Effective Date: December 10, 2024

GlobalCandidate Privacy Notice Regarding Use of Personal Information (“Notice”)

What is the purpose of this document?

Affirm, Inc. and its affiliates (collectively, “Affirm” “Company”, “we” or “us”) is a "controller" in relation to personal data. This means that we are responsible for deciding how we hold and use personal information about you. This privacy notice is applicable to you because you are applying for work with us. It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment and hiring exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under applicable data protection laws.

Data protection principles

We will comply with data protection law and principles, which means that your data will be:

• Used lawfully, fairly, and in a transparent way.

• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

• Relevant to the purposes we have told you about and limited only to those purposes.

• Accurate and kept up to date.

• Kept only as long as necessary for the purposes we have told you about.

• Kept securely.

The kind of information we hold about you

In connection with your application for work with us, we will collect, store, and process the following categories of personal information (which means any information about an individual from which that person can be identified) about you:

• The information you have provided to us in your curriculum vitae, resume, cover letter, and/or any portfolios or websites.

• The information you have provided on our application form, including name, title, state or province, telephone number, personal email address, gender, preferred pronouns, employment history, qualifications. Any information or output you provide to us during an interview or assessment.

• Interview and transcription notes.

• Your voice or image recordings, with your prior explicit consent.

We may also collect, store and process the following types of more sensitive personal information, though such information will only be used in making a hiring decision and only when is necessary for complying with our legal obligations:

• Information about criminal convictions and offenses.

We may also collect, store and process the following types of sensitive information, where you have provided this to us voluntarily. We will only process this in accordance with applicable law and subject to a relevant legal basis.

• Any sensitive personal information which you voluntarily provide, such as your gender identity, LGBTQ+ status, race or ethnicity, veteran status, or disability status.

How is your personal information collected?

We collect personal information about candidates from the following sources (where applicable to your jurisdiction):

• You, the candidate.

• Recruitment agencies, from which we collect the following categories of data: name, resume/curriculum vitae, contact details, email address.

• Background check providers, from which we collect the following categories of data: name, date of birth, place of birth, gender. We may also collect the following as applicable to your jurisdiction: mother's maiden name, social security number, identification documents.

• Criminal conviction information.

How we will use information about you and the legal grounds for processing

We will use the personal information we collect about you to:

• Assess your skills, qualifications, and suitability for the role.

• Carry out background and reference checks, in accordance with applicable law.

• Communicate with you about the recruitment process.

• Keep records related to our hiring processes.

• Comply with legal or regulatory requirements.

The lawful basis for processing your personal data for the above purposes are the following:

• It is in our legitimate interests to decide whether to appoint you to the role, since it would be beneficial to our business to appoint someone to that role.

• To process your personal information to decide whether to enter into a contract with you and to comply with our obligations resulting from either the employment contract or from the provisions of the law.

• The execution of the pre-contractual relationship between Affirm and you for a specific position or for other similar positions during the retention period of their curriculum vitae and other related data.

• The processing of your personal data related to this purpose is strictly necessary to fulfill this relationship and provide the described services.

We may utilize artificial intelligence or machine learning tools as part of our process. Please be advised that we do not use any of these tools in the process of any decision making.

If you fail to provide personal information

If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to assess your application further.

How we use sensitive personal information and the legal grounds for processing

We will only use your sensitive personal information (as defined in applicable data protection laws) in accordance with applicable law in your jurisdiction in the following ways and on the basis of the following legal grounds:

• We will use information about your disability status or religion to consider whether we need to provide appropriate adjustments during the recruitment process, in order to comply with our legal obligations.

• We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or LGBTQ+ status, to ensure meaningful equal opportunity monitoring and reporting.

Information about criminal convictions

We may process information about criminal convictions depending on your jurisdiction.

When we do so, we will ensure that this is done in accordance with applicable law and we have in place appropriate safeguards which are required when processing such data.

Automated decision-making

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

Data sharing

We will only share your personal information with the following third parties for the purposes of processing your application: Affirm affiliates and subsidiaries, software and third party service providers for the following purposes (not limited to), sourcing, reporting, scheduling, feedback, and interviewing. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

Data Transfer

Your Personal Information will be held and processed in the country you reside in. From time to time, we may be required to transfer your Personal Information across borders and internationally for the purposes set forth above, including but not limited to the United States, Canada, UK and EU/EEA. Personal Data processed and stored in another country may be subject to disclosure or access requests by the governments, courts or law enforcement or regulatory agencies in that country according to its laws. Where applicable, when we transfer your data, we will ensure that an appropriate level of protection is given to your Personal Information and that the transfers are conducted in compliance with applicable law.

If you have any questions, you may contact us using the information set out at the bottom of this Notice.

Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Where recipients of your personal data are in jurisdictions that are outside the European Economic Area (EEA), and local laws may not have similar data protection laws as the European Union (i.e. because an adequacy decision of the European Commission does not exist), we will take all reasonable steps necessary to ensure that your personal data has an appropriate adequate level of protection and safeguards to comply with applicable laws, for example, by using standard contractual clauses approved by the European Commission.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

Your personal information will be processed during the recruitment process and will be retained for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. We retain your personal information so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with applicable laws and regulations.

The retention period for your data may vary depending on your jurisdiction, and we may request your consent to retain your data for an extended period to consider you for any future roles at Affirm.

Rights of access, correction, erasure, and restriction

Your rights in connection with personal information. Under certain circumstances, in certain jurisdiction by law you have the right to:

• Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

• Request erasure of your personal information or restrict the dissemination of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

• Right to request certain information about decisions made using automated decision making.

• Request the transfer of your personal information to another party.

If you want to exercise your rights, please contact employeeprivacy@affirm.com.

Right to withdraw consent

Where you provided consent for us to undertake certain processing as set out in this Notice, where applicable under certain data protection law, you have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact employeeprivacy@affirm.com. Once we have received notification that you have withdrawn your consent, we will cease such processing activity and, subject to data protection laws, we will dispose of your personal data securely.

Questions

If you have any questions about this privacy notice or how we handle your personal information, please contact the employeeprivacy@affirm.com. In the UK and EU/EEA, you have the right to make a complaint at any time to the relevant data protection authority.

For Poland
President of the Office for Personal Data Protection, address: 2 Stawki Street, 00-193 Warsaw, www.uogo.gov.pl

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