Nasdaq, Inc., and its global subsidiaries and affiliates including, but not limited to eVestment, Inc., and Solovis, Inc., and their respective subsidiaries and affiliates (referred to as “Nasdaq” throughout this notice) provides this Applicant Data Protection Notice to explain our practices regarding the collection, use, and other processing of certain individually identifiable information about job applicants or other potential employees ("Applicant Data"), in connection with recruiting and hiring activities.

Nasdaq appreciates the trust you are showing in our company in providing us your personal data.  Consistent with our corporate commitment to Integrity and our privacy practices, we will only use Applicant Data for the purposes described herein.  We encourage you to contact us if you have any questions about how Applicant Data is processed either by contacting the individual person on our Recruiting Team with whom you are working or contacting our Privacy Team at privacy@nasdaq.com.
 

I. CATEGORIES OF APPLICANT DATA

Nasdaq collects, uses, and otherwise processes the following categories of Applicant Data in consideration of your potential employment at Nasdaq:

• Contact information, such as personal and business address, and personal and business phone/fax numbers and email addresses;
• Personal information, such as name, date of birth, nationality, gender, and country of birth; and
• Employment qualifications information, such as certificates and degrees obtained, languages spoken and skills, software experience, professional memberships, summaries of strengths and technical areas of expertise, pre-Company work history information (previous employers and positions held, dates, locations, supervisors, responsibilities, salary), resume and cover letter information, references and information obtained from them, and related background check information (to the extent permitted, and in accordance with applicable law).

We may also collect information from cookies or other tags placed on your device from other websites (e.g., job boards) in order to identify the effectiveness of our recruiting campaigns. This information is not used at the individually identifiable level to track individual job applicants or create profiles, but is used in aggregate to understand how best to reach potential job applicants. [We may also collect information related to whether emails sent to you have been opened, in order to better understand the effectiveness of our communications, but this information is not used at the individually identifiable level to track individual job applicants or create profiles.] We refer to these types of data collectively as "Tag Information" in this Applicant Data Protection Notice.

Applicant Data will be collected either directly from you, or from authorized third parties (e.g., people you have named as your references, previous employers, schools, or public authorities) or public resources, subject to the requirements of applicable law.

The provision of Applicant Data as described in this Applicant Data Protection Notice is partly a statutory requirement, partly a contractual requirement under the terms of our recruiting website, and partly a requirement to carry out the recruitment and hiring process with you. In general, you are required to provide the Applicant Data, except in limited instances when we indicate that certain information is voluntary. Not providing your Applicant Data may prevent Nasdaq from carrying out recruiting and hiring activities that impact your potential employment with us.
 

II. PURPOSES AND BASIS FOR PROCESSING APPLICANT DATA

Nasdaq will process Applicant Data for the following purposes:

Nasdaq relies on the following legal grounds for the collection, use, and other processing of Applicant Data:

Applicant Data

• Taking steps at your request (i.e., administering your application, prior to entering into a potential employment contract with you);
• Performance of the contract with you for the usage of our recruiting website;
• Compliance with legal obligations, in particular in the area of labor and employment law, social security and social protection law, data protection law, tax law, and corporate compliance law;
• Consent, as permitted by applicable law; and
• Legitimate interest of Nasdaq or other third parties (e.g., existing or potential suppliers, customers,  governmental bodies, or courts) where the legitimate interest could be in particular internal information sharing, and customer relationship management activities, or potential merger and acquisition activities.
   

III. CATEGORIES OF RECIPIENTS

Nasdaq may transfer your Applicant Data as necessary, to third parties for the processing purposes described above as follows:

• Within the affiliated group: We share your Applicant Data with our ultimate parent company, Nasdaq, Inc. in the United States and its subsidiaries as necessary for the purposes identified above, and in particular to conduct recruiting and hiring activities, and to respond to and comply with requests and legal demands;
• With certain acquiring or acquired entities: If Nasdaq business for which you submitted your Applicant Data, in relation to your interest for an employment position, is sold or transferred in whole or in part or if Nasdaq is acquiring and integrating another entity into the Nasdaq entity or business for which you applied for an employment position, your Applicant Data may be transferred to the other entity prior to the transaction (e.g., during the diligence phase) or after the transaction, subject to any rights provided by applicable law, including the laws of the jurisdictions where the other entity is located; and
• With certain Data Processors. Certain third party service providers such as IT support or HR support providers, whether affiliated or unaffiliated, will receive your Applicant Data to process such data under appropriate instructions ("Data Processors") as necessary for the processing purposes, in particular to conduct recruiting and hiring activities, comply with applicable laws and employment-related requirements, and other activities. These Data Processors will be subject to contractual obligations to implement appropriate technical and organizational security measures to safeguard the Applicant Data, and to process the Applicant Data only as instructed.

The recipients identified above may be located inside or outside the European Economic Area ("EEA"). Recipients outside the EEA might be located in countries that are not deemed by the European Commission to provide an adequate level of protection for personal data from an EEA data protection law perspective. Nasdaq takes all necessary measures to ensure that transfers out of the EEA are adequately protected as required by applicable data protection law. With respect to transfers to recipients located in countries not deemed by the European Commission to provide an adequate level of data protection, Nasdaq bases the transfer on appropriate safeguards under Article 46 of the General Data Protection Regulation (GDPR), such as the European standard contractual clauses, approved codes of conduct together with binding and enforceable commitments of the recipient, or approved certification mechanisms together with binding and enforceable commitments of the recipient.

Any access to your Applicant Data is restricted to those individuals who have a need to receive or access Applicant Data in order to fulfill their job responsibilities. Nasdaq may also disclose your Applicant Data as required or permitted by applicable law to professional advisors, governmental authorities and courts, external advisors, and similar third parties.
 

IV. RETENTION PERIOD

Your Applicant Data is stored by Nasdaq, and/or our service providers, strictly to the extent necessary for the performance of our obligations and strictly for the time necessary to achieve the purposes for which the Applicant Data is collected, in accordance with applicable data protection laws. Nasdaq will generally retain your Applicant Data in accordance with applicable retention policies and procedures, the periods of retention under which are determined by taking into account the time necessary to achieve the purposes for which the personal data is processed, unless retention for a longer period is warranted due to a legal requirement, including the need to support or defend a legal claim that is not yet barred by the applicable statute of limitations.

If you accept an offer from Nasdaq, your Applicant Data will be retained for the duration of your employment with Nasdaq and as necessary in accordance with applicable law and applicable retention policies and procedures.

Where you consent to Nasdaq being able to consider you for employment against future opportunities other than the one(s) for which you originally applied and/or were being considered for, we will keep your Applicant Data on file for such purposes.  You may withdraw this consent at any time by contacting the Recruiting Team in writing (email acceptable).
 

V. YOