This policy explains:

• What information we collect during our application and recruitment process and why we collect it.
• How we use that information; and
• How to access and update that information.

Types of information we collect

This policy covers the information you share with us and/or which may be acquired during the application or recruitment process including:

• Your name, address, email address, telephone number and other contact information.
• Your resume or CV, cover letter, previous and/or relevant work experience or other experience, education, transcripts, or other information you provide to us in support of an application and/or the application and recruitment process.
• Information from interviews and phone-screenings you may have, if any.
• Details of the type of employment you are or may be looking for, current and/or desired salary and other terms relating to compensation and benefits packages, willingness to relocate, or other job preferences.
• Details of how you heard about the position you are applying for.
• Any sensitive and/or demographic information obtained during the application or recruitment process such as gender, information about your citizenship and/or nationality, medical or health information and/or your racial or ethnic origin.
• Reference information and/or information received from background checks (where applicable), including information provided by third parties.
• Information relating to any previous applications you may have made to Vitori Health and/or any previous employment history with Vitori Health.
• Information about your educational and professional background from publicly available sources, including online, that we believe is relevant to your application or a potential future application (e.g., your LinkedIn profile); and/or
• Information related to any assessment you may take as part of the interview screening process.

How we use information we collect

Your information will be used by Vitori Health for the purposes of carrying out its application and recruitment process which includes:

• Assessing your skills, qualifications, and interests against our career opportunities.
• Verifying your information and carrying out reference checks and/or conducting background checks (where applicable) if you are offered a job.
• Communications with you about the recruitment process and/or your application(s), including, in appropriate cases, informing you of other potential career opportunities at Vitori Health.
• Creating and/or submitting reports as required under any local laws and/or regulations, where applicable.
• Where requested by you, assisting you with obtaining an immigration visa or work permit where required.
• Making improvements to Vitori Health's application and/or recruitment process including improving diversity in recruitment practices.
• Complying with applicable laws, regulations, legal processes, or enforceable governmental requests; and/or
• Proactively conducting research about your educational and professional background and skills and contacting you if we think you would be suitable for a role with us.

We will also use your information to protect the rights and property of Vitori Health, our users, applicants, candidates, employees, or the public as required or permitted by law.

If you are offered and accept employment with Vitori Health, the information collected during the application and recruitment process will become part of your employment record.

If EU data protection or UK data protection law applies to the processing of your information, our legal basis for processing your information

We collect and process your information where it is necessary in order to take steps, at your request, prior to our potentially entering into a contract of employment with you.

We may also seek your consent to process your personal information in specific circumstances or process it where necessary to comply with a legal obligation or for purposes connected to legal claims. If we use your information to improve our application or recruitment process, we do so on the basis that it is in our legitimate interests to ensure we recruit the best possible candidates.

Who may have access to your information?

• Your information may be shared with our affiliates, subsidiaries, or joint ventures in the US and in other jurisdictions, in relation to the purposes described above. If you have been referred for a job at Vitori Health by a current employee, with your consent, we may inform that employee about the progress of your application and let the employee know the outcome of the process. In some cases, if it is identified that you have attended the same university/school or shared the same previous employer during the same period as a current Vitori Health employee we may consult with that employee for feedback on you.
• Vitori Health may also use service providers acting on our behalf to perform some of the services described above including for the purposes of the verification / background checks. These service providers may be located outside the country in which you live or the country where the position you have applied for is located.
• Vitori Health may sometimes be required to disclose your information to external third parties such as to local authorities, courts, and regulatory bodies and/or law enforcement agencies for the purpose of complying with applicable laws and regulations, or in response to legal process.
• We will also share your personal information with other third parties if we have your consent (for example if you have given us permission to contact your referees), or to detect, prevent or otherwise address fraud, security, or technical issues, or to protect against harm to the rights, property, or safety of Vitori Health, our users, applicants, candidates, employees, or the public or as otherwise required by law.
• It is your responsibility to obtain consent from referrals before providing their personal information to Vitori Health.

Vitori Health takes appropriate steps to protect information about you that is collected, processed, and stored as part of the application and recruitment process.

Our retention of your information

If you apply for a job at Vitori Health and your application is unsuccessful (or withdraw from the process or decline our offer), we will retain your information for a period after your application. We retain this information for various reasons, including in case we face a legal challenge in respect of a recruitment decision, to consider you for other current or future jobs at Vitori Health and to help us better understand, analyze, and improve our recruitment processes.

If you do not want us to retain your information for consideration for other roles, or want us to update it, please contact jbrooker@vitorihealth.com. Please note, however, that we may retain some information if required by law or as necessary to protect ourselves from legal claims.

Your rights in respect of your information

In certain countries, you may have certain rights under data protection law. This may include the right to request access or to update or review your information, request that it be deleted or anonymized, or object to or restrict Vitori Health using it for certain purposes.

If you wish to exercise a right of access, please contact jbrooker@vitorihealth.com. We will respond to any requests in accordance with applicable law, and so there may be circumstances where we are not able to comply with your request.

Changes to this Policy

We may change this policy from time to time. We will post any changes to this policy on this page. Each version of this policy is identified at the top of the page by its effective date.

Last updated: June 8, 2021