Employee & Applicant Privacy Notice

Amplifon is an Italian based company that complies with various data protection regimes around the world. This Employee and Applicant Privacy Notice (“EA Privacy Notice”) applies throughout the Amplifon enterprise, including all employees, independent contractors, or those who are otherwise engaged with or being considered for engagement with Amplifon on an employment, contractual, or professional basis. This EA Privacy Notice outlines the personal information that Amplifon may collect during the application process and your employment relationship with Amplifon, how Amplifon uses and safeguards that information, and with whom we may share it.

This EA Privacy Notice is designed to set a uniform standard across the Amplifon enterprise with respect to its protection of employee personal information. Amplifon acknowledges that certain laws may impose additional requirements than those described in this EA Privacy Notice. This EA Privacy Notice is supplemental to the public-facing Privacy Notice, to the extent you may have interacted with the public-facing areas of the Amplifon website during your application process or otherwise. In addition, any local notices or privacy-related disclosures specific to your country or jurisdiction or residence shall supersede this EA Privacy Notice, the degree to which there is a conflict. 

Personal information (also commonly known as personally identifiable information (PII) or personal data) is information that can be used to identify you, or any other individual to whom the information may relate. Some information requested from you as part of your application process is required to verify your identity and assess your qualifications for the position in which you are applying for. In addition, certain information is required to establish the employment relationship while other information is collected throughout the duration of your employment. Amplifon collects information consistent with what is allowed by law in your country or jurisdiction of residence. Certain information, such as gender, race, and religion, may only be collected where legally permissible in your jurisdiction. 

The personal information that we collect in conjunction with your employment or application may include the following categories:

1. Personal Identifiers: name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
2. Personal Information: date of birth, marital status, birthplace, nationality, residency, citizenship, work permit status, military status, nationality, preferred language.
3. Characteristics of Protected Classifications: race, sex, gender, ethnicity, disability information (if provided voluntarily), or military and veteran status.
4. Internet or Other Electronic Network Information: network activity, browsing history, search history, information regarding your interaction with a website, application, or advertisement.
5. Health Information: medical information or maternity leave.
6. Professional or Employment Related Information: Amplifon employee number, dates of employment, payroll information, pension plans, benefits information, beneficiaries, emergency contacts, workers compensation, worker status, absence records, PTO, evaluations, retirement, union affiliation, or career development.
7. Account Information: login credentials for applicant or employee portals.
8. Application Information: education level, field and institution, competency assessments, professional licenses and certifications, training courses, previous employers or previous positions, interview information, CV or resume, cover letters, references, reference letters, background and credit checks, transcripts, pre-hire interactions, letters of reference, letters of offer and acceptance dates of hire, start and end dates, resignation date and reasons.
9. Communication Information: voicemails, e-mails, correspondence, documents, and other work product and communications created, stored or transmitted using our networks, applications, devices, computers, or communications equipment; survey information);
10. Image and Likeness Information (where permitted by law and/or after subsequent notice where required by law): identification photo, CCTV footage, other images or photographs, and key card use times and locations.

Some personal information is considered Sensitive or a Special Category of personal information under certain data privacy regulations. Where required by law, your explicit consent to collection, processing, or transferring of such Sensitive Personal Data will be obtained. Appropriate security and protection measures will be provided that will be congruent with the nature and risks associated with the data and processing activities.

What are the sources of personal information collected by Amplifon?

When providing personal information to Amplifon as described in this EA Privacy Notice, that personal information is typically collected directly from you, and you will know the precise personal information being collected by us.

If you are a job applicant using a third-party job search engine, a social media platform (e.g. LinkedIn), or a recruiter that is not affiliated with Amplifon, Amplifon may receive some of your personal information indirectly through those respective sources. Please be advised this EA Privacy Notice does not apply to external third parties and Amplifon has no control over the privacy practices of external third parties. It is recommended that you review the privacy practices of the particular website, entity, or individual by contacting them directly or reviewing information available on their websites.

In certain limited circumstances, third-party service providers may collect information on behalf of Amplifon (e.g. for the purposes of background checks, screening, etc.), though such collection will always be within the context of your employment or application, and you will always be informed that such information collection is being conducted by a third party at the time of collection.

Finally, certain information may be collected from customers, associates, or others that you may engaged with in the course of your employment with Amplifon (e.g. surveys for performance review and similar purposes).

Subject to the terms of this EA Privacy Notice, Amplifon uses the above-described categories of personal information in several ways. Unless otherwise stated specifically, the above information may be used for any of the purposes listed below. These purposes are not all inclusive, and you may receive subsequent notice about additional purposes for other, specific types of processing. Amplifon may use your personal information to:

• Determine your eligibility for employment, including verification of references and qualifications;
• Administer pay and benefits to you;
• Assess qualifications for a particular job or task;
• Enable communication and networking among employees;
• Comply with applicable labor or employment statutes;
• Contact you regarding other recruitment opportunities;
• Provide general information about Amplifon;
• Respond to your queries and requests;
• Process work-related claims (e.g. worker compensation and insurance claims);
• Provide training or other developmental requirements;
• Conduct performance reviews and disciplinary action;
• Establish contact in the event of an emergency;
• Comply with legal obligations, including health and safety requirements, and requests for information from government agencies, and security investigations, or to assert or defend a legal claim;
• Compile employee directories;
• Ensure the security of company-held information;
• Manage staffing resources, financial planning, corporate compliance, internal audits, and other administration;
• Administer our applications, software, and electronic systems;
• Improve employee satisfaction and performance;
• Prevent potentially fraudulent, prohibited, or illegal activities;
• Generally manage all aspects of the employment relationship, including but not limited to establishing, maintaining, and terminating employment relationships, general operations, and administrative, financial, and human resources related purposes;
• For other such purposes as are necessary and reasonably required by Amplifon for which you will receive subsequent notice if it is a material deviation from the above purposes.

In applicable countries, the information that you provide in the equal opportunities section of a job application will be used for the sole purpose of monitoring equal opportunities within the Amplifon enterprise. Amplifon does not use this information for marketing purposes.

Amplifon may collect similar or related information or use personal information for a similar or related purpose consistent with laws and regulations of a particular jurisdiction. Where required, subsequent notice will be provided prior to further collection. Depending on your jurisdiction, you may have data subject rights such as deletion, correction, or limitation of use. Such data subject rights, and the jurisdictions where they are applicable, are described below. 

How do we share your Personal Information with third parties?

We may provide any of the described categories of personal information to Amplifon employees, consultants, affiliates or other businesses or persons for the purpose of processing such information on our behalf in order to establish, manage, or terminate the employment relationship with you. In such circumstances, we require that these parties agree to protect the confidentiality of such information consistent with the terms of this EA Privacy Notice, as well as the public-facing Privacy Notice and any internal privacy compliance standards, and the laws and regulations of the jurisdiction where you live.

When applying for a job with Amplifon, access to your personal information will be limited to those persons necessary for consideration of your job application. Processing of your application may require your information be transferred to Amplifon individuals or groups outside your country or jurisdiction of residence. If transferred outside your country of residence, such transfer will be subject to your jurisdiction’s data privacy law and this EA Privacy Notice

Parties receiving your information may include:

• Our affiliates and related companies;
• Business partners, contractors, or others which are not considered affiliated companies.
• Third-party vendors or service providers providing crucial services and necessary to support your employment or application and or provide you certain employment-related services (including for purposes addressed outlined in the preceding section);
• Third parties who may provide professional advice (for example, lawyers, bankers, accountants);
• Government agencies or other parties in response to legal process or other requests, where permitted by law;
• With other persons or third parties with whom you have requested that we share information.

Except as described above, we will not share your personal information with other, third-party companies for their commercial or marketing use without your consent or except as part of a specific program or feature for which you have the ability to opt-in or opt-out.

In addition, we may release personal information: (i) to the extent we have a good-faith belief that such action is necessary to comply with any applicable law; (ii) to enforce our rights and/or make or defend claims related to your employment with Amplifon, protect ourselves against any liability, defend ourselves against any claims, protect the rights, property and personal safety of any user, or protect the public welfare; (iii) when disclosure is required to protect the security of other persons, consistent with applicable laws (iv) to respond to a court order, subpoena, search warrant, or other legal process, to the extent permitted and as restricted by law; (v) in the event that we go through a business transition, such as a merger, divestiture, acquisition, liquidation or sale of all or a portion of our assets; or (vi) is for an additional purpose that is directly related to the original purpose for which the personal information was collected. 

Amplifon will retain your personal information only for as long as is necessary for the purposes set out in this EA Privacy Notice, which is typically the length of your employment, plus at least an additional year following the termination of the employment relationship. If you are a job applicant whose application is not accepted, you may consent to Amplifon’s retention of your data so that Amplifon can keep you informed of future employment opportunities, and you may inquire at any time regarding the length of retention for your personal information.

In certain jurisdictions, the length of time that your personal information will be retained may vary depending on local law. You may inquire with your manager or contact Amplifon as described herein for the retention period that is specific to your jurisdiction. Further, we may retain and use personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies. 

The California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CCPA”), requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, sale, sharing, and retention of personal information and of the rights of California residents regarding their personal information. This section of the Privacy Policy is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this section does not apply to you and you should not rely on it.

The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information or lawfully obtained, truthful information that is a matter of public concern.

Disclosure Notice at Collection of Personal Information

We currently collect and, in the 12 months prior to the Last Updated Date of this Privacy Policy, have collected the categories of personal information listed earlier in this Notice. We collect personal information directly from California residents and from the sources listed above. We do not collect all categories of personal information from each source.

In addition to the purposes stated above in the section “HOW DOES AMPLIFON USE PERSONAL INFORMATION?” we currently collect and have collected the above categories of personal information for the following business or commercial purposes:

• Helping to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for these purposes.
• Debugging to identify and repair errors that impair existing intended functionality.
• Performing services, including maintaining or servicing accounts, verifying information, providing analytic services, providing storage, or providing similar services.
• Undertaking internal research for technological development and demonstration.
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

Sale, Sharing, and Disclosure of Personal Information

The following table identifies the categories of personal information that we disclosed for a business purpose in the 12 months preceding the Last Updated Date of this EA Privacy Notice and, for each category, categories of recipients to whom we disclosed personal information.

