Applicant and Candidate Privacy Notice

At Circle, protecting the privacy of personal information is a top priority. This Applicant and Candidate Privacy Policy (“Privacy Policy”) describes how Circle Internet Financial, LLC and the Circle company affiliates and subsidiaries (collectively, the “Circle Group”) collect, use, and disclose personal information in connection with the recruitment process for employment, contingent work, and/or internship opportunities.

This Privacy Policy is issued on behalf of the Circle Group. When we mention “Circle”, “we”, “us” or “our” in this Privacy Policy, we are referring to the relevant company in the Circle Group responsible for processing your personal information, which we call your data controller. Typically, your data controller is the Circle entity that would be responsible for your working relationship if you were to receive an offer. For a list of Circle Group entities, please see the Local Circle Entities list in the appendices to this Privacy Policy.

Depending on where you reside, the information in one of the attached appendices may apply to you. The appendices include important information about rights under data protection and privacy laws in certain countries and regions. Please see the appendices for additional information. 

Please read through this Privacy Policy carefully. It is important that you read this Privacy Policy, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

We want to keep this Privacy Policy up to date, so it may change over time. If you have a question, please let us know by reaching out to privacy@circle.com.

This Privacy Policy does not form any express or implied contract of employment or other contract to provide services. Nothing in this Privacy Policy should be construed to interfere with Circle’s ability to process personal information for purposes of complying with our legal obligations, or for investigating alleged misconduct or violations of company policy or law, subject to compliance with local legal requirements. Circle’s processing of personal information is subject to the requirements of applicable local law and internal Circle policy. To the extent this Privacy Policy conflicts with local law, local law controls.

Who is Covered by this Privacy Policy

This Privacy Policy covers all candidates or other individuals (a) who apply to an open position with us; (b) who express interest in working with us or are contacted by us regarding job opportunities; (c) who participate in any Circle recruitment event or activity; or (d) who undergo an interview or assessment with us (“Candidate(s),” “you”).  

This Privacy Policy does not apply to your interactions with Circle when using any Circle products or services or when you visit the main Circle website at Circle.com. Please review the Circle Privacy Policy posted on our website for information about our privacy practices related to these interactions.

If you are an employee or contingent worker with Circle, the Circle Global Workforce Privacy Notice applies to you.

What Personal Information We Collect and How We Collect It

“Personal information” means any information that identifies or could be used to identify an individual person, such as name, email address, and phone number.  Personal information does not include anonymized or aggregated information.

Circle processes the following categories of Candidate personal information: 

• • Identifiers — full name;
  • Contact information — such as email address, phone number, postal address;
  • Education and professional background information — CV and/or resume, employment history, education history, job qualifications
  • Professional online profiles— LinkedIn profile information and URL, information from other professional website or social media profiles that are publicly available or that you provide; 
  • Job application information and communications — information submitted when completing a job application, such as business or government relationships that could lead to conflicts of interest, responses to questions related to the role and/or your skills and experience, and information provided in communications with us during the recruitment and interview process, such as through email communications with us; 
  • Immigration status and right to work information — citizenship status, visa status, residency status, work permits;
  • Interview information — information gathered during the interview process, such as notes and any information you choose to provide during interviews;
  • Hiring decision information — results of the selection process and hiring decisions; 
  • Video, voice and image — such as video calls and video call recordings, photos from a resume/CV and/or profile on LinkedIn or other online professional website or job board;
  • Online identifiers and usage information — Online identifiers, usage and log data, such as IP address, device ID, browser type and version, and clickstream data, collected via automated means such as through cookies and other trackers when you access or use the Circle online job application portal, such as when you submit a job application online. Please see the Circle Cookie Policy for more information. For information collected when you visit the Circle careers pages on the Circle.com website, please see Use of the Circle Careers Website below;
  • Demographic information — such as gender identity and certain sensitive personal information that may include race, ethnicity, sexual orientation, marital status, veterans status, religious affiliation, and political or philosophical belief information. If we collect demographic information, we typically do so on a voluntary basis unless it’s necessary for us to comply with our legal obligations;
  • Survey and feedback data — data colle[;cted in response to any questionnaires or surveys throughout the recruiting and interview process and any feedback a Candidate may provide about the process.

You may choose not to provide personal information. However, some personal information is necessary so that we can evaluate and process your job application and candidacy and comply with our legal obligations. If personal information is not provided, our ability to consider you as a candidate may be limited.

