APPLICANT AND CANDIDATE PRIVACY NOTICE

Last Updated July 1, 2024

Axon Enterprise, Inc. and its group companies (“Axon” “we”, “us”, “our”) respect the privacy rights of individuals and is committed to handling Personal Data responsibly and in accordance with applicable laws and regulations. This Privacy Notice (“Notice”) describes how Axon collects and uses Personal Data or Personal Information during and after the recruitment process, and the rights you have in connection with that data. When you participate in this process, you acknowledge that you have read this Notice and understand its contents.

Axon may occasionally update this Notice. When Axon posts changes, Axon will revise the "last updated" date at the top of this page.

This Notice applies to anyone who (whether on a permanent or non-permanent basis): (1) applied for a job role; or (2) who otherwise seeks to work with or for us; or (3) who otherwise was previously or is currently being considered for a job role.

DEFINITIONS

·      “Candidate” means anyone who (whether on a permanent or non-permanent basis): (1) applies for a job role; or (2) who otherwise seeks to work with or for us; or (3) who is being considered for a job role.

·      “Personal Data” or “Personal Information” means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

·      “Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

WHAT PERSONAL DATA WE COLLECT

Axon collects and processes the following types of Personal Data about you in connection with our recruitment process.

·      Contact details: such as your name, home address, email address, phone number;

·      Information relating to your career: such as job history, academic background, qualifications, professional and personal competencies and skills, your job expectations;

·      Where permitted, information about your history of remuneration & benefits and your salary expectations;

·      Information relating to your employment references;

·      Information collected as part of the hiring process such as assessments and aptitude tests;

·      Identification information, as part of the pre-hiring process: such as copies of identification documents, immigration status;

·      Your video in case you conduct your interview using a tele-conferencing tool such as Zoom;

·      Details of your visits to our Website including, but not limited to, traffic data, the site that referred you to Axon’s Website and the resources that you access.; and

·      Any other information you submit to us as part of the recruitment process.

Where permitted, we may also collect, store and use the following special categories of more sensitive personal data, which could include:

·      Where you may choose to provide this information: Information about whether or not you have a disability for which we need to make reasonable adjustments as part of the recruitment process;

·      Where you may choose to provide this information: Information concerning your racial/ethnic origin, gender and disabilities for the purposes of equal opportunities monitoring, to comply with anti-discrimination laws or for government reporting obligations; and

·      Information about criminal convictions and offences (where the nature of the job requires this).

HOW YOUR PERSONAL DATA IS COLLECTED

Personal Data may be collected in different ways:

·      It may be contained in your CVs or resumes, in your application form, your identification documents, or may be gathered from interviews or assessments you take during the recruitment process;

·      In some cases, it may also be collected from third parties, for example from colleges for recruitment purposes or when seeking employment references or if we receive details of a certification or training you obtained;

·      We may also receive your CVs or resumes from recruiters and the results of verification and vetting checks from background checking providers; and

·      As part of our talent sourcing program, we often obtain your contact details and profile from various databases, Resume Books, LinkedIn, social media, or other available professional networking platforms or directories – some publicly available and others not.

HOW YOUR PERSONAL DATA IS USED

Axon will use your Personal Data for the following purposes:

·      Recruitment, selection, evaluation and appointment of job candidates (temporary or permanent) for the job for which you have applied;

·      Communicate with you and to inform you of current status of your application and future opportunities (unless you have told us that you do not want us to keep your information for such purposes);

·      General HR administration and management (in case you become an Axon employee);

·      Carrying out satisfaction surveys (for example, to manage and improve the recruitment process);

·      Application analysis such as verification of your employment reference(s) that you have provided, background checks and related assessments; and

·      Compliance with corporate governance and legal requirements (for example, to monitor diversity requirements).

