Privacy Notice For Job Applicant Residents Of Europe

Date: May 20, 2025

This European employee privacy notice (“Notice”) is being provided to all full time, part-time and temporary employees as well as independent contractors (“you”) of the below employers who reside in countries who are members of the European Economic Area as well as the United Kingdom:

Momentum Commerce, LLC

The employers listed above (referred to as “us,” “we” or “our”) collect and use personal information about you in an employment context as described in this Notice.

Please review this Notice carefully to understand our practices and treatment regarding your personal information. We respect the privacy rights of individuals – especially our employees – and are committed to handling personal information responsibly and in accordance with all applicable laws. This Notice is designed to help you understand the categories of information about you that we collect, the purposes for which those categories of information will be used and to whom your personal information is disclosed. If you have any questions, regarding our collection or processing of your information, or have any comments or questions about this Notice, please reach out through the mechanisms found in section titled Contact Us.

Our Notice includes:

1. Collection And Use Of Personal Information

2. Obtaining Consent

3. Third-Parties

4. Limitations

5. Retention Of Personal Information

6. Where Your Personal Information Is Being Stored Or Processed

7. Access And Rights To Your Personal information

8. How To Submit A Request

9. How We Process Data Rights Requests

10. Response Time

11. Costs

12. Accuracy

13. Safeguards

14. Changes To This Privacy Notice

15. Contact Us

  1. COLLECTION AND USE OF PERSONAL INFORMATION

During your employment with us, we will collect and/or process personal information about you. We will also disclose your personal information to third parties for the purposes of facilitating your employment with us, as described below. Whenever we permit another entity to access your personal information, we will implement appropriate measures to ensure the information is used in a manner consistent with this Notice and that the security and confidentiality of your information is maintained.


Categories CollectedThe personal information we collect may include:		Sources of CollectionWe may collect your personal information from:Purpose of CollectionThe purposes of collection include:Categories of Third Parties to Whom Personal Information is DisclosedWe may disclose your personal information:Legal Basis for Processing We process your personal information based upon:
Identifier Information:*you directlyour background check providerspublicly available databasesidentify you as an employee administer your employment with usto perform background checks on youto communicate with you in regards to your employmentto pay you or provide disbursementsto provide you with employee benefitsas required by lawto defend claims brought against us, to investigate violations of law or breaches of our own internal policiesto our subsidiaries and affiliates to our service providers**to individuals or entities you authorizeto our employee benefits administrators and providersfederal, state and local government authoritiesto your financial or banking institutionto public health related entitiesas required for legal purposesto entities that acquire all or part of our business in a corporate transactionsyour consent in providing this information for processing consistent with this Noticeour obligation to pay you wages or salaries per our employment agreement with youour obligation to provide you with employment benefits per our employment agreement with youour need to comply with a legal or regulatory obligationour legitimate interest in administering your employment
*For example, we may collect your full name, personal e-mail address, personal phone number, signature, sex, gender, date of birth/age, postal address, unique personal identifier (employee identification number), location and preferred language.
**For example, your personal information may be made available to our human resource platform provider, our employee data hosting vendor, our employee intranet platform provider, our employee background check provider, our employee benefits providers and administrators, our e-mail and SMS texting platform provider, with our expense and payroll support services or our auditors.  
Professional or Employment-Related Information:†you directlyyour supervisoryour related HR professionalour background check providersour headhunting or employee search providerspublicly available databasesadminister your employment with usto determine your eligibility for employment, raises or promotionsto pay you or provide disbursementsto provide you with employee benefitsdocument and conduct disciplinary actionsas required by lawto defend claims brought against us, to investigate violations of law or breaches of our own internal policiesto our subsidiaries and affiliates to our service providers††to individuals or entities you authorizeas required for legal purposesto entities that acquire all or part of our business in a corporate transactionsyour consent in providing this information for processing consistent with this Noticeour obligation to pay you wages or salaries per our employment agreement with youour obligation to provide you with employment benefits per our employment agreement with youour need to comply with a legal or regulatory obligationour legitimate interest in ensuring that all employees have adequate qualifications to perform job related dutiesour legitimate interest in administering your employment
†For example, we may collect your resume, date of employment, absence dates and details, vacation requests, requests for family leave, requests for disability leave, sickness records, employment history, pay or salary, standard hours, salary administration plan, bonus, termination details, business unit and location, disciplinary actions, corporate credit card usage, work authorization status, employee accomplishments, assessments, reviews, training data, company computer and device assets used, acknowledgements, disability, military or veteran status, involvement in security and/or privacy incidents, pension or retirement fund participation, EEOC data, ACA health compliance information, health insurance information, Medicare information, Medicare beneficiary identifiers, health insurance plan and premium information, health insurance claim number, life insurance plan and premium information, policy number and claim number.
††For example, your personal information may be made available to our human resource platform provider, our employee data hosting vendor, our employee intranet platform provider, our employee background check provider, our employee benefits providers and administrators, our e-mail and SMS texting platform provider, with our expense and payroll support services or our auditors.  
Background Check Information: ˤyou directlyour background check providerspublicly available databasesadminister your employment with usto determine your eligibility for employment, raises or promotionsdocument and conduct disciplinary actionsas required by lawto defend claims brought against us, to investigate violations of law or breaches of our own internal policiesto our subsidiaries and affiliates to our service providersˤˤas required for legal purposesto entities that acquire all or part of our business in a corporate transactionsyour consent for us to collect this information about you our legitimate interest in operating a safe and compliant work environmentour need to comply with a legal or regulatory obligationour legitimate interest in securing our information systems and confidential information as well as fraud detection and prevention
ˤ For example, we may collect your educational and employment background, history, arrest records, conviction records, credit information, disciplinary actions and news articles about you.ˤˤFor example, your personal information may be made available to our human resource platform provider, our employee data hosting vendor, our employee intranet platform provider, our employee background check providers or our auditors.
Financial Information:‡you directlyyour financial or banking institutionadminister your employment with usto pay you or provide disbursementsto provide you with employee benefitsas required by lawto defend claims brought against us, to investigate violations of law or breaches of our own internal policiesto our subsidiaries and affiliates to our service providers‡‡to individuals or entities you authorizeas required for legal purposesto entities that acquire all or part of our business in a corporate transactionsyour consent in providing this information for processing consistent with this Noticeour obligation to pay you wages or salaries per our employment agreement with youour legitimate interest in administering your employment
‡For example, we may collect your account name and number, pay check information, tax information and garnishment information.‡‡For example, your personal information may be made available to our human resource platform provider, our employee data hosting vendor, our employee intranet platform provider, our employee benefits providers and administrators, our e-mail platform provider, our financial and banking institutions, with our expense and payroll support services or our auditors.
Education Information:⁂you directlyour background check providersour headhunting or employee search providerspublicly available databasesadminister your employment with usto determine your eligibility for employment, raises or promotionsas required by lawto defend claims brought against us, to investigate violations of law or breaches of our own internal policiesto our subsidiaries and affiliates to our service providers⁂⁂to individuals or entities you authorizeas required for legal purposesto entities that acquire all or part of our business in a corporate transactionsyour consent in providing this information for processing consistent with this Noticeour legitimate interest in ensuring that all employees have adequate qualifications to perform job related dutiesour legitimate interest in administering your employment
⁂For example, we may collect your resume, curriculum vitae, transcripts, educational background, educational records and participation in ongoing education and training courses.⁂⁂For example, your personal information may be made available to our human resource platform provider, our employee data hosting vendor, our employee intranet platform provider, our employee background check provider or our auditors.
Audio and Visual Information:# you directlysecuring our electronic systems and physical areasemployee identificationpromotional and marketing effortsto our subsidiaries and affiliates to our service providers##to law enforcementas required for legal purposesto entities that acquire all or part of our business in a corporate transactionsyour consent in providing this information for processing consistent with this Noticeour legitimate interest in securing our information systems and confidential information as well as fraud detection and preventionour legitimate interest in administering your employment
#For example, we may collect information including voice recordings, facial photographs and/or video on our premises.##For example, your personal information may be made available to our managed security service provider, physical security provider or our auditors.
Internet or Other Electronic Network Activity Information:§you directlysecuring our electronic databases and systemsinvestigating security incidents and eventsto our subsidiaries and affiliates to our service providers§§to law enforcementas required for legal purposesto entities that acquire all or part of our business in a corporate transactionsyour consent in providing this information for processing consistent with this Noticeour legitimate interest in securing our information systems and confidential information as well as fraud detection and preventionour legitimate interest in administering your employment
§For example, we may collect information including how you access and navigate our internal systems, data accessed, pages visited and other electronic activity information.§§For example, your personal information may be made available to our managed security service provider or our auditors.
Inferences:⁑you directlyyour supervisoryour related HR professionaladminister your employment with usto determine your eligibility for employment, raises or promotionsas required by lawto defend claims brought against us, to investigate violations of law or breaches of our own internal policiesto our subsidiaries and affiliates to our service providers⁑⁑in corporate transactionsto individuals or entities you authorizeas required for legal purposesto entities that acquire all or part of our business in a corporate transactionsyour consent in providing this information for processing consistent with this Noticeour legitimate interest in ensuring that all employees have adequate qualifications to perform job related duties
⁑For example, we may collect your behavioral information, attitude information or abilities and/or preferences.⁑⁑For example, your personal information may be made available to our human resource platform provider, our employee data hosting vendor, our employee intranet platform provider or our employee background check provider.
Sensitive Personal Information (identity information)ǂyou directlyidentify you as an employeeadminister your employment with usto perform background checks on youto pay you or provide disbursementsto provide you with employee benefitsas required by lawto defend claims brought against us, to investigate violations of law or breaches of our own internal policiesto our subsidiaries and affiliates to our service providersǂǂto individuals or entities you authorizeto our employee benefits administrators and providersfederal, state and local government authoritiesto your financial or banking institutionto public health related entitiesas required for legal purposesto entities that acquire all or part of our business in a corporate transactionsyour consent in providing this information for processing consistent with this Noticeour need to comply with a legal or regulatory obligationour obligation to pay you wages or salaries per our employment agreement with youour obligation to provide you with employment benefits per our employment agreement with youour legitimate interest in administering your employment
ǂ For example, we may collect your Social Security number, driver’s license number, state identification card and number, nationality, place of birth and racial or ethnic origin.ǂǂ For example, your personal information may be made available to our human resource platform provider, our employee data hosting vendor, our employee intranet platform provider, our employee background check provider, our employee benefits providers and administrators, our e-mail platform provider, our expense and payroll support services or our auditors.  
Sensitive Personal Information (health information)+you directlyyour medical providersyour related HR professionaladminister your employment with usto provide you with employee benefitsto comply with laws and guidelines from applicable governmental authorities and public health entitiesto defend claims brought against us, to investigate violations of law or breaches of our own internal policiesto our subsidiaries and affiliates to our service providers++  your medical providersfederal, state and local government authoritiesto public health related entitiesas required for legal purposesto entities that acquire all or part of our business in a corporate transactionsyour consent in providing this information for processing consistent with this Noticeour need to comply with a legal or regulatory obligationour legitimate interest in ensuring a safe and healthy working environment
+For example, we may collect information relating to medical accommodation requests, the date, cause, location, and description of work related injuries and treatments, your exposure, or potential exposure, to or vaccination against, illnesses; including positive or negative test results, the date on which you tested positive or negative, the proof of vaccination against an illness, and the date(s) on which you came into the office or otherwise interacted with our property or personnel.++For example, your personal information may be made available to our human resource platform provider, our employee data hosting vendor, our employee intranet platform provider, our employee benefits providers and administrators or our auditors.
  1. OBTAINING CONSENT

