iCIMS, Inc. and its subsidiaries, iCIMS International, LLC, TextRecruit, Inc., Opening HR Limited, EasyRecrue S.A.S., Altru Labs, Inc., Candidate ID Ltd, and SkillSurvey, Inc. (collectively, “iCIMS,” “we,” or “us”), respects the privacy of its subscribers, prospects, business partners, event attendees, employees, job applicants, and website and mobile application users (collectively, “you”), and we are committed to protecting their respective personal data. To that end, we have put together this Privacy Notice (“Privacy Notice”) to give you a better understanding of who we are and our practices with respect to the collection, use, disclosure, and retention of personal data obtained in connection with the use of our Website and our marketing efforts.

For purposes of this Privacy Notice:

• The term “personal data” means any information which relates to an identified or identifiable, living individual that directly or indirectly references one or more factors specific to their physical, physiological, mental, economic, cultural, or social identity. Personal data excludes anonymous data.

Please take the time to read this Privacy Notice and the related statements in their entirety to ensure you are fully informed. If you have any questions or concerns about our processing of your personal data, please contact us by using the contact details under the “Contact Information” heading below.

Services Privacy Notice. Our Services Privacy Notice covers our privacy practices with respect to the collection, use, and disclosure of personal data obtained in connection with the use of our Subscription and related services, including professional services and trainings that we provide to Subscribers. It also describes our privacy practices with respect to Subscriber and partner contact information we process for Subscriber account, contract, and billing management purposes (e.g., the processing of Subscriber address and billing information) in connection with the use of our products and services and services, or technology provided by our partners to our Subscribers. For clarity, iCIMS collects personal data under the direction of its Subscribers and has no direct relationship with the Subscribers’ candidates. If you are a candidate of one of our Subscribers, please contact that Subscriber.

Talent Acquisition Privacy Notice. Our Talent Acquisition Privacy Notice covers our privacy practices in connection with an individual’s application for employment or interest in potential employment opportunities at iCIMS.

As further described below, we collect several types of personal data from and about you that broadly falls into the following three (3) categories:

1. Personal data you voluntarily provide to us:

• When filling out forms on our Website.
• When you register for a demo of one of our products or services.
• When you interact with a chatbot on our Website.
• When you enter a contest or promotion we sponsor.
• When you contact us.
• When you complete one of our surveys.
• When you register for or attend an event.
• When you visit our corporate offices.
• When you report an incident or concern or ask a question.

In each case, the personal data collected may include (but is not limited to):

• First name
• Last name
• Business or preferred mailing address
• Business or preferred email address
• Business or preferred telephone number
• Company or organization name
• Job title or role

If we ask you to provide any other personal data not described above, then the personal data we will ask you to provide, and the reasons why we ask you to provide it, will be made clear to you at the point we collect it. If we ask you to provide personal data that we consider to be mandatory for us to administer your relationship with us, we will inform you of such at the time of collection. In addition, we will also inform you of the consequences for not providing us with the mandatory personal data.

2. Personal data from third parties.

From time to time, we may collect and use personal data we receive about you from third parties in connection with your use of the Website or attendance at an event. For instance, we may receive personal data about you from our business partners related to your registration information for events. We also use third parties for reporting and analytics to measure the effectiveness of our Website and marketing efforts, and to identify areas for improvement.

We may combine personal data we collect from third parties with personal data you provide us to update, expand, or provide you with tailored information regarding our products, services, and events.

3. Data we collect as you navigate through the Website.

As is true of most websites, we gather certain data automatically. This data may include Internet protocol (“IP”) addresses, browser type, Internet service provider (“ISP”), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.

iCIMS and its third parties use cookies or similar technologies to analyze trends, administer the Website, track users’ movements around the website, and to gather demographic data about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service. You can also manage your preferences for the Website’s cookies by using the Cookie Preference Centers found in the Website’s cookie banners, and which can also be accessed here: .  For more information about our use of cookies and similar technologies, please see our Cookie Notice.

