Last updated: November 15, 2022

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1. What does this notice cover?

This notice describes how Samba TV and our affiliates and subsidiaries, which include Samba TV UK Limited, Samba TV Poland Sp.zo.o, Samba TV Germany Gmbh, Screen6 B.V., Samba TV Taiwan Branch, Samba TV (Australia) Pty LTD and Samba TV Japan KK (each and every one referred to as "SambaTV", "Samba", "we", "us" or"our"), uses your personal data in connection with your application for employment with us. It also describes your data protection rights, including a right to object to some of the processing which Samba TV carries out. More information about your rights, and how to exercise them, is set out in the "Your choices and rights" section.

We also may provide you with additional information when we collect personal data, where we feel it would be helpful to provide relevant and timely information.

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2. What personal data we collect

• Personal identification and communication information: your name, home address, phone number; email address; date of birth, gender, immigration status, and information about your entitlement to work;
• Application-related information: curriculum vitae (CV), cover letter, employment history, education history, qualifications and skills, reference contact information, position preferences, willingness to relocate, desired salary, interests and aspirations and background screening information if relevant; and
• Sensitive information: for example, information about your health and disabilities where     we need to make any reasonable adjustments; equal opportunities monitoring information, including information about your ethnic     origin and health.

We collect most of this information from you directly. For example, data is collected through our application portal and CVs; from correspondence with you; or through interviews, meetings or other assessments. We also collect some information about you from other people (e.g. recruiters, referrals), your referees or organisations (e.g. from LinkedIn if you choose to connect us with your LinkedIn profile; where applicable, we also collect data from our third-party background screening provider during the pre-employment screening process).

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3. Why we collect, use and store this personal data

We collect, use and store your personal data for the reasons set out below.  

·      Where this is necessary for Samba TV to enter into an employment contract with you:

• To make informed decisions on recruitment and assess your suitability for the role;
• To communicating with you about your application, to respond to your inquiries and schedule interviews;
• To reimburse you for any agreed expenses incurred in the application process where applicable.

·      Where necessary for Samba TV's legitimate interests, as listed below, and where our interests are not overridden by your data protection rights:

• To improve our recruitment process and activities;
• To verify the details you have supplied and, where applicable, conduct pre-employment background checks;
• Protecting our legitimate business interests and legal rights, including, use in connection with legal claims, compliance, regulatory, auditing, investigative and disciplinary purposes (including disclosure of such information in connection with legal process or litigation) and other ethics and compliance reporting requirements;
• To analyse and monitor the diversity of the workforce in accordance with applicable laws. This includes, for example, compliance with equal opportunity employment laws.

Where we process personal data on this basis, then– as required by data protection law – we have carried out a balancing test to document our interests, to consider what the impact of the processing will be on individuals and to determine whether individuals interests outweigh our interests in the processing taking place. You can obtain more information about this balancing test by using the contact details at the end of the notice.

·      Where necessary to comply with a legal obligation.

• To comply with legal, regulatory and other requirements under EU or Member State laws.

·      Where you have given consent: ‍

• To contact you about future career opportunities at Samba TV.

We may provide you with more specific notices for some of the processing described above and, if we require your consent, will ask for thisat the time we collect your personal data.

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4. Verification and background checks

For certain positions, it will be necessary for us to verify the details you have supplied (for example, in relation to your identity, employment history, academic qualification and professional credentials) and to conduct pre-employment background checks (for example, in relation to previous criminal convictions or financial standing). The level of checks will depend on your role, in particular whether you will occupy a regulated role, and will be conducted at as late a stage as is practicable in the recruitment process and often only after you have been selected for the position. If your application is successful, we will provide further information about the checks involved and will obtain any necessary consent prior to completing such checks.

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5. How we share your personal data

Personal data will primarily be processed by employees in our Human Resources, IT and finance, and facilities departments. This will include sharing your personal data with our HR and leadership personnel in the UnitedStates.

Your personal data will be shared with companies providing services, such as technology services including hosting, maintenance, administration and analysis, as well as other agencies, under contract to Samba TV as part of the recruitment process. For general recruitment services, we use a third party applicant tracking system. With your consent, we may also share your personal data with a third party background checking provider.

Your personal data also will be shared with government authorities and/or law enforcement officials if mandated by law or if required for the protection of our legitimate interests in compliance with applicable laws.