Except when otherwise permitted by law or binding regulation, we will obtain the requisite consent from you prior to collecting and, in any case, prior to using or disclosing your personal information for any purpose other than as disclosed in this Notice. You may provide your consent to us orally, in writing, by electronic communication, through your actions or any other means reasonably capable of conveying your consent. However, your refusal to provide consent for collection (or your withdrawal of previously given consent) or to give your personal information when requested, can interfere with our ability to administer your employment. 

  1. THIRD PARTIES

We remain responsible for all personal information communicated to other entities for processing on our behalf. As such, we ensure that other entities that are engaged to provide products or services on our behalf and who are provided with personal information are required to observe the intent of this Notice by having comparable levels of security protection or, when required, by assuring us (through a confidentiality agreement) that they will not use or disclose the personal information for any purpose other than the purpose for which the personal information was communicated. You can find specific details about to whom we discloses your personal information in the section titled Collection And Use Of Personal Information.

  1. LIMITATIONS

We only collect the personal information necessary to fulfill the purposes identified to you prior to or at the time of collection, or any other reasonable and legitimate purposes or as required by law. We do not use or disclose your personal information except for the purposes for which it was collected, new purposes to which you have consented, or as required or otherwise permitted by applicable law. We do not as a condition of your employment, or as an administrative or management requirement, require consent to the collection, use or disclosure of personal information beyond what is reasonably required for such purposes, or to comply with our obligations under applicable law or regulation.

  1. RETENTION OF PERSONAL INFORMATION

Your personal information will be kept as long as needed to carry out the purposes described in this Notice or as otherwise required by applicable law. This means your personal information may be retained after the end of your employment or work relationship with us if needed for our legitimate business purposes, such as post-employment requirements (e.g., pension benefits or separation payments) or various legal matters (e.g., judicial and disciplinary actions, investigations or audit requirements), or if required by employment-related laws and regulations. To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means and the applicable legal requirements. 

  1. WHERE YOUR PERSONAL INFORMATION IS BEING STORED OR PROCESSED

Your personal information is being stored or processed in the European Union, United States, United Kingdom where our administrative and data centers are located. If you are a resident of the European Union, please note that the United Kingdom has been recognized by the European Commission as providing an adequate level of privacy protection to data subjects. Similarly, the European Union has been recognized by the UK as providing an adequate level of privacy protection to data subjects. However, United States’s adequacy determination is still being resolved by both the UK and EU. Therefore, the United States may not have privacy laws that are as strong or comprehensive as the privacy laws in your own country. 

Your personal information may also be stored in a multi-tenant cloud environment hosted by our service providers.

  1. ACCESS AND RIGHTS TO YOUR PERSONAL INFORMATION

Depending on your country of residence, you may have data rights as provided by various laws, regulations and codes, which can include the European Union’s General Data Protection Regulation (GDPR) and the UK Data Protection Act 2018. An interactive map showing the various privacy and protection laws around the world can be found here.

Subject to the exceptions provided by applicable law or regulation, and depending on your country of residence, you may have the following rights regarding your personal information: 

  • if we process your personal information based on your consent, you have the right to withdraw your consent at any time for further processing;
  • you have the right to request access to, rectification or deletion of your personal information;
  • you have the right to object to the processing of your personal information;
  • you have the right to request us to transfer your personal information to another controller; and
  • you have the right to request us to restrict the processing of your personal information.

Finally, you have the right to raise a complaint with us or the appropriate data protection authority of your country of residence if you feel that our processing of your personal information violates your individual rights, is not in line with this Notice or violates the privacy principals, laws or regulations of your country of residence. 