We may use personal data that we collect about you for the following purposes:

• To operate, maintain, and improve our Website.
• To communicate with you about events or register you for events you sign up for with us.
• To provide you access to our corporate offices.
• To provide you with information, products, or services that you request from us.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and iCIMS, including, but not limited to, our Website Terms of Use.
• To notify you about changes to our Website or obtain any required consent.
• To allow you to participate in interactive features of our Website, when you choose to do so, such as chatbots of community forums.
• For industry analysis, benchmarking, analytics, marketing, and other business purposes.
• To track your browsing and email actions, such as the pages you visited over time, for analytics and advertising purposes.
• To contact you for marketing purposes, in accordance with your marketing preferences (e.g., we may use your personal data to contact you to further discuss your interests in our services and products or other events), including, but not limited to, promotional offers for our own or third parties’ products or services. If you do not wish to receive our email marketing communication for promotional purposes, you may opt out by clicking on the “unsubscribe” or “opt out” link in the marketing e mails we send you.
• To comply with applicable laws, judicial requests from courts of competent jurisdiction, or exercising or defending legal rights.
• To prevent and detect fraud or other types of wrongdoing.
• To communicate with you about incidents, concerns, or questions that you submit to us.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For other lawful or legitimate purposes, which may be reasonably required for day-to-day operations.

Our processing of Personal Data for the purposes described in this Privacy Notice also includes the use of automated methods of processing, including sentiment analysis, machine learning, artificial intelligence, and generative intelligence capabilities. to analyze your Personal Data, determine trends, or create AI-generated responses or other content. When you interact with the chatbot on our Website, we may also store the transcript for the purposes described in this Privacy Notice.

We may also partner with third parties to either display advertising on our Website or to manage our advertising on other sites. Our third parties may use technologies such as cookies to gather data about your activities on the Website and other websites to provide you advertising based upon your browsing activities and interests. If you wish to not have this data used for the purpose of serving you interest-based ads, you may opt-out from many third parties through the Digital Adverting Alliance’s self-regulatory opt-out by clicking here or the Network Advertising Initiative’s self-regulatory opt-out by clicking here (or if you are located in the Economic European Area (“EEA”), the United Kingdom (“UK”), or Switzerland through the European Interactive Digital Advertising Alliance’s self-regulatory opt-out by clicking here). Please note that you will continue to receive generic ads. iCIMS uses online advertising services from Microsoft. To provide such advertising services, Microsoft collects Personal Data from you in accordance with the Microsoft Privacy Statement available at https://privacy.microsoft.com/en-us/privacystatement. iCIMS uses online analytics services from Google. If you do not want your data collected with Google Analytics, you can install the Google Analytics opt-out browser add-on. To opt-out of Google Analytics, visit the Google Analytics opt-out page (located at https://tools.google.com/dlpage/gaoptout) and install the add-on for your browser. For more details, visit the “Google Analytics opt-out browser add-on” page (located at https://support.google.com/talent-cloud-recruiting/platform/recruiting-analytics/answer/181881?hl=en). For more information about how you can manage cookies related to analytics and targeted advertising, please see our Cookie Notice.

If we need to process your personal data for an incompatible purpose not discussed in this Privacy Notice, we will provide notice to you and, if required by law, seek your consent. We may process your personal data without your knowledge or consent only where required by applicable law.

iCIMS takes care to allow your personal data to be accessed only by those who need such access to perform their tasks and duties, and to third parties who have a legitimate purpose for processing or accessing it. As such, we may share your personal data as described in this Privacy Notice to the following categories of recipients:

• To our subsidiaries, affiliates, or their or our successors or assigns.
• To our private equity investor, Vista Equity Partners, and its affiliates, contractors, service providers, and other third parties, including Vista Consulting Group, which will process the personal data on the basis of its legitimate interests in overseeing the administration, research, and business operations of iCIMS.
• To our contractors, business partners, service providers, and other third parties who require the data to assist us in supporting our business (e.g., third-party hosting facilities) or third parties with products, services or positions that may be of interest to you, provided such parties provide at least the same level of privacy protection as is required of iCIMS. These companies are authorized to use your personal data only as necessary to provide these services to us.
• To a potential buyer (and its agents and advisors) in connection with any proposed merger, acquisition, or any form of sale or transfer of some or all of our assets (including in the event of a reorganization, dissolution or liquidation), in which case, personal data held by us about you will be among the assets transferred to the buyer or acquirer.
• To a third party under the following circumstances where we, in good faith,: (i) believe we are compelled by applicable law or regulation, judicial request from a court of competent jurisdiction, or another legal process or government authority; (ii) find it necessary to exercise, establish or defend our legal rights; (iii) seek to enforce or apply our Website Terms of Use or terms of any other agreement; (iv) seek to protect iCIMS’ rights or property; (v) seek to protect iCIMS, our Subscribers, or the public from harm or illegal activities; (vi) seek to respond to an emergency which we believe, in good faith requires us to disclose data to prevent harm; or (vii) rely on your consent.

