Applicant Privacy Policy

Part I: How to Contact Us

Part II: What Data We Collect and How We Use It

Part III: How We Use Your Personal Data

Part IV: How and With Whom We Share Your Data

Part V: Security and Retention

Part VI: Your Privacy Rights and Choices

Part VII: GDPR and Global Privacy Laws

Part VIII: Definitions

We have appointed Data Protection Officers (“DPO”) to oversee compliance with this Applicant Privacy Notice in the EU, UK, and other regions.

If you have any questions about this privacy notice or how we handle your personal data, please email your DPO at privacy@cradlepoint.com.

We value your opinion. If you have questions or comments about this Applicant Privacy Notice or our privacy practices, please also feel free to contact us at:

Phone: +1 855 813 3385

Address: Cradlepoint, Inc., 1100 West Idaho Street, Suite 900, Boise, ID  83702.

Attn: Privacy Department

Email at: privacy@cradlepoint.com

When you apply for employment with us, we collect your Personal Data. We collect data via our application portal, our websites and the recruitment agencies we engage to help us connect with applicants and interview them.  We gather, store and use the following Personal Data:

Information we collect directly from you

When you create an account in our careers portal: We collect your email address and password.

When you apply for a position: We ask for your contact data, including your first and last name, phone numbers and mailing address. We collect Personal Data to assess your educational and employment background, including your resume and/or curriculum vita (CV), your cover letter, job or educational transcripts, employment references, skills, websites and work samples (if applicable to the role).  We may also collect information how you heard about us and previous work experience or relationships with us or our Affiliates and the social media accounts used to register.

Sensitive Data including special categories of personal data in our application form:  Our application contains some voluntary questions for roles based in the United States that are intended to help us meet US government Equal Employment Opportunity requirements and to learn about the various identities and backgrounds that make up the candidates applying to Cradlepoint, for example, gender identification, veteran status or race/ethnic origin. Providing us with this information will help us take actions that support under-represented groups and make sure our hiring process is inclusive and fair for everyone. These questions are voluntary and you are under no obligation to answer them.  Please leave the answers blank if you have any concerns.  Not answering these questions will in no way impact your application to work with us or the hiring process.

During the interview process: During interviews and phone-screenings, we may collect your name, date of birth, age, gender, home address, personal email address, education, job qualifications and work experience details, and any other information you share with us.  We may also create interview notes, ask you about your compensation requirements, and gather other information to get to know more about you and your career interests.

After the interview and before we make you an offer:  We may also collect additional information including, government-issued identification numbers (such as a social security number) or your passport information, evidence of your right to work in the country where the role you applied to is based and/or immigration status.

All information is provided on a voluntary basis, and you determine the extent of information you provide to Cradlepoint. However, some information may be necessary to complete an evaluation of your application and if it is not provided, our ability to consider you as a candidate may be limited.

We do not request Sensitive Personal Data (as defined by local privacy laws) in connection with recruiting unless permitted or required by local law (for example, for equal opportunity monitoring or internal policies related to diversity and anti-discrimination). Where required by applicable data protection or privacy law, we will obtain your consent to our use of your Sensitive Personal Data.

Automatically collected: We may automatically collect certain technical data from you about your visit to our sites using “cookies” and other similar tracking technologies. We try to understand how you interact with our recruitment tool and services including URL, IP address, cookies, and how you interact with and browse away from the page.

For further information about our use of cookies, please consult the Cradlepoint Cookie Notice.

Information from third party sources

We also collect information about you from other people and organizations, if permitted by applicable law, including data from your references, previous employers, recruitment agencies, background and/or criminal or identity verification service providers and regulatory authorities that issue ID documents and provide criminal records.

You may also choose to provide us with access to certain Personal Data stored by third parties such as social media sites (for example, LinkedIn, Indeed, Google, Apple, Facebook or Microsoft). By authorizing Cradlepoint to have access to this information, you agree that Cradlepoint may collect, store and use this information in accordance with this Applicant Notice.

