Brooks Candidate Privacy Statement

At Brooks, we put the Runner First, and we put your privacy first. This Candidate Privacy Statement explains how Brooks collects, handles and retains information from internal and external job applicants; how we use that information, including who we share it with; and the rights applicable to your information under the law. In this Candidate Privacy Statement, “Personal data” means information, or a combination of pieces of information, that could reasonably allow you to be identified; “we”, “us” or “Brooks” means Brooks Sports, Inc. and its local affiliate relevant to the job in question depending on your application:

• The Netherlands, Brooks Sports B.V.
• Belgium, Brooks Sports B.V.
• Germany, Brooks Sports GmbH
• Switzerland, Brooks Sports GmbH Schweiz
• Austria, Brooks Sports GmbH • United Kingdom, Brooks Sports Ltd
• Republic of Ireland, Brooks Sports Ltd
• Italy, Brooks Sports S.R.L.
• France, Brooks Sports Sarl • Spain, Brooks Sports S.L.U.

Types of Personal Data We Collect

The categories of data that we collect directly from you are:

• Identifiers: personal and contact details (e.g. your name, phone number, email address, postal address or mobile number); username and password for the online recruiting system; and information about family and dependents that we may collect for relocation purposes.
• Professional and Employment-Related Information: information contained in your CV and other documents related to the application process, such as cover letters, transcripts and certifications; other information you may choose to submit to us, including information contained in a cover letter; information disclosed in an interview; or information you volunteer regarding your criminal records history, compensation history, family history or personal situation; job history information, such as previous employment, roles and performance history.
• Educational Information: your educational history, degrees earned, qualifications, certifications and skills.
• Personal Characteristics: data related to diversity (where allowed by law), such as nationality, age, gender and citizenship or immigration information that we need for visa purposes or right to work information.
• Electronic, Visual and Audio Information: on-premises information collected for security purposes, such as video surveillance when attending our premises for an interview.
• Internet Activity Information: we use cookies and similar technologies to automatically collect information about you when you use the recruiting system and visit our website (see our Privacy Policy for further information about how this works).

We may collect the following data about you from other sources:

• Professional and Employment-Related Information: in the United States, background check data—potentially including your criminal records history, employment history, educational history and/or compensation history—from employment screening agencies, publicly available registers or databases, former employers and/or educational institutions (each as allowed by local laws); information provided by your references and/or current or former employers pertaining to your performance or conduct; information provided by other Brooks employees or Brooks employees who interview you and who may provide feedback about you. We do not collect background check data in countries outside the United States.
• Internet Activity Information: we review relevant publicly available information from websites or social media, including information that you choose to submit to us in connection with your application, such as when you apply through LinkedIn or another third-party website.

How We Use Your Personal Data and the Basis on Which We Use It

We collect and use your personal data only when we need it for specific purposes, such as the following:

• Manage and maintain the recruiting system, job applications and a database of interested individuals and leads;
• Evaluate your skills, qualifications and interests for the position you applied for and/or other Brooks positions;
• Communicate with you about your interest in Brooks, job opportunities, your application, or the recruiting process;
• Verify your information, including through reference and background checks, where applicable and allowed by law;
• Send you information about working at Brooks before your first day;
• Send you information about other Brooks positions which may be of interest to you (subject to your consent);
• Operate, evaluate and improve the recruiting system, including tracking applications, analysing our hiring practices or trends, identifying qualifications or skills shortages, and using information to match candidates and potential opportunities; • Detect, prevent and respond to fraud or potentially illegal activities or breach of applicable policies;
• Audit, assess, maintain and test the recruiting system and recruiting processes;
• Comply with our legal obligations and cooperate with regulators and law enforcement bodies;
• Respond to your questions and requests.

In most cases, our legal basis for processing your personal data will be at least one of the following:

• Compliance with our (pre-)contractual obligations to you.
• Compliance with our legal obligations. When we are required by local law to collect certain personal data about you, your failure to provide this data may prevent or delay the fulfilment of our legal obligations and may affect our ability to employ you.
• Our legitimate interests, such as managing the recruiting processes and applications efficiently and fairly.
• When you have consented for your information to be saved so that we may contact you in the future, you have consented to the processing. If we ask for your consent to process your personal data, you may withdraw your consent at any time by contacting us at privacy@brooksrunning.com.

Rights Applicable to Your Personal Data

You have certain rights regarding your personal data, subject to applicable local laws. These include the right to access your personal data and under certain conditions fix any errors in your personal data; erase or delete your personal data; restrict our use of your personal data; object to our use of your personal data; receive your personal data in a usable electronic format and transmit it to a third party (right to data portability). You also have the right to lodge a complaint with your local data protection authority or regulatory body. If you would like to exercise any such right, please contact us at privacy@brooksrunning.com. We encourage you to also contact your recruiting contact to update or correct your information if it changes or if the personal data we hold about you is inaccurate.

Who May Have Access to Your Personal Data

The following entities and third parties may have access to your personal data:

• Brooks affiliates, for recruitment purposes, human resources management and internal reporting.
• Service providers and business partners with whom we have professional contracts for business operations, including those related to recruiting and information verification.
• Law enforcement agencies, courts, regulators, tax authorities, government authorities, or other third parties if necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, your rights, or the rights of a third party.

Data Security and Retention

We implement appropriate technical and organisational measures to secure your data, including implementing security software and allowing access to your data only if there is a business need to do so. Our goal is to maintain the ongoing integrity and confidentiality of personal data, and we evaluate these measures regularly to ensure the security of processing.

We will keep your personal data until the position you are applying for has been filled, after which we will retain your personal data as necessary for the following reasons:

• Maintain business records for analysis or audit purposes.
• Comply with record retention requirements as required by local law or other relevant legal or regulatory requirements.
• Defend, establish, exercise or bring existing or potential legal claims.
• Detect or prevent fraud.
• Respond to your queries or complaints.
• With your consent, suggest roles that may be of interest to you.

We will delete your personal data in accordance with local law and when it is no longer required for these purposes. If there is any personal data that we are technically unable to delete entirely from our systems, we will take appropriate measures to prevent any further processing or use of that personal data.

International Data Transfer

Brooks is a global business, so we may transfer or process your personal data in a country other than where you reside, including in countries that are not subject to an adequacy decision by the European Commission, and that may not provide for the same level of data protection as your jurisdiction. In these instances, we comply with applicable legal frameworks (such as the Standard Contractual Clauses, which establish an equivalent level of protection with EU law). Please contact us at privacy@brooksrunning.com if you wish to receive more information or a copy of the SCC.

Contact

You may contact us with questions about this Policy at privacy@brooksrunning.com. We may modify or update this Candidate Privacy Statement from time to time by making changes to this web page. Each version of this Statement is identified with the date it was last updated.

Last updated 1 April 2022