Please note that we do not sell (as defined in applicable data protection and privacy laws) your personal data (and will not sell it without providing any required notices and/or opt-in/opt-out rights).

If you are a resident of the EEA, the UK, or Switzerland, our legal basis for collecting and using the personal data described above will depend on the personal data concerned and the context in which we collect it. However, we will normally collect and/or process your personal data pursuant to one or more of the following legal bases:

• The processing is in our legitimate interests which do not override your data protection interests or fundamental rights and freedoms.
• The processing is necessary to perform a contract with you.
• The processing is necessary to comply with our legal obligations.
• We may also seek your consent to process or retain your personal data in certain, limited circumstances that we clearly identify to you.
• In some limited cases, we may need the personal data to protect your vital interests or those of another person; for example, we may need to share your personal data with third parties for security reasons (when we believe in good faith that disclosure is necessary to protect our rights, protect your or others’ safety, to investigate fraud, or respond to a related government request).

If we ask you to provide personal data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and let you know whether the provision of your personal data is mandatory or not (as well as the possible consequences if you do not provide it). Similarly, if we collect and use your personal data in reliance on our legitimate interests (or those of a third party) that are not listed above, we will make clear to you at the relevant time what those legitimate interests are. If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us using the contact details provided in the “Contact Information” section below.

iCIMS or its appointed service providers or contractors may collect, use, process, store and disclose your personal data outside of your home jurisdiction, including in the U.S., and in some cases, other countries, for the purposes described in this Privacy Notice.  These countries may have data protection and privacy laws that are different than the laws of your home country. iCIMS only transfers personal data to another country in accordance with applicable data protection and privacy laws, provided there are legally adequate protections in place for the personal data. A list of iCIMS’ global offices is available here.

If your personal data is processed within the EEA, the UK, or Switzerland, and for onward transfers of personal data to iCIMS’ appointed service providers or contractors, iCIMS and its appointed services providers or contractors will protect your personal data (as defined in the European Union’s (“EU”) General Data Protection Regulation (“GDPR”)) when it is transferred outside of the EEA, UK, or Switzerland by:

• Processing it in a territory which the European Commission (or other relevant governmental authority) has determined provides an adequate level of protection for personal data; or
• Otherwise implementing appropriate safeguards to protect your personal data, including through the use of Standard Contractual Clauses or another lawful transfer mechanism approved by the European Commission (or other relevant governmental authority).

If you require further information about our international transfers of personal data, please contact us by using the contact details under the “Contact Information” heading below.

iCIMS, Inc. and certain of its subsidiaries listed here comply 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. iCIMS 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 EEA in reliance on the EU-U.S. DPF and from the UK (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. iCIMS 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. If there is any conflict between the terms in this Privacy Notice 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/.

iCIMS is responsible for the processing of personal data it receives under the DPF and subsequently transfers to a third party acting as an agent on its behalf. iCIMS complies with the DPF Principles for all onward transfers of personal data from the EEA, the UK, and Switzerland, including the onward transfer liability provisions.

Although iCIMS also relies on Standard Contractual Clauses or other lawful transfer mechanisms approved by the European Commission (or other relevant governmental authority) to transfer personal data from the EEA, the UK, and Switzerland, iCIMS is committed to maintaining its DPF certification and will honor its obligation to comply with the DPF Principles.

The Federal Trade Commission has jurisdiction over iCIMS’ compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. In certain circumstances, iCIMS may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

EEA, UK, and Swiss individuals with inquiries or complaints regarding our privacy practices should first contact iCIMS as provided in the “Contact Information” section below. In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, iCIMS commits to refer 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 to TRUSTe, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://feedback-form.truste.com/watchdog/request for more information or to file a complaint. The services of TRUSTe are provided at no cost to you.