Sensitive personal information

Circle may collect personal information that is considered under applicable data protection laws to be sensitive personal information, also called special categories of personal information. This may include personal information such as race, ethnicity, sexual orientation, health information (such as disability status), marital status, and veterans status. Circle only processes sensitive personal information as required or permitted under applicable law.

Sources of personal information

We collect personal information in the following ways:

• • Directly from you — such as when you submit a job application, interview with us, and/or communicate with us.  
  • Automatically collected — such as through cookies and other similar tracking technologies on our online job application portal. Please see our Cookie Policy for more information.
  • From third-party sources — such as from online job boards, recruiting websites and social media platforms like LinkedIn, third-party recruiting agencies, individuals who refer you for a role with us, former employers, our service providers, and your professional references.

Use of the Circle Careers Website

Your access to and use of the Circle careers pages on the Circle.com website is covered by the Circle Privacy Policy and Cookie Policy posted on Circle.com. Please review those policies for information about personal information that is automatically collected and processed when you access and use the Circle.com website and Circle’s use of cookies and other tracking technologies on the website, including for Circle’s targeted advertising purposes, as well as your options for managing cookies and other tracking technologies.

How We Use Personal Information

We process personal information for the following purposes: 

• • Communicate with you — contact you about job opportunities that may interest you, respond to your inquiries, communicate with you regarding the status of a job application.  
  • Process job applications — identify potential Candidates, evaluate your job application and/or your skills and qualifications, determine your suitability for current and future roles with us, maintain our recruiting records.
  • Conduct interviews and make hiring decisions — schedule and conduct interviews with you, determine your suitability for current and future roles with us, make hiring decisions, prepare a job offer package or employment contract (if applicable).
  • Immigration — determine your eligibility for hiring.
  • Background checks — administer background screenings and conduct reference checks, as required or permitted under applicable law.
  • Diversity, equity and inclusion (“DEI”) — foster a diverse and inclusive candidate pool and recruitment process as part of Circle’s global DEI programs, as permitted under applicable law.
  • Analytics — conduct analytics, data insights, and reporting related to our talent acquisition and hiring activities and use of our careers websites.
  • Security and management of systems and facilities — provide for the security of Circle systems, data and other confidential information, maintain the security and safety of Circle’s facilities and staff, protect Circle’s business interests, and detect and investigate fraud, all as permitted by applicable law.
  • Legal requirements – comply with our legal obligations and policies (e.g., labor and employment laws, equal opportunity and anti-discrimination requirements), under judicial authorization, or to exercise or defend legal rights.
  • Business transfers – in the event of a business transition, such as a merger, acquisition by another company or sale of all or a portion of Circle’s assets.
  • Manage and improve our recruiting programs and systems – obtain feedback from you regarding your experience with our recruiting process, administer recruiting campaigns, manage and improve our recruiting systems, processes and programs. 

If you are hired, the personal information described in this Privacy Policy will be processed for onboarding purposes and will become part of your human resources records, in accordance with our Global Workforce Privacy Notice.

Please see the Appendix below for information about the relevant legal bases of processing.  

How We Share Personal Information

Circle shares personal information only with those who have a legitimate business need or reason to access it.  We may share personal information in the following ways:

• • Within Circle – We share personal information with Circle personnel who have a business need to know the information in connection with the recruitment and/or hiring process, such as the manager in charge of hiring for the role, and internally within the Circle Group for the purposes described in this Privacy Policy and as required under applicable law.  All Circle personnel who handle personal information must comply with Circle’s privacy and security policies.  
  • With Circle’s third-party service providers and agents – We share personal information with external third parties that help us provide and administer our recruiting functions. These third parties may include, but are not limited to, technology platform providers, recruiting agencies and consultants, candidate relationship management services, legal service providers, and IT service providers. We require these third parties to agree to safeguard the personal information they receive.  
  • Merger or sale of our business – If we are involved with a merger, asset sale, reorganization, financing, liquidation, bankruptcy, or the acquisition of all or part of our business, we may share personal information in connection with that event, such as with an acquiring company and its advisors. Any acquirer or successor of Circle may continue to use the personal information as described in this Privacy Policy provided that the acquirer or successor is bound by appropriate agreements or obligations and may only use or disclose personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy, or unless you consent otherwise.
  • Response to legal requests – We or another entity in the Circle Group may share personal information with third parties when we reasonably believe disclosure is required or permitted to comply with a subpoena, court order or other applicable law, regulation, legal process or government authority. We or another entity in the Circle Group may share personal information as necessary to establish, exercise or defend against potential, threatened or actual litigation.
  • Protection of Circle and others – We may share personal information with third parties when we believe it is appropriate to protect the rights, property, or safety of Circle, our products or services, our customers, our personnel or others, or to respond to an emergency that we believe in good faith requires us to disclose personal information to prevent harm.  
  • With your consent – We may share your personal information in other ways not described in this Privacy Policy with your consent.

We may share information in a form that does not identify you individually, such as in aggregate and/or anonymized form, internally within the Circle Group or with certain third parties for purposes such as analytics, research, reporting and benchmarking.

Managing Your Personal Information

You may review, update and correct certain personal information that you provide to us by contacting talent-acquisition@circle.com. Alternatively, you can contact us using the methods described in this Privacy Policy.

You may opt out of receiving communications from our Talent Acquisition team by clicking “unsubscribe” in any email that we send you or you can contact us using the methods described in this Privacy Policy. If you opt out, we will still send you transactional emails, such as emails related to a pending job application or upcoming interview. 

International Data Transfers

The personal information that we collect or receive may be transferred to and processed in countries located outside of your country of residence to the countries where we or our third-party service providers or agents process it, including the United States. The data protection laws of the countries where personal information is processed may be different from those in your country of residence. Whenever we transfer personal information internationally, including within the Circle Group, we take steps to protect it as required under applicable law.

How We Protect Personal Information

At Circle, we take our responsibility to protect the security and privacy of personal information seriously. We have implemented what we believe to be reasonable and appropriate security measures designed to prevent personal information from being lost, used, accessed, altered, or disclosed in an unauthorized or unlawful way.

However, no method of transmission over the Internet, or method of electronic storage, is 100% secure, and we cannot and do not guarantee that personal information is completely secure and safe from such risks. 

How Long We Store Personal Information

We retain personal information for as long as needed to fulfill the purposes stated in this Privacy Policy and as required under applicable law and regulatory requirements. Generally, we keep personal information in our records to consider you for future opportunities with us, as permitted under applicable law, unless you tell us not to keep it. We also keep personal information for a reasonable period of time as necessary to respond to any hiring-related inquiries and manage legal obligations. To determine how long we keep personal information, we consider the amount, nature, and sensitivity of the personal information, the reasons for which we collect and process the information, and applicable legal requirements. 

Changes to this Privacy Policy

We may occasionally update or make changes to this Privacy Policy. When we do, we will revise the “Effective Date” at the top of the Privacy Policy. If we make material changes to this Privacy Policy, we will inform you of the changes as required under applicable law. You can see when this Privacy Policy was last updated by checking the “Effective Date” displayed at the top of this Privacy Policy.

How to Contact Us

If you have questions or comments about this Privacy Policy or our privacy practices, please contact us at privacy@circle.com.

Appendices

California

This California privacy notice supplements the information provided in this Privacy Policy and applies only to Candidates who are California residents. If you have any questions about your California privacy rights or the information provided in this California privacy notice, please contact us at privacy@circle.com.

For purposes of this California privacy notice, “Personal Information” is used as defined under the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CPRA”) and means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular consumer or household. Personal information does not include:

• •  information that is lawfully made available from federal, state, or local government records;
  • anonymous, de-identified, or aggregated information; and
  • information excluded from the scope of the CPRA, such as health or medical information covered under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and financial information covered under the Fair Credit Reporting Act (“FCRA”) or Gramm-Leach Bliley Act (“GLBA”)

California Privacy Rights

Candidates who are California residents have the following rights related to their Personal Information:

Exercising Your California Privacy Rights

To exercise any of the California privacy rights described above, you or your authorized agent acting on your behalf may submit a request by:

• • contacting Support or 
  • emailing us at privacy@circle.com

To verify your identity, we may ask you to confirm Personal Information we already have on file for you. If we cannot verify your identity from the information we have on file, we may request additional information, which we will only use to verify your identity and for security or fraud prevention purposes. If you use an authorized agent to make a request on your behalf, we may require proof from you that they have been authorized directly by you to act on your behalf. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request.

We will respond to your rights request as required under the CPRA. 

We reserve the right to deny your request subject to applicable law, such as if we cannot verify your identity or the authority to receive the Personal Information.

No Sale or Sharing of Personal Information

In the previous twelve (12) months, we have not “sold” or “shared” Personal Information or Sensitive Personal Information to or with third parties, as “sale” and “share” are defined under the CPRA. We do not sell or share Personal Information of consumers we actually know are under 16 years of age.

Please note that the use of certain tracking technologies on our Circle.com website, including the careers page on our website, may be considered “selling” and/or “sharing” of Personal Information under the CPRA. For more information and for a description of your opt-out rights with respect to the Circle.com website, please see our Circle Privacy Policy.

Retention of Personal Information

Please see the “How Long We Store Personal Information” section in the Privacy Policy above for information about how long we retain personal information that we collect.

Sources of Personal Information

We collect this personal information directly from California residents themselves, automated technologies, Circle entities, and third parties. The sources of personal information collected are noted in How We Collect Your Personal Data. 

Additional CPRA Disclosures

Below is a summary of the Personal Information categories, as defined by the CPRA, that we have collected in the previous twelve (12) months, the sources of the Personal Information, the business purposes for which we’ve used them, and the third parties to which we’ve disclosed them for business purposes. Some of the information in several of the categories may overlap.

In the table below, “Service Providers” means our service providers, agents, and professional advisers as described above in Section 4 (How We Share Personal Information).

For more information about the purposes for which we use Personal Information and the third parties with whom we share Personal Information, please see Sections 3 and 4 in the Privacy Policy above. 

For more information about the categories of Sensitive Personal Information we collect and the purposes for which we use Sensitive Personal Information, please see Section 2 in the Privacy Policy above. 

Outside of the United States (European Union, United Kingdom, and other non-U.S. countries)

This section applies only to Candidates who are located in countries or regions outside of the United States that have data protection or privacy laws applicable to Circle’s processing of personal information. This includes Candidates located in the European Union and the United Kingdom. 

For these Candidates, the data controller of your personal information is the Circle corporate entity with which you are seeking a job opportunity and/or with which you applied for a job.  Please refer to the list of local Circle entities below for more information.

Legal Basis for Processing

Circle processes personal information where there is a legal basis to do so. The applicable legal basis for processing will depend on the personal information concerned and the context in which we process it. Circle relies on the following legal bases for processing: where we are taking steps to enter into an employment contract with you (as applicable), where we need the personal information to comply with our legal obligations or exercise rights in the field of employment, where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or in some cases where we have your consent. Please see the table below for information about the relevant legal bases for the purposes of processing described in this Privacy Policy.

Data Rights

Under data protection laws in certain countries or regions, such as under the EU General Data Protection Regulation (“GDPR”) and the UK Data Protection Act, you have certain rights regarding your personal information. Depending on the applicable law, your rights may include the right to:

• • Be informed – that’s a right to be informed about how we use personal information (and that’s what we’re doing in this Privacy Policy);
  • Request Access – that’s a right to request access to and obtain a copy of the personal information we hold about you;
  • Request rectification – that’s a right to request that we correct personal information about you that is incomplete or inaccurate;
  • Request erasure (or deletion) – that’s where, in certain circumstances, you can ask us to delete the personal information we hold about you.  Please note that even if you request for your personal information to be deleted, we may need to retain certain personal information for particular reasons.  For example, we may need to retain personal information to meet our legal or regulatory compliance obligations;
  • Restrict processing – that’s a right for you in certain circumstances to ask us to suspend processing personal information;
  • Data portability – that’s a right for you to ask us for a copy of your personal information in a common, machine-readable format (for example, a .csv file);
  • Object – that’s a right for you to object to the processing of your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes, as applicable;
  • Withdraw Consent – if we have collected or otherwise processed personal information with your consent, you have the right to revoke that consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Depending on the applicable law, certain rights are subject to rules around when you can exercise them. Certain rights may apply differently depending on the type of personal information involved and Circle’s particular legal basis for processing the personal information.

To make a request to exercise any of your rights, please contacting Support or send us an email at privacy@circle.com. We will respond and act upon requests we receive in accordance with applicable data protection laws. 

We may need to request specific information from you to help us confirm your identity before we can respond to your request. This is a security measure to help ensure that personal information is not disclosed to any person who has no right to receive it and to help ensure that the person exercising the right is the person about whom the personal information relates or has the appropriate authority to do so.

While we hope we can answer any questions that you may have, if you are a resident of the European Economic Area or the United Kingdom, you also have the right to lodge any complaints or concerns with your local data protection authority. You can find a list of the European DPAs here: https://ec.europa.eu/newsroom/article29/items/612080/en

Data Protection Officer (“DPO”)

Circle has appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your rights, please contact us using the details set out below.

Full name of legal entity: Circle Internet Financial Limited (as GDPR representative)

Contact: DPO@circle.com 

You have the right to make a complaint at any time to your local data protection authority. We would, however, appreciate the opportunity to deal with your concerns before you approach your data protection authority, so please contact DPO@circle.com in the first instance.

Local Circle Entities