Information from publicly available sources

We may collect information such as details of your employment and education history from business related public sources available online (e.g., Facebook, LinkedIn).

We use your Personal Data to:

• Search for suitable candidates either via our internal recruitment resources or by using third parties;
• Assess your skills, qualifications, and suitability for the position you have applied for;
• Communicate with you about the recruitment process;
• Perform pre-employment background and reference checks in accordance with applicable law;
• Keep records related to our hiring processes;
• Analyze and monitor the diversity of applicants and candidates;
• Manage the performance of our recruitment activities;
• Protect our legal rights, including in the course of legal proceedings, obtaining legal advice, and establishing or defending legal claims;
• Send you job alerts when you have subscribed to this feature;
• Retain your data for future positions that you may be interested in;
• To facilitate our global operations, we may transfer and access such information from around the world, including from other countries in which Cradlepoint or its parent company or Affiliates have operations for the purposes described in this Applicant Policy; and
• Comply with legal or regulatory requirements.

Profiling and automated decision making

We do not use profiling or automated decision-making processes as part of our recruitment. If you feel that such processes may have impacted you or have any concerns, please contact us at privacy@cradlepoint.com.

We take care to allow your Personal Data to be accessed only by those who really need access in order to perform their tasks and duties, and to third parties who have a legitimate purpose for accessing it.  We may share Personal Data about you in the following circumstances:

Vendors, consultants and other third parties or service providers: We may share your Personal Data internally and with third parties including but not limited to service providers, agents, recruiters, consultants, attorneys, and background checking services.   We only share information that is necessary for recruiting and employment purposes.

Where personal data is disclosed to third parties, appropriate safeguards are implemented to ensure that the data is processed legitimately and protected appropriately. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

Cradlepoint does not sell any Personal Data provided by an applicant to us as part of the recruitment or hiring process to any third parties.

Cradlepoint Affiliates: We may share your information with our parent companies, subsidiaries and/or Affiliates. Our parent company is Ericsson.  For more information about Ericsson’s privacy policy, please click here. This information will only be shared as necessary in connection with your recruitment and employment as described in this Applicant Privacy Notice. We may also obtain information about you from our affiliated companies.

Third-Party Service Providers: Cradlepoint may also use service providers acting on Cradlepoint’s behalf to perform some of the services described above, including but not limited to, for the purposes of verification or background check, where legally permitted. For successful applicants, we may contract with a third-party service provider in select global markets where we do not have an established Cradlepoint entity to perform employment services. Cradlepoint will specify in the job description if this is the case.

Compliance with laws or any competent law enforcement body, regulatory body, government agency, court or third party: We may disclose information where we believe disclosure is necessary or required (i) by law or regulation, in order to comply with legal process or government requests (including in response to public authorities to meet equal opportunity laws, national security or law enforcement requirements); or (ii) to exercise, establish or defend our legal rights.

Business transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, acquisition, dissolution, corporate reorganization or similar event. We will inform any buyer that your information shall only be used in accordance with this Applicant Privacy Notice.

With your consent: We may disclose your Personal Data for any purpose with your consent.

See the Cradlepoint Global Privacy Notice, Part V: Security and Retention.

See the Cradlepoint Global Privacy Notice, Part VI: Your Privacy Rights and Choices.

Cradlepoint is the Data Controller and responsible for the collection, processing and use of your Personal Data as part of the recruitment and hiring process.

Legal Basis for processing Personal Data

If you are an applicant from the European Economic Area, United Kingdom or other country that requires a similar legal basis for collecting and using Personal Data, our legal basis for collecting and using the Personal Data described above is:

• Contract: It is necessary for us to process your Personal Data to decide whether to enter into a contract of employment with you.
• Your consent: We may also seek your consent to process your Personal Data in specific circumstances, or process it where necessary to comply with a legal obligation or for purposes connected to legal claims.
  Where we have asked for your consent, you may withdraw that consent at any time by notifying privacy@cradlepoint.com. If you withdraw your consent, we will no longer process your Personal Data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so by law. Withdrawal of consent will not affect the legality of any processing which had previously taken place under that consent.

