Effective Date: November 1, 2019
Last Updated: November 1, 2019

This Applicant Privacy Policy (the “Policy”) describes the practices of LightBox Inc. and any LightBox Inc. company (“LightBox” or “us” or “we”) regarding the information that is solely collected through the LightBox Careers or any LightBox company Careers page (“Careers Site”) in connection with your application for a job or internship with us.

This Policy describes how we collect, use, disclose, and protect the personal information of our customers and website users (”you”), describes the types of information we may collect from you or that you may provide when you visit the Careers Site, and our practices for collecting, using, maintaining, protecting, and disclosing that information. Privacy laws in Canada and the U.S. generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person.

Please read this Policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, your choice is not to use the Careers Site. By accessing or using the Careers Site, you indicate that you understand, accept, and consent to the practices described in this Policy. This Policy may change from time to time. Your continued use of this website after we make changes indicates that you accept and consent to those changes, so please check the Policy periodically for updates.

1. CATEGORIES OF INFORMATION WE COLLECT THAT YOU PROVIDE

We may collect the following information from you in connection with your application through the Careers Site: Name, e-mail address, phone number(s), work authorization status, resume, profile information (e.g., work experience, education, skills, licences & certifications, and memberships), personal attributes (race, ethnicity, gender, veteran status, and disability), professional and other work-related licences, permits and certifications, references, and any other information you elect to provide to us (e.g., employment preferences, willingness to relocate, current salary, desired salary, awards, or professional memberships).

If you do not provide sufficient information, we may be unable to consider your employment application.

However, please avoid submitting the following information that may qualify as sensitive information under applicable law, except where such information is legally required: information on race, religion, ethnicity, nationality or national origin, age, gender identity, sex life or practices or sexual orientation, marital status, medical or health information (including disability status), genetic or biometric information, biometric templates, political or philosophical beliefs, political party or trade union membership, background check information, judicial data such as criminal records or information on other judicial or administrative proceedings, and veteran status.

If the personal information you provide contains details of the information referenced in the preceding paragraph or your job evaluations or educational records, you authorize us to handle such details for the purposes of your job application.

Any information you submit through the Careers Site must be true, complete and not misleading.

It is your responsibility to ensure that information you submit does not violate any third party’s rights. If you provide us with personal information of a reference or any other individual as part of your application, it is your responsibility to obtain consent from that individual prior to providing the information to us.

2. USE OF INFORMATION / LEGAL BASIS
We collect and process information about you for the following reasons:

Because you voluntarily provide this information;
Because this information is necessary to take steps at your request prior to entering into an employment or internship;
Because this information is of particular importance to us and we have a specific legitimate interest under law to process it;
To comply with a legal obligation; or
Where necessary to protect the vital interests of any person.

The information that you submit on the Careers Site will be used for our personnel recruitment, management, and planning purposes, as permitted by local law, including:

To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it, including to process your application;
To assess your capabilities and qualifications for a job;
To conduct reference checks;
To respond to your inquiries and communicate with you about your application, and to send you information regarding the Careers Site and changes to our terms and policies;
To comply with or monitor compliance with any applicable law or regulation;
To conduct background checks if we offer you a position; and
To preserve our other legitimate interests, for example, for our administrative purposes, aggregate management reporting, internal training, and as generally required to conduct our business.

The information about you will be added to our candidate database. If you do not wish us to do this, please contact careers@lightboxre.com.

If we hire you, personal information we collect in connection with your application may be incorporated into our human resourcessystem and may be used to manage the new-hire process; any such information may become part of your employee file and may be used for other employmentrelated purposes.
We may also use the information as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to protect our legal rights and operations or the rights, privacy, safety or property, and/or of us, you, or others; and (e) to allow us to pursue available remedies or limit the damages that we may sustain.

3. DISCLOSURE OF PERSONAL INFORMATION

We may share personal information with affiliates and/or partners that are involved in evaluating candidates for a given position. We will make the information available to personnel with a business need to know the information, including personnel in the recruiting, human resources, and
information technology departments, and in the department responsible for the position for which you are applying.

We may share personal information with third-party service providers who provide services such as hosting and operating the Careers Site, recruiting assistance, background check processing, and similar services.

We also may share personal information as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to protect our legal rights and operations or the rights, privacy, safety or property, and/or of us, you, or others; and (e) to allow us to pursue available remedies or limit the damages that we may sustain. We may transfer information in the event of any reorganization, merger, sale, joint-venture,
assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

Disclosing your personal information may include transferring personal information to servers located outside of the U.S., your province, territory or Canada.

4. DATA RETENTION

We keep your personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include (i) for as long as we have an ongoing relationship with you (such as an application process); as required by a legal obligation to which we are subject; or as advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations).

We may remove personal information for inactive accounts, subject to any applicable legal or regulatory obligations. Furthermore, we may delete personal information about you (including your CV/résumé) from our database at any time and without providing any reason. Therefore, please retain your own copy of the personal information provided to us.

5. INFORMATION COLLECTION: SOURCES, COOKIES AND TRACKING TECHNOLOGY
We collect your personal information from the following sources:

information that you provide to us through the Careers Site;
email, text, and other electronic messages between you and the Careers Site;
third party service providers who conduct background checks;
third party references, who you provide to us;
third party assessment providers, where you complete assessment.