For complaints regarding DPF compliance not resolved by any of the other DPF mechanisms, you have the possibility, under certain conditions, to invoke binding arbitration. Further information can be found on the official DPF website.

iCIMS maintains appropriate technical and organizational measures, including, but not limited to, reasonably designed administrative, physical, and technical safeguards, designed to protect the personal data obtained as discussed in this Privacy Notice from accidental or unlawful destruction, loss, alteration, unauthorized disclosure and access. iCIMS personnel, service providers, and contractors with access to personal data collected as discussed in this Privacy Notice are required to keep such personal data confidential and secure.  iCIMS has a dedicated team responsible for monitoring and responding to security events, and it notifies applicable parties of security or privacy incidents and data breaches in accordance with its incident response procedures and applicable law.

Unless a longer retention period is required by law, we will retain your personal data for as long as is needed to fulfill the purposes outlined in this Privacy Notice, or for as long as we have a legitimate business interest that is not outweighed by your data protection interests or fundamental rights and freedoms. When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymize it or, if this is not possible (e.g., because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible. As such, we reserve the right to use such anonymous data for any legitimate business purpose without further notice to you or your consent.

Certain jurisdictions may provide you with privacy rights under applicable data protection or privacy law regarding your personal data. In particular, you may have the right to:

• be informed about your personal data;
• access your personal data;
• correct any personal data that is inaccurate;
• have your personal data erased;
• restrict or suppress the processing of your personal data;
• obtain and reuse your personal data;
• object to the processing of your personal data;
• object to how your personal data is used in automated decision making, if applicable.
• lodge a complaint with a supervisory authority; and
• obtain a copy of Standard Contractual Clauses (if applicable).

These rights may be limited, for example, if fulfilling your request would reveal personal data about another individual, or if you ask us to delete personal data which we are required by law to keep or which we need to defend claims against us.

If you are a California resident, please see our Privacy Notice for California Residents for additional disclosures and information about the personal data we have collected about you over the last 12 months and rights you may have regarding your personal data.

If you do not wish to receive our email marketing communication for promotional purposes, you may opt out by clicking on the “unsubscribe” or “opt out” link in the marketing e mails we send you.

If we process your personal data in reliance upon your consent, you can contact us at any time to withdraw your consent.

To exercise any of these rights, please contact us by using the contact details under the “Contact Information” heading below.

We will respond to such requests in accordance with the requirements of applicable data protection laws. Please note that in order to fulfil your request, we may need you to provide certain personal data to verify your identity. Depending upon applicable data protection and privacy law, individuals may also designate an authorized agent to exercise these rights on their behalf.

Various browsers (i.e., Internet Explorer, Chrome, Firefox, Edge, etc.) may allow a “do not track” (DNT) setting, which sends a signal to websites visited by an individual about their browser DNT setting. At this time, there is no general agreement on how companies, like iCIMS, should interpret DNT signals. Therefore, we do not currently commit to respond to DNT signals. We will continue to monitor developments around DNT browser technology and the implementation of a standard.

This Website may link to websites that are not owned or controlled by iCIMS. As such, this Privacy Notice does not apply to personal data collected on any third party site or by any third party application that may link to or be accessible from the Website. This Privacy Notice does not apply to personal data collected by Subscribers, our business partners, and other third parties or third party applications or services, even if this personal data is collected using our Website or at events.

The Website is not directed to or intended to be used by anyone under the age of 18. We do not knowingly collect personal data from anyone under the age of 18. If you are under 18, please do not attempt to fill out our forms or send any personal data about yourself to us. If we learn that we have collected personal data from a child under age 18, we will delete that data promptly.

iCIMS reserves the right to update or change this Privacy Notice from time to time. If we make material changes to this Privacy Notice, we will post it to our Website home page prior to or at the time of the change becoming effective. We ask that you review the Privacy Notice periodically to stay informed about any updates or changes that we may have made.

You can see when this Privacy Notice was last updated by checking the “Effective Date” displayed at the top of this Privacy Notice.