Passport Global Candidate Privacy Notice

Last Modified: April 20, 2026

This Passport Global Candidate Privacy Notice (“Notice”) describes how Passport Global, Inc. and its subsidiaries and affiliates (collectively, “Passport,” “we,” “our,” or “us”) collect and otherwise process Personal Data of candidates applying for employment with us (“Candidates”), including from passportglobal.com/careers (the “Site”).

This Notice supplements our Privacy Notice. In the event of a conflict between any other policy, statement, or notice and this Notice, this Notice will prevail as to Candidates.

This Notice does not cover Passport employees. If you are an existing Passport employee, please see the Employee Handbook for additional disclosures.

Personal Data We Collect

“Personal Data” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Data includes “Sensitive Data.” Personal Data also includes the term “personal information” as used in data privacy laws, including the California Consumer Privacy Act, as amended from time to time (“CCPA”). Personal Data does not include information that is publicly available, de-identified, or aggregated.

We and our vendors collect Personal Data about Candidates through various means, including when you directly provide it to us; automatically through your use of our Site; from vendors that help us to run our business; and from other parties, including recruiters and your references. The Personal Data we collect varies based on how you interact with us, and may not include all the examples listed.

• Identifiers, including real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, driver’s license number, passport number, or other similar identifiers.
• Personal Records, including name, signature, social security number, address, telephone number, passport number, driver’s license or state identification card number, education, employment, and employment history.
• Characteristics of Protected Classifications under state or federal law, including age and date of birth, marital status, race, ancestry, ethnic origin, sex, gender, sexual orientation, gender identity, religion or creed, military or veteran status, medical condition, genetic information, and disability.
• Internet or Other Electronic Network Activity Information, including browsing history, search history, and information regarding your interactions with our Site, applications, logs, device data and registration, social media account information, or advertisements.
• Geolocation Data, including location data inferred from your device IP address.
• Audio, Electronic, Visual, or Similar Information, including video or audio recordings of you for the recruitment process, such as interviews.
• Professional or employment-related information, including:
  • Skills, qualifications, work experience, references, recommendations, and other information included in a resume, CV, application form, or cover letter;
  • Answers to behavioral or other screening questions in an application or interview;
  • Information contained in any personal webpages or documents you choose to share with us;
  • Information relating to professional licenses, training, disciplinary actions, and membership in professional organizations; and
  • Information relating to membership in civic organizations.
• Non-Public Education Information, including school(s) attended, grades, transcripts, and other information relating to your secondary and post-secondary education.
• Inferences used to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

How We Use Personal Data

We and our vendors may use the Personal Data we collect during the recruiting process to:

• Manage your application and recruiting process, including opening and maintaining application records; evaluating your application, eligibility, and suitability for current or future roles; assessing and improving recruiting and interview practices; and communicating with you about your application and the hiring process.
• Verify identity and eligibility, including authenticating your identity; verifying your eligibility to work; checking sanctions lists where applicable; and conducting role- and location-specific screening.
• Accommodate Candidate needs, including accommodating disabilities or health conditions during the application process.
• Facilitate the onboarding of new employees, including conducting background checks, processing employment documentation, establishing credentials, and otherwise formalizing the employment relationship.
• Provide support and respond to inquiries, including responding to emails, requests, questions, or other communications.
• Conduct advertising and analytics, including monitoring and analyzing Site usage and trends and showing you relevant advertisements while browsing the internet or using social media.
• Protect security and prevent wrongdoing, including managing and protecting the security of our Site, premises, and systems; preventing misuse of our Site; detecting, preventing, investigating, and responding to fraud, security incidents, or illegal or policy‑violating activity.
• Comply with legal and regulatory obligations, including complying with applicable laws, regulations, legal processes, lawful government requests, industry standards, and company policies; and investigating, preparing for, or defending legal claims.
• Support corporate transactions, including evaluating or carrying out mergers, divestitures, restructurings, reorganizations, dissolutions, or asset sales in which Personal Data may be transferred.
• For any other purpose with your consent.

