.

3. How and why we collect applicants’ Personal Information

Your application: when you apply for a job with Freudenberg (whether you already work for Freudenberg or not), we will ask you to provide personal information to support your application and to enable us to determine your eligibility and suitability for the role. This will include the personal information we need to enable us to select the right candidate for the role and may include things such as career history, employment details, educational qualifications, and skills. If you are successful in the employment process any personal information provided to us may then form part of your HR record, which we would maintain for the duration of your employment.

Pre-employment checks: before you start work with us or change jobs within Freudenberg, we may use your personal information to carry out pre-employment checks. Where your local law allows, this may include criminal record checks and right-to-work checks and verify references. We only collect this information where local laws allow it.

Legal and compliance: we may use your personal information as may be necessary to meet our legal, statutory, or regulatory obligations, comply with applicable law, or detect, investigate, defend, bring, or otherwise address legal claims and issues, such as:

  • 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 national security or law enforcement purposes).
  • As necessary to establish, exercise, or defend against potential, threatened, or actual litigation.
  • Where necessary to protect the vital interests of another person.

4. What we do with the Personal Information we collect

We will not sell, trade, or otherwise transfer to third parties your personal information unless we provide you with advance notice; however, we may share this data with our parent company, subsidiaries, and affiliates (our “Business”), and vendors we retain to provide services necessary to our operations (our “Service Providers”). Such third parties could include website hosting companies, public relations companies, advertising and marketing agencies, and mail delivery service companies. These parties are under obligation to use the information only in support of our business, not their own.

We also reserve the right to release personal information (i) when we are under legal compulsion to do so (e.g., we have received a subpoena) or we otherwise believe that the law requires us to do so; (ii) when we believe it is necessary to protect and/or enforce the rights, property interests, or safety of Freudenberg, our users or others; or (iii) as we deem necessary to resolve disputes, troubleshoot problems, prevent fraud, and otherwise enforce the Privacy Statement and any applicable Terms of Use for our Website.

Additionally, if Freudenberg is merged with or becomes part of another organization, or if Freudenberg is sold or it sells all or substantially all of its assets or is otherwise reorganized, the information you provide may be one of the transferred assets to the acquiring or reorganized entity.

5. How we protect your Personal Information

Although we cannot guarantee the impenetrability of our infrastructure, we have established physical, electronic, and procedural safeguards for the information we collect is reasonable given the nature of the information and its sensitivity.

6. How long we keep your Personal Information

If you are employed by us, we retain personal information for as long as you are employed with Freudenberg or post termination of employment if it is necessary to provide the services you have requested and for other legal compliance or essential business purposes such as enforcing our employment contracts, maintaining the security of our services, enforcing our legal rights, or dispute resolution. If you are employed by us, you will receive our California Employee Privacy Notice, which will explain the future handling of your Personal Information.

If you are not hired by us, we retain your employment application information and associated records for seven (7) years after an employment decision.

7. California privacy rights

Under California law, you have certain rights regarding information that could reasonably be used to identify you or your family. This Privacy Policy is provided so that you can understand at or before the point of collection what we are collecting and why. These rights do not extend to anonymized or aggregated information that can no longer be connected to you personally. Please note also that certain banking and health information is outside the scope of these state data privacy laws.

Right to know and data portability. You have the right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom we disclose Personal Information, and the specific pieces of Personal Information we have collected about the consumer.

Under California law, we are not required to research Personal Information where it is not in a reasonably searchable format, we maintain the information solely for legal or compliance reasons, we do not use the information for commercial purposes or sell it, and we explain what we are not searching on these grounds. Likewise, we are not required to disclose a particular Social Security number, driver’s license number or another government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions, and answers, or unique biometric data generated from measurements or technical analysis of human characteristics. We will, however, identify which of these items we retain.

Right to deletion. You have the right to delete Personal Information that we have collected from you, subject to certain exceptions; except where there is a statutory exception. In California, these exceptions when the Personal Information is needed to:

  1. Complete a transaction for which the Personal Information was collected, provide a good or service requested by you, reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
  3. Debug to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act under Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the California Penal Code.
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research if you have provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.

We may ask you to confirm your election to delete your Personal Information.

Right to correct Personal Information. You have the right to correct inaccurate Personal Information that we maintain about you. We may request documentation establishing the inaccuracy of the information we have. Per applicable law, these requests may be denied if the totality of the circumstances suggests that the information we have on file is accurate.

Right to limit the use of Sensitive or Special Personal Information. You have the right to limit the use of sensitive Personal Information (as defined by law) to that necessary to conduct business with you. Freudenberg does not collect intentionally collect these types of information from the public and does not use them in its external business dealings.

Right to Opt-Out of the sale or sharing of your Personal Information. Freudenberg does not sell Personal Information and has not done so in the past twelve (12) months. If Freudenberg conducts activities that may constitute the sale or sharing of Personal Information under the law, it will provide the appropriate notice and an opportunity to opt out.

Right to non-discrimination. You have the right to not be discriminated against due to the exercise of your privacy rights. However, the exercise of certain privacy rights by California residents may make it so that we are no longer able to provide those residents with certain services or communications. For example, if, at the request of a California resident, Freudenberg deletes all of the California resident’s Personal Information that it maintains, Freudenberg will no longer be able to send communications to that resident.

Right to opt out of automated decision-making or profiling. You have the right to know about and opt out of automated decision-making.

Other rights: to the extent you have data subject rights that are not shown here, we will honor them.

Exercising your rights. To exercise your rights, please contact privacy@freudenbergmedical.com or call +1 (978) 281-2023 or +1 877) 308-0558 and state the nature of your request. We will require you to verify your identity. There are some circumstances in which we are not required to grant requests concerning your Personal Information, including where repeated requests are made for purposes of harassment or fraud.

Authorized agents. California residents can designate an authorized agent to make requests under the CCPA on their behalf relating to the residents’ Personal Information. Only you as a California resident, or a person you have designated in writing as your authorized agent, may make a consumer request related to your Personal Information.

If you wish to have an authorized agent make a verifiable consumer request on your behalf, they will need to provide us with sufficient written proof that you have designated them as your authorized agent, such as a power of attorney under California Probate Code sections 4000 to 4465. We will still require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we have collected Personal Information.

We can deny any request made by a purported authorized agent who does not submit proof that they have been authorized by the California resident to act on the California resident’s behalf. For more information on submitting a request on behalf of a California resident as an authorized agent, you can contact us using the information at the bottom of this Privacy Statement.

Response time. Consistent with CCPA, we will respond within 45 days of a verifiable request to provide or erase your Personal Information, unless we notify you that up to another 45 days will be needed.

8. How do I ask questions and provide feedback regarding privacy?

We welcome your questions, comments, and concerns about privacy. Freudenberg is committed to the resolution of concerns about your privacy and our collection or use of your personal information. If you have any questions regarding this privacy statement or how we protect your data, please contact us at:

Freudenberg Medical
Attn: Recruiting/Privacy
40 Sam Fonzo Drive
Beverly, MA 01915
+1 (978) 281-2023

+1 (877) 308-0558
privacy@Freudenbergmedical.com