We use different methods to collect your information, including through:

Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us by phone, email, or otherwise;
User contributions. You may also provide information for us to publish or display on public Careers Site areas or transmit to other Careers Site users or third parties;
Third parties or publicly available sources, for example, our business partners;

In addition, when you visit the Careers Site, we collect certain information by automated means. Cookies are small text files that websites send to your computer or other internet-connected device to uniquely identify your browser or to store information or settings in your browser. Cookies allow us to recognize you when you return. They also help us provide a customized experience and enable us to detect certain kinds of fraud. In many cases, you can manage cookie preferences and opt-out of having cookies and other data collection technologies used by adjusting the settings on your browser. All browsers are different, so visit the “help” section of your browser to learn about cookie preferences and other privacy settings that may be available.

We also use Flash Cookies (also known as Local Stored Objects) and similar technologies to personalize and enhance your online experience. The Adobe Flash Player is an application that allows rapid development of dynamic content, such as video clips and animation. We use Flash Cookies for security purposes and to help remember settings and preferences similar to browser cookies, but these are managed through a different interface than the one provided by your web browser. To manage Flash Cookies, please see Adobe’s website at http://kb2.adobe.com/cps/526/52697ee8.html or visit www.adobe.com. We do not use Flash Cookies or similar technologies for behavioural or interest-based advertising purposes.

Pixel tags and web beacons are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, the pixel tags and/or web beacons generate a notice of that action. These tools allow us to measure response to our communications and improve our web pages and promotions.

We collect different types of information. For example, we collect information from the device you use to access the Careers Site, your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. Our server logs also record the Internet Protocol (“IP”) address assigned to the device you use to connect to the Internet. An IP address is a unique number that devices use to identify and 6 communicate with each other on the internet. We may also collect information about the website you were visiting before you came to us and the website you visit after you leave the Careers Site.

In many cases, the information we collect is only used in a non-identifiable way, without reference to personal information. For example, we use information we collect about website users to optimize the Careers Site and to understand website traffic patterns. In some cases, we associate the information we collect with your personal information. This Policy applies to the information when we associate it with your personal information.

Although the Careers Site currently does not have a mechanism to recognize the various web browser Do Not Track signals, we do offer individuals choices to manage their preferences that are provided in the previous sections above. The Careers Site does not collect personal information about an individual’s online activities over time and across different websites when a consumer uses the Careers Site. To learn more about browser tracking signals and Do Not Track please visit http://www.allaboutdnt.org/. We use Google Analytics as a third party vendor. For information on how Google Analytics uses data, please visit “How Google uses data when you use our partners sites or apps”, located at http://bit.ly/2jXZ13Y. We also use Pendo as a third party vendor. For information on how Pendo uses data, please visit https://www.pendo.io/privacypolicy/.

6. ACCESS, CORRECTION, AND DELETION

If you register on the Careers Site, you may access, review, and change your personal information stored therein by logging into the Careers Site and updating your account information. However, if have authenticated your login via a mobile number or email address, such information cannot be updated in the same login session.

We encourage you to promptly update your personal information if it changes or is inaccurate.

Apart from information contained in your profile, where permitted by applicable law, you may request (i) access to personal information we collect, (ii) its modification or suppression, (iii) that we restrict its processing, (iv) that we cease using it (objection right); (v) that we delete your personal information; and/or (vi) that we transfer personal information to you or another organization in a structured, commonly used and machine-readable format (right to data portability). Please email us careers@lightboxre.com or contact us at 5201 California Ave Suite 200, Irvine, CA 92617 with any such requests. You may also contact us via our toll-free number (Canada only): 1-877.477.3684.

For your protection, we may only implement requests with respect to the information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. Please note that certain personal information may be exempt from such access, correction, or suppression rights pursuant to local data protection laws.

Note that if you request that we delete your information before we complete processing your application, we may not be able to complete processing your application.

7. SECURITY
We use reasonable organizational, technical and administrative measures to protect personal information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been 7 compromised), please immediately notify us of the problem by contacting us in accordance with the “Contact Us” section below.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Careers Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Careers Site like message boards, which any Careers Site visitor can view.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Careers Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Careers Site.

We hereby disclaim, as far as permitted by local laws, any liability for us and our affiliates and contractors for any personal information we collect in connection with your application that is lost, misused, illegally accessed, disclosed, altered or destroyed or not timely delivered to our Careers Site.

8. LINKS TO THIRD-PARTY WEBSITES
The Careers Site may contain links to other websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. This Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or service to which the Careers Site links. The inclusion of a link on the Careers Site does not imply endorsement of the linked site or service by us. We encourage you to read the legal notices posted on those sites, including their privacy policies.

9. LAW APPLICABLE TO JOB APPLICATION
This Careers Site is operated from United States. Accordingly, any personal information you submit to the Careers Site will collected in United States and will be subject to US Federal laws.

The Careers Site is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to local law or regulation.

10. ABOUT CHILDREN
Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at careers@lightboxre.com Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

11. WITHDRAWING YOUR CONSENT
Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at careers@lightboxre.com Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

12. CHANGES TO THE POLICY
We reserve the right to amend this Policy at any time in order to address future developments, the Careers Site, or changes in industry or legal trends. We will post the revised Policy on the Careers Site or announce the change on the home page of the Careers Site.

You can determine when the Policy was revised by referring to the “Last Updated” legend on the top of this Policy.

Any changes will become effective upon the posting of the revised Policy on the Careers Site. By continuing to use the Careers Site following such changes, you will be deemed to have agreed to such changes.

If you do not agree with the terms of this Policy, in whole or part, you can choose to not continue to use the Careers Site.

13. CONTACT US
If you have questions or requests, please feel free to contact us at careers@lightboxre.com or 5201 California Ave Suite 200, Irvine, CA 92617.