How We Disclose Personal Data

We may disclose your Personal Data for purposes consistent with this Notice, our written communications at the point of collection, or applicable laws. Generally, we disclose Personal Data as described below:

• Within our group of companies, including with our affiliates and subsidiaries.
• With our agents, service providers, consultants, and other vendors in order for them to provide their services to us, including to process your application, provide recruitment and hiring services, improve our Site, communicate with you, and otherwise operate our business.
• With third parties to confirm the accuracy of your application, check your references, and otherwise carry out the recruitment process.
• With our advertising partners for the purposes of ad targeting, remarketing, and customized advertising content.
• With our insurers and professional advisers for the purposes of managing risks, exercising or defending against legal claims, and otherwise obtaining professional advice.
• In connection with, or during negotiations of, any proposed or actual merger, purchase, sale, or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
• As necessary to: (1) comply with applicable law or other legal processes, (2) respond to lawful requests by public and government authorities, (3) enforce our terms and conditions, (4) protect our operations and the rights, privacy, safety, and/or property of us, you, and others, and (5) seek remedies or mitigate potential damages.
• For any other purpose disclosed to you and with your consent.

Data Security

We use reasonable safeguards to protect Personal Data from loss, theft, misuse, and unauthorized access. Please note, however, that no electronic transmission of information is completely secure, and we cannot guarantee the security of your Personal Data. The safety and security of your information also depends on you. You are responsible for keeping your password confidential.

Retention

We will retain the categories of Personal Data described in the “Personal Data We Collect” section for as long as is necessary for the purposes set out in this Notice or otherwise authorized by law. Generally, this means we will hold Personal Data for as long as one of the following apply:

• Your Personal Data is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the Personal Data;
• Your Personal Data is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the Personal Data was collected;
• Your Personal Data is reasonably required to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or
• Your Personal Data may be maintained indefinitely according to legal or regulatory requirements, including applicable legal holds, or for data backup or recovery purposes.

Where Personal Data is used for more than one purpose, we will retain it until the purpose with the latest period expires. For more information about our retention policies, please contact us using the contact details below.

Additional Disclosures for California Residents

This section supplements the Passport Global Candidate Privacy Notice above and is provided pursuant to the California Consumer Privacy Act, as amended from time to time (“CCPA”). Capitalized terms not otherwise defined in this section or the Passport Global Candidate Privacy Notice above have the same meaning as the matching terms defined in the CCPA.

In the event of a conflict between any other of our policies, statements, or notices and this section, this section will prevail as to California Consumers’ rights under the CCPA.

Unless otherwise noted, the disclosures contained within this section describe our current practices and our practices for the twelve (12) months preceding the “Last Modified” date.

Personal Data We Collect, Use, and Disclose

We and our vendors may collect the Personal Data described in the “Personal Data We Collect” section above, both online and offline. We collect, use, and disclose these categories of Personal Data as described in the “How We Collect Personal Data,” “How We Use Personal Data,” and “How We Disclose Personal Data” sections above.

Some of the Personal Data we collect is considered Sensitive Data under the CCPA, including social security, driver’s license, state identification card, or passport numbers; Personal Data that reveals a consumer’s racial or ethnic origin, religious or philosophical beliefs, citizenship or immigration status, or union membership; Personal Data collected and analyzed concerning a consumer’s health (i.e., drug-screening information); and Personal Data collected and analyzed concerning a consumer’s sex life or sexual orientation.

Sales and Sharing

This section describes the categories of Personal Data Sold or Shared with Third Parties for Cross-Context Behavioral Advertising in the preceding twelve (12) months.

We may Sell and/or Share the following categories of Personal Data: Identifiers, Personal Records, Internet or Other Electronic Network Usage Data, Geolocation Data, and Inferences. We may Sell and/or Share these categories of Personal Data to or with advertising and digital analytics companies. For more information, see the “Cookies and Other Similar Tracking Technologies” section in our Privacy Notice.

We do not have actual knowledge that we Sell or Share the Personal Data of Consumers under sixteen (16) years old.

California Privacy Rights

California Consumers may contact us using the information in the “Contact Us” section to exercise any of the rights outlined below. In some cases, we may need to verify your identity (or that of your authorized agent). To do this, we may request additional information from you.

California Consumers have the following rights related to their Personal Data:

• Right to Know. You have the right to request that we provide you with the following information:
  • The specific pieces of Personal Data we have collected and maintain about you.
  • The categories of Personal Data we have collected.
  • The categories of sources from which we collect Personal Data.
  • The Business or Commercial Purpose for collecting, Selling, or Sharing Personal Data.
  • The categories of Personal Data we have disclosed about you for a Business Purpose and the categories of recipients to which it was disclosed.
  • The categories of Personal Data we Sold or Shared about you and the categories of Third Parties to which each category of Personal Data was Sold or Shared.
• Right to Correct. You have the right to request that we correct Personal Data we maintain about you that you believe is inaccurate.
• Right to Delete. You have the right to request that we delete Personal Data we collected from you or about you, subject to certain exceptions.
• Right to Opt Out of Sales and Sharing. You have the right to opt out of Selling and Sharing of your Personal Data. You may opt out of Sales or Sharing via Cookies through an opt out preference signal (such as the Global Privacy Control) or by selecting the cookie icon in the lower left-hand corner of the Site and updating your preferences. Note that if you come back to our Site from a different device or use a different browser on the same device, you will need to opt out for that browser and device as well.