LEGAL BASIS UNDER WHICH WE PROCESS YOUR PERSONAL DATA

If you are an individual in the European Economic Area, and Switzerland (“EEA”) or United Kingdom (“U.K.”), our legal basis for the collection and processing of your Personal Data is as follows:

·      Axon’s legitimate interests, namely the recruitment, selection, evaluation and appointment of new employees and the management and administration of the recruitment and HR process, to the extent these activities do not prejudice or harm your rights and freedoms.

·      Compliance with Axon’s legal obligations where employment law or other laws require the processing of your Personal Data (for example to the extent the law requires monitoring diversity requirements).

·      Other legal grounds where applicable such as in your vital interests (for example, health and safety reasons if you attend an interview at our site).

·      On your consent, when we ask you if you wish to hear about other jobs that may be of interest to you, or when we process special categories of more sensitive personal data such as race, gender, and disability.  

AUTOMATED DECISION-MAKING

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

WITH WHOM WE SHARE PERSONAL DATA

We will disclose your Personal Data to the following types of entities or in the following circumstances (where applicable):

·      Internally: to other Axon personnel involved in the recruiting and hiring processes;

·      Service Providers: in order to administer services during the Axon hiring process. These service providers include technology service providers, travel management providers, human resources suppliers, background check companies, and employment agencies or recruiters, where applicable;

·      Legal Compliance: when required to do so by law, regulation or court order; ;

·      Litigation Purposes: to seek legal advice from our external lawyers or in connection with litigation with a third party;

·      Business Transaction Purposes: in connection with a sale, purchase, or merger; and

·      Where we have otherwise obtained your consent.

DATA RETENTION

Axon retains personal data for the duration of your recruitment and for a period of time thereafter to allow Axon to analyze the data for Axon’s own operations and as required by law. For more information on where and how long your Personal Data is stored, please contact us at privacy@axon.com

If your application for employment is successful, Personal Data gathered during the recruitment process will be transferred to your personal file and retained during your employment. The periods for which your data will be held will be in accordance with the retention period applicable to employees.

DATA SECURITY MEASURES

Axon is committed to help protect the security of your Personal Data. Axon has established and implemented policies, programs, and procedures that are commercially reasonable and in compliance with applicable industry practices, including administrative, technical and physical safeguards to protect the confidentiality, integrity and security of Personal Data against unauthorized access, use, modification, disclosure or other misuse.

Axon will take appropriate steps to ensure compliance with the data security measures by its employees, contractors, third parties and vendors.

INTERNATIONAL TRANSFERS

Your Personal Data will be stored in a range of different places, including in our recruitment files, in our HR system, and in other IT systems (including email systems).

Your Personal Data may also be transferred to other Axon companies, branches and service providers, including outside the EU, UK and/or Switzerland and will be stored and processed manually and electronically through global systems and tools for the recruitment purposes described above.  Axon has appropriate safeguards in place to protect your Personal Data.

Axon complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  Axon has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.  Axon has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.   

Axon is subject to the investigatory and enforcement powers of the United States Federal Trade Commission regarding compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF). In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Axon commits to cooperate and comply respectively with the advice of  the panel established by the EU data protection authorities (DPAs), the UK Information Commissioner’s Office (ICO) and the Gibraltar Regulatory Authority (GRA), and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF,  the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. Under certain circumstances, you may also have the right to invoke binding arbitration.  Axon maintains contracts with third parties with whom it shares Personal Data restricting their access, use and disclosure of Personal Data in compliance with Axon’s obligations under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, including the onward transfer provisions. Axon may be liable if we fail to meet those obligations. 

If there is any conflict between the terms in this Policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/. 

If you are an individual in the E.E.A., U.K., or Switzerland, to obtain a copy of the safeguard describing how your Personal Data is protected, please contact us using the information in the Contact Us section below. 