• Legitimate interest: because we or a third party have a legitimate interest to:
  1. ensure the effective management of the recruitment process;
  2. ensure we hire a suitable and eligible individual for a role;
  3. address disputes and accidents and take legal or other professional advice.

  If we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time, or upon request, what those legitimate interests are.  We also review that that our legitimate interest does not override your data protection interests or fundamental rights and freedoms.

• Legal obligations: We need to process your information in order to comply with a legal or regulatory obligation. If we ask you to provide Personal Data to comply with a legal requirement, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
• Vital Interest: We may disclose information where we believe it is necessary in order to protect the vital interests of any person, such as a person experiencing a medical emergency while visiting our office.

Special Categories of Personal Data: We will use special categories of Personal Data collected about you because: (1) you have provided your explicit written consent; (2) we need to do so to carry out our legal obligations; (3) it is necessary for the establishment, exercise or defense or legal claims or in relation to court cases; (4) there is a substantial public interest; or (5) it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent.

If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us at privacy@cradlepoint.com.

International Transfers

Cradlepoint is a U.S. based, global company owned by Ericsson, a Swedish-based company. We primarily store job applicant information in the United States. To facilitate our global operations, we may transfer and access such information from around the world, including from other countries in which Cradlepoint or its parent company or Affiliates have operations for the purposes described in this Applicant Policy.

Your Personal Data, including information collected in the European Economic Area (“EEA”), the United Kingdom or Switzerland, may be transferred, stored and processed by us and our services providers, partners and Affiliates in the United States and potentially other countries whose data protection laws may be different to the laws of your country.ome of these countries are not deemed ‘adequate’ by the European Commission and/or the UK Government. We will protect your Personal Data in accordance with this Applicant Notice wherever it is processed and will take appropriate contractual or other steps to protect the relevant Personal Data in accordance with applicable laws. We enter into appropriate data transfer agreements based on so-called Standard Contractual Clauses approved from time-to-time under GDPR Art. 46 by the European Commission, the UK Information Commissioner’s Office or UK Government (as and where applicable); or rely on other appropriate means permitted by GDPR Chapter V, which establish that such recipients will provide an adequate level of data protection and that appropriate technical and organizational security measures are in place to protect personal data against accidental or unlawful destruction, loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing, including the:

Data Privacy Framework

Cradlepoint complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Cradlepoint has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Cradlepoint has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Transfers to third parties/controllers/processors

Cradlepoint has set out above where we may transfer personal data to third-party controllers and processors. In those cases, we ensure that there is a contract in place that sets out that personal data may only be processed for limited and specified purposes and that the recipient will provide the same level of protection as the DPF Principles and that they will notify Cradlepoint if it can no longer meet that obligation. Cradlepoint remains liable under the DPF Principles if the receiving organization (processor/agent) processes in a manner which is inconsistent with the DPF Principles unless that organization can prove that it is not responsible for the event giving rise to the damage. We may need to disclose your personal data in response to lawful requests by public authorities including to meet national security or law enforcement requirements.

Independent Dispute Resolution

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Cradlepoint commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Gibraltar Regulatory Authority (GRA) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF. Individuals have the possibility, under certain conditions, to invoke binding arbitration for complaints regarding DPF compliance not resolved by any of the other DPF mechanisms. See Annex I of the DPF Principles for additional information: https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2.We are also subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) who have jurisdiction over Cradlepoint’s compliance with the EU-US DPF, the UK extension to the EU-US DPF and the Swiss-US Data Privacy Framework (Swiss US DPF).

If you have any questions about or need further information concerning the appropriate safeguards Cradlepoint has in place to protect your Personal Data , please contact us.

See the Cradlepoint Global Privacy Notice, Part VIII: Definitions.

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