We do not use or disclose Sensitive Data for purposes to which the right to limit use and disclosure applies under the CCPA. We also do not engage in automated decisionmaking in furtherance of decisions that produce legal or similarly significant effects.

We will not discriminate against any Candidate who exercises these rights.

Additional Disclosures for International Visitors

This section supplements the Passport Global Candidate Privacy Notice above and is provided pursuant to applicable law, including requirements under the EU and UK General Data Protection Regulations.

Passport Global, Inc. is the controller of Personal Data processed pursuant to this Notice. If you have questions regarding this Notice or our privacy practices, you may contact our DPO at privacy@passportglobal.com.

Personal Data We Collect, Use, and Disclose

We and our vendors may collect the Personal Data described in the “Personal Data We Collect” section above, both online and offline. We collect, use, and disclose these categories of Personal Data as described in the “How We Use Personal Data” and “How We Disclose Personal Data” sections above.

Legal Bases for Processing

We generally rely on the lawful basis of taking steps to enter into a contract when reviewing your application and making employment decisions, as well as our legitimate interests in selecting and hiring talent. We may also process your Personal Data, with your consent, to inform you about upcoming job opportunities. Furthermore, we use your Personal Data to manage our business, fulfil contractual and legal requirements, and ensure the security of our systems and staff.

Data Subject Privacy Rights

Depending on your jurisdiction, you may have certain rights related to the Personal Data that we process about you.

You may exercise your privacy rights by using the information in the “Contact Us” section. We will comply with your request as soon as reasonably practicable, in accordance with applicable legal requirements.

To prevent unauthorized requests related to your Personal Data, we take steps to verify that you are the person that is the subject of the request. Following verification of your identity, we will process your request; if we are unable to fulfill your request, we will let you know why.

If you have questions about this process, including about requests we are unable to fulfill, you may contact privacy@passportglobal.com. You also may submit a complaint to the data protection regulator in your jurisdiction.

Subject to certain exceptions, you may exercise the following rights:

• Right to Know, Access, and Transfer. You may have the right to confirm that we process your Personal Data, know details concerning that processing, and access your Personal Data. You also may have the right to obtain your Personal Data in a transportable format.
• Right to Correct. You may request that we correct Personal Data that we maintain about you if you believe such Personal Data is inaccurate. Upon receipt of a verifiable request to correct inaccurate Personal Data, we will use commercially reasonable efforts to correct the information as you direct.
• Right to Delete. You may request that we delete your Personal Data. Please note that we may retain certain Personal Data as permitted or required by applicable law.
• Right to Restrict Processing. You have the right to request that we suspend the processing of your Personal Data in certain scenarios.
• Right to Object. You have the right to object to our reliance on our legitimate interests as the basis for processing your Personal Data.
• Right to Opt Out of Profiling. We do not engage in profiling that results in legal decisions or has a similarly significant impact. Accordingly, we do not offer the right to opt out of profiling.

International Data Transfers

Your Personal Data may be transferred to and processed in the United States, or in other jurisdictions which may have data protection laws and regulations that are different from the laws in the country in which you are located. We implement appropriate legal mechanisms and other safeguards to protect transferred Personal Data, and to ensure that an essentially equivalent degree of protection is applied to such Personal Data outside its country of origin. Where applicable, we will use standard contractual clauses to safeguard your Personal Data, including the Standard Contractual Clauses approved by the European Union and United Kingdom.

Changes to this Notice

We may update this Notice from time to time. Any changes will be effective immediately upon posting the revised Notice and updating the “Last Modified” date on the top of this page. If we make material changes to this Notice, we will provide notice or obtain consent regarding such changes, as may be required by law.

Contact Us

If you have questions about the application process, please contact the dedicated Passport recruiter with whom you have been connected. If you have any questions about this Notice or our privacy practices, please contact us by email at privacy@passportglobal.com or by mail at:

Attention: Data Privacy Compliance

Passport Global, Inc.

3790 El Camino Real, Suite 854

Palo Alto, CA 94306