  • You can contact our privacy officer by using the information provided under Contact Us. We will promptly investigate any complaint and will respond within the timeframes describe in this Notice.
  • If you are a resident of the European Union, you can find your appropriate data protection authority by following this link.
  • If you are a resident of the United Kingdom, you can contact your data protection authority through the information provided in this link.
  1. HOW TO SUBMIT A REQUEST

You can submit your request to exercise a data right through:

  • Filling-out the Data Subject Request Form (linked here)
  • Calling us toll-free at 1-(844)-441-9869 PIN: 685805
  • E-mailing us directly at dataprivacy@momentumcommerce.com

Please be as specific as possible in your request so that we can meet the applicable handling timelines. Where we are the data controller with regards to the personal information that we process, you may exercise your rights as a data subject directly with us. Where we are collecting your personal information on behalf of another entity (i.e., we are not the data controller), we will provide you with the identity of the data controller to the extent we are required to do so by law. 

  1. HOW WE PROCESS DATA RIGHTS REQUESTS

Not all individuals about whom we possess information will have access to these rights and we may not be able to provide these rights to everyone due to legal and jurisdictional limitations. We may not be able to comply with your request for a number of reasons, including:

  • you do not live in a jurisdictions that grants you the specific right that you have requested;
  • the information that you’ve requested is not subject to the regulation that grants you the right to make a request in relation to your personal information;
  • we are prevented by law, regulation or rule from complying with your request;
  • we are not able to comply with your request without incurring disproportionate burden or expense; or
  • if complying with your request conflicts with our ability to administer your employment or to establish, defend or administer legal claims.

If any of the above reasons apply, we will let you know in our response to your request. Note that we may be required to gather additional information from you in order to process your request. We will only use this information in the context of evaluating and responding to your request. If you fail or refuse to provide the necessary information, we may not be able to process your request.

  1. RESPONSE TIME

We will make every reasonable effort to respond to your written request not later than 30 days after receipt of such request. We will advise you in writing if we cannot meet your request within this time limit. When applicable, you have the right to make a complaint to the appropriate supervisory authority, as detailed in this Notice, with respect to this time limit.

  1. COSTS

We expect to be able to respond to your request without charge as a general matter. However, where allowed by law, we reserve the right to collect a reasonable charge when you request the transcription, reproduction or transmission of such information. We will notify you, following your request of the appropriate amount that will be charged. You will then have the opportunity to withdraw your request.

  1. ACCURACY

We will use reasonable efforts to ensure that your personal information is kept as accurate, complete and up to date as possible. We do not routinely update your personal information in our possession, unless such a process is necessary. In order to help us maintain and ensure that your personal information is accurate and up to date, you must inform us, without delay, of any change in the data that you have provided to us.

You can at any time, challenge the accuracy or completeness of the personal information we have about you, subject to the exceptions provided by applicable law. If you demonstrate that the personal information we have on you is inaccurate or incomplete, we will amend the personal information as required. Where appropriate, we will transmit the amended data to third parties to whom we have communicated your personal information.

  1. SAFEGUARDS

We use security safeguards appropriate to the sensitivity of personal information to protect it from loss or theft, as well as unauthorized access, disclosure, copying, use or modification. These safeguards include physical measures, such as restricted access to offices and equipment, organizational measures, such as security clearances and publishing this policy to appropriate personnel with instructions to act in accordance with its principles (for example, limiting access on a “need to know” basis), and technological measures, such as the use of passwords and/or encryption. 

  1. CHANGES TO THIS PRIVACY NOTICE 

This Notice may be updated periodically to reflect any necessary changes in our privacy practices. You will be able to see when we last updated this Notice because we will include a revision date at the top. The latest version of this Notice is available on our human resource platform (Workday) as well as on the intranet (Here). We will inform you through your employee e-mail of any material changes and request that you read and accept a new version of the Notice when prompted. We will also circulate the current version of this Notice at least once annually.

  1. CONTACT US

To submit questions or to inquire about or submit a request relating to data rights, you can contact us by:

  • Calling us toll-free at 1-(844)-441-9869 PIN: 685805
  • E-mailing us directly at dataprivacy@momentumcommerce.com