Job applicant privacy notice

General

Wren US Holding Inc (“we”, “us”, or “our”) is committed to protecting the privacy and security of personal information of job applicants (“you” or “your”). This Privacy Statement explains how we collect, use, disclose, and protect your personal information during our recruitment process, in accordance with applicable data protection laws.

This Privacy Statement applies to all job applicants who apply for a position with us, whether through our website, through a job posting platform, or by any other means.

Information we collect

We may collect and process the following categories of personal information about you:

• Identification information that can be used to identify you, such as name, address, telephone number, email address, driver’s license number, date of birth, and Social Security number or similar government identifiers.
• Protected class information under state or federal laws, such as your immigration status, ability to work legally in the U.S., gender, race and ethnic background.
• Audio, electronic, video or image information such as video and audio recordings taken if you participate in video interviews, and video recording at Wren’s sites for security purposes.
• Professional or employment-related information such as employment history, work restrictions or accommodations, candidate identification number, licenses, and certifications, information needed to establish eligibility to work for us, including visa information and other information provided to HR throughout the employment
• Education information such as your degree and education
• Sensitive personal information. We may also collect personal information about you that may be classified as “sensitive personal information” under certain privacy This may include government issued ID, race and ethnic information for diversity, inclusion and compliance purposes, and log in credentials when creating a job account to apply for a position. We may also collect health related information to comply with the Americans with Disabilities Act (ADA).
• Other personal information you choose to share with us or make publicly available, or that we receive from a third party in connection with your work for us, such as personal or family employment affiliation with Wren or criminal record.

We do not knowingly collect personal information from children under the age of 16 without parental or guardian consent. If a child under the age of 16 has provided us with personally identifiable information, we ask that a parent or guardian contacts us so that the information can be deleted.

How we collect your information

We collect different types of information about you from a number of sources, including personal information you provide to us, personal information we automatically collect, information we obtain from other sources and information we derive or infer about you.

INFORMATION PROVIDED BY YOU

You may provide identification information, protected class information under state or federal laws, professional or employment related information, education information, sensitive personal information, inferences or preferences, and other personal information during the job application process.

INFORMATION WE COLLECT BY AUTOMATED MEANS

We collect audio, electronic and video or image information by automated means online and offline.

INFORMATION WE COLLECT BY FROM OTHER SOURCES

We may obtain certain information about you from other businesses, such as background checks or updated contact information. We may also obtain information from public sources, such as information you submit in a public forum. We may also obtain information about you from Wren’s affiliates. We may also obtain potential job applicant information from recruitment business partners.

INFORMATION WE GENERATE, DERIVE OR INFER

We may generate personal information about you, such as assigning a job applicant ID to you. We may also derive or infer information about you, such as information related to any assessment you take as part of the interview screening process upon hire.

Why we collect your information

We use the personal information we collect from you for a range of business purposes, including to:

• Identify you and maintain records related to your application;
• Communicate with you;
• Evaluate and respond to employment related requests, inquiries, and applications;
• Manage all aspects of your application process, including, but not limited to, recruitment and hiring processes;
• Conduct business analysis, research and development for purposes such as operational improvement;
• Comply with applicable laws; and
• Protect the security and integrity of data, systems, processes, and our business, and help prevent fraud.

How we share your information

WITHIN WREN

We share personal information relating to you within our family of companies for recruiting purposes and uses that are consistent with this Privacy Statement.

SERIVE PROVIDERS AND BUSINESS PARTNERS

We may disclose your personal information to companies or agents that provide services to us, such as information technology vendors, recruitment agency vendors and vendors that help us manage application processes. At your direction, we may provide your contact information and government ID to business partners that provide travel and accommodation services in the recruitment process. These providers may need access to information about you in order to perform their functions.

PUBLIC DISCLOSURE

With your consent, we may publicly disclose comments about your recruitment experience that you are willing to share to enhance our recruitment strategy.

LEGAL, ENFORCEMENT, SECURITY AND INVESTIGATION

We may disclose personal information about you:

• If we believe we are required to do so by law, regulation or legal process, such as a court order or subpoena;
• As we deem appropriate or necessary in response to requests by government agencies, such as law enforcement authorities or tax authorities;
• When we believe disclosure is appropriate or necessary to protect the rights, property or safety of Wren, our customers, or others, including to prevent physical, financial or other harm, injury or loss, or to collect debts you owe; or
• In connection with an investigation of suspected or actual unlawful

SALE OR TRANSFER OF BUSINESS OR ASSETS

We reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including, without limitation, in the event of a reorganization, dissolution, or liquidation).

How we protect your information

We maintain administrative, technical, and physical safeguards designed and intended to protect personal information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. Despite these safeguards, due to inherent uncertainty in the use of the internet and information systems and the potential for unlawful attacks by third parties, we cannot guarantee that the use of our systems, websites, or applications will be completely safe or secure.

How we retain your information

When we use the term “personal information” in this Privacy Statement, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual within the context of the individual’s role as a job applicant. It does not include aggregated or de-identified information that is maintained in a form that cannot reasonably be used to infer information about, or otherwise linked to, a particular individual. Where we maintain de-identified data, we will maintain and use the data in de-identified form and not attempt to re-identify the data except as required or permitted by law.

The Privacy Statement covers the privacy practices of Wren US Holding Inc and its U.S. operating subsidiaries and affiliates (“Wren”), expect as outlined below. It applies to personal information related to job applicants in an employment context.

In some cases, we may provide additional details about privacy practices specific to particular operation or location. Any such terms supplement or amend of this statement, but only with respect to matters governed by such separate disclosure.

This Privacy Statement does not apply to:

• Personal information collected when you interact with Wren as a
• Personal information collected if and when you are employed by
• Your interactions with third parties or their websites that are linked to or accessible from Wren’s websites or that are operated by unaffiliated parties, even though the website may contain references to The information collection, use and sharing practices are governed by the respective privacy notices.

Updates

The Privacy Statement may be updated periodically and without prior notice to you to reflect changes in our information practices or relevant laws.