We do not knowingly sell or share the personal information of individuals under 16 years of age. We do not collect or process personal information for the purpose of inferring characteristics.

Your Rights

As a California resident, you have the following rights with respect to your personal information:

• The right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which we collected personal information, the business or commercial purpose collecting, selling, or sharing personal information (if applicable), the categories of third parties to whom we disclose personal information (if applicable), and the specific pieces of personal information we collected about you;
• The right to delete personal information that we collected from you, subject to certain exceptions;
• The right to correct inaccurate personal information that we maintain about you;
• If we sell or share personal information, the right to opt-out of the sale or sharing;
• If we use or disclose sensitive personal information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use or disclosure; and
• The right not to receive discriminatory treatment by us for the exercise of privacy rights conferred by the CCPA.
  
  

How to Submit a Request to Know, Delete, and/or Correct

To exercise your Right to Know, Data Portability, and Right to Delete, you must provide us with sufficient information to allow us to verify your identity and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. Once we receive the information you provide to us, we will review it and determine if more information is necessary to verify your identity as required by law, and we may request additional information in order to do so. We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the personal information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable. To exercise your California privacy rights described above, please submit a verifiable request to us by: completing our webform or emailing us at compliancedept@amplifon.com.

Only you, or a person authorized by you to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for Right to Know or Data Portability twice within a 12-month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We may deny your request if we are unable to verify your identity or have reason to believe that the request is fraudulent.

If we determine that your request is subject to an exemption or exception, we will notify you of our determination. If we determine that your request is not subject to an exemption or exception, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. Our verification process may differ depending on whether you maintain a password-protected account with us.

If you maintain a password-protected account, we may verify your identity through existing authentication practices available through your account. Prior to disclosing or deleting the personal information, we will ask you to re-authenticate yourself with respect to that account.

If you do not maintain a password-protected account, or if you are an account-holder but we suspect fraudulent or malicious activity with your account, We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the personal information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable. To do so, we will ask you to verify data points based on information we have in our records concerning you.

Right to Limit Use and Disclosure of Sensitive Personal Information

California residents have the right to limit our use or disclosure of their sensitive personal information for purposes other than those allowed by the CCPA and its regulations. You may submit a request to limit our use or disclosure of your sensitive personal information through our interactive webform available by clicking here.

If you are located in the EU, Canada, or a jurisdiction with a similar law, the GDPR or its local equivalent may grant you certain rights under the law. In particular, the right to access, correct, and delete the personal information we hold about you. Amplifon will retain your personal information for the length of time you engage with our services as described in the retention section of this EA Privacy Notice, until you request deletion of such personal information. Amplifon is considered the Data Controller (or equivalent distinction) with regard to your personal information. In certain circumstances, you have the following data protection rights:

• The right to access, update, or delete the personal information we have on you.
• The right of rectification. You have the right to have your personal information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your personal information.
• The right of restriction. You have the right to request that we restrict the processing of your personal information.
• The right to data portability. You have the right to be provided with a copy of the personal information we have on you in a structured, machine-readable and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your personal information.

In order make a request regarding your personal information, please contact your manager, HR, or compliancedept@amplifon.com.

If you have a comment, question, or complaint about how we are handling your personal information, we hope that you contact us as described herein to allow us to resolve the matter. In addition, if you are located in the EEA, you may submit a complaint regarding the processing of your personal information to a regulatory authority.

Legal Basis for Processing

If you are located in the EEA or a jurisdiction that requires a similar legal basis for processing, our legal basis for collecting and using the personal information described in this Notice depends on the personal information we collect and the specific context in which we collect it. We may process personal information because:

• It is necessary for the performance of a contract between you and Amplifon;
• You have given us consent to do so (in applicable jurisdictions);
• The processing is in our legitimate interest as the Controller, when that legitimate interest is not overridden by your rights;
• Amplifon must comply with the law.

Where certain sensitive personal information is processed based on your explicit consent, you may have the right to withdraw such consent at any time. To do so, please contact us as described in this EA Privacy Notice. If there is a different legal basis that would permit us to continue processing your personal information after withdrawing consent, we will notify you of that legal basis at the time of your request.

We employ industry-standard security measures designed to protect the security of all information submitted through the Service. However, the security of information transmitted through the internet or via a mobile device can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data.

Users of the Service are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password protected or secure areas of the Service. In order to protect you and your information, we may suspend your use of any of the Service, without notice, pending an investigation, if any breach of security is suspected.

Amplifon reserves the right to modify this EA Privacy Notice from time to time in order to ensure that it accurately reflects the regulatory environment and our data collection principles. We will provide you with a new version of this notice when material updates are made.

If you have any questions or comments about this EA Privacy Notice, please contact us at:

Amplifon Americas

Attn: Compliance Officer

150 South 5^th Street, Suite 2300

Minneapolis, MN 55402

Email: compliancedept@amplifon.com

Telephone: 800-234-9314 or 763-268-4103