YOUR RIGHTS

In some jurisdictions you have the rights described below with respect to your Personal Data. You may have the rights described below: 

·       Access and obtain a copy of your Personal Data on request; 

·       Require Axon to change incorrect or incomplete Personal Data; 

·       Require Axon to delete or stop processing your Personal Data, for example where the Personal Data is no longer necessary for the purposes of processing; 

·       Object to the processing of your Personal Data where Axon is relying on its legitimate interests as the legal ground for processing; and 

·       Withdraw your consent in circumstances where consent is the legal basis for processing. 

If you would like to exercise any of these rights or have any questions, please contact us at privacy@axon.com.

If you believe that Axon has not complied with your data protection rights, you may have the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred.  

In the EEA: the data protection authority of their place of residence; 

In the United Kingdom: the UK Information Commissioner’s Office (“ICO”); 

In Switzerland: the Federal Data Protection and Information Commissioner (“FDPIC”). 

In the United States, please contact your applicable State Attorney General.  

In other locations around the world, their local data protection authority. 

YOUR CALIFORNIA PRIVACY RIGHTS  

Pursuant to the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act ("CPRA"), we provide this California Consumer Privacy Act Addendum (the "CCPA Addendum") to California residents ("consumers" or "you" or “your”). This CCPA Addendum supplements the information contained in our Applicant and Candidate Privacy Notice. Any capitalized term used but not defined in this Notice has the meaning given in our Applicant and Candidate Privacy Notice. 

This CCPA Addendum only applies to information we collect about individuals in their capacity as present or former job applicants or employees of Axon.

Categories of Personal Information Collected  

Categories of Personal Information 

Examples  

Identifiers and Contact Information 

Name, postal address, telephone number, unique personal identifier, online identifier, 

Internet Protocol address, 

username, email address or other similar identifiers 

Internet or other electronic network activity information 

Interaction with our websites, applications, or advertisements 

Geolocation data 

Approximate physical location (derived from an Internet Protocol address) 

Professional or employment-related information 

Job title, employer name. Inferences drawn from the any of the above 

Account authentication credentials 

Username, encrypted and hashed password  

Sources of Personal Information 

We obtain the categories of Personal Information listed above directly from you as well as from the following categories of sources:

• It may be contained in your CVs or resumes, in your application form, your identification documents, or may be gathered from interviews or assessments you take during the recruitment process;

• In some cases, it may also be collected from third parties, for example from colleges for recruitment purposes or when seeking employment references or if we receive details of a certification or training you obtained;

• We may also receive your CVs or resumes from recruiters and the results of verification and vetting checks from background checking providers; and

• As part of our talent sourcing program, we often obtain your contact details and profile from various databases, Resume Books, LinkedIn, Social Media, or other available professional networking platforms or directories – some publicly available and others not.

Use of Personal Information 

We use Personal Information for a variety of business and commercial purposes, as described this Applicant and Candidate Privacy Notice.

Your Consumer Rights under the CCPA  

California law grants state residents certain rights, including the rights to know and access specific types of Personal Data, to learn how we process Personal Data, to request deletion of Personal Data, to request correction of Personal Data, to opt-out of sharing your Personal Data for third party advertising purposes, and not to be denied goods or services for exercising these rights. 

If you would like to exercise any of these rights, please contact us at privacy@axon.com.  

Right to Opt-Out of Selling or Sharing 

In the preceding 12 months, Axon has not sold or shared (as those terms are defined in the CCPA) any personal data. 

Authorized Agents 

To make a request as an authorized agent on behalf of a California resident, you may use the submission methods noted above. Please provide us with a copy of the consumer’s written authorization designating you as their agent. 

Nondiscrimination 

We will not unlawfully discriminate against you for exercising your rights under the CCPA. 

IF YOU CHOOSE NOT TO PROVIDE PERSONAL DATA

You are under no statutory or contractual obligation to provide Personal Data to Axon during the recruitment process.  However, if you fail to provide Personal Data when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we may not be able to process your application further.

HOW TO CONTACT US

If you have any questions or concerns regarding privacy and security of your personal data, please contact privacy@axon.com.