In the event that a Samba TV business is sold or integrated with another business, your details may be disclosed to our advisers and any prospective purchaser's adviser and will be passed to the new owners of the business.

In the event that applicant data is otherwise transferred outside of the UK or the EEA to an organisation in a country which is not subject to an adequacy decision by the EU Commission or considered adequate as determined by applicable data protection laws, we will take steps to ensure your personal information is adequately protected (e.g. by way EU Commission approved Standard ContractualClauses, an appropriate Privacy Shield certification, a vendor's ProcessorBinding Corporate Rules or by relying on such other data transfer mechanisms as available under applicable data protection laws). A copy of the relevant mechanism can be obtained for your review on request by using the contact details below.

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6. Transfer of data outside of the European Union

Like most international businesses, we have centralized certain aspects of our business operations, including for example, financial, human resources, and information technology administration. This may result in the transfer of personal information from one country to another and amongst our various subsidiaries and affiliates. It should be noted that this may or may not include countries where the level of privacy protection and the legal rights of individuals are not considered commensurate with standards of protection in jurisdictions having comprehensive data protection laws, such as the countries of the European Union. In the event that applicant data is otherwise transferred outside of the UK or the EEA to an organisation in a country which is not subject to an adequacy decision by the EU Commission or considered adequate as determined by applicable data protection laws, we will take steps to ensure your personal information is adequately protected (e.g. by way EUCommission approved Standard Contractual Clauses, an appropriate Privacy Shield certification, a vendor's Processor Binding Corporate Rules or by relying on  such other data transfer mechanisms as available under applicable data protection laws). A copy of the relevant mechanism can be obtained for your review on request by using the contact details below. In the context of an onward transfer, Samba TV remains responsible for the processing of such personal information in a manner consistent with this Privacy Policy and where applicable, the EU-US Privacy Shield Framework.

SambaTV complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Samba TV has certified to the U.S. Department of Commerce that it adheres to the PrivacyShield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy ShieldPrinciples, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/. In compliance with the Privacy Shield Principles, Samba TV commits to resolve complaints about our collection or use of your personal information.  EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Samba TV at privacy@samba.tv. You may also address your concerns through the independent dispute resolution body JAMS at no cost to you, and, under the conditions set forth in the Privacy Shield Framework, invoke binding arbitration (for more information, please see Privacy ShieldAnnex I). Samba TV has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU in the context of the employment relationship.

As a participant in the Privacy Shield Framework, Samba TV is subject to the investigatory powers of the United States Federal Trade Commission.

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7. Your choices and rights

You have the right to ask Samba TV for a copy of your personal data; to correct, delete or restrict processing of your personal data; and to obtain the personal data you provide in a structured, machine readable format. In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement). Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to Samba TV processing your data, this will not affect any processing which has already taken place at that time.

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep.If you have unresolved concerns, you have the right to complain to a data protection authority.

Where we collect personal data to administer our contract with you or to comply with our legal obligations, this is mandatory and we will not be able to manage the employment relationship without this information. In all other cases, provision of the requested personal data is optional, but this may affect your ability to participate in certain programs or systems, where the information is needed for those purposes.

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8. How long we retain your personal data

If you are successful: we will retain your personal data only for as long as we need it for Samba TV's legitimate interest in accordance with applicable law, for the purposes of the recruitment process and, once this process is finished, for an appropriate period so as to be able to deal with any legal claims linked to the application process. Recruitment records for successful applicants will be processed in accordance with applicable laws, and the for the time periods stated therein. After this period, we will take steps to delete your personal data or hold it in a form that no longer identifies you. If you become a Samba TV employee, relevant personal information you provide will become a part of your employee file and may be used later for the management of the employment relationship.

If you are not successful: we will delete your information after 1 year.If you have provided us your permission to contact you about future opportunities, then we may use this information to contact you.

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9. Updates to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

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10. Contact us

The data controller for your personal data will be Samba TV.

If you have questions about this privacy notice or wish to contact us for any reason in relation to our personal data processing, please contact us by:

·       Email to privacy@samba.tv

·       Letter to Samba TV, Inc. 118 King St. San Francisco, CA 94107

You may also contact our data protection officer by emailing DPO.SambaTV@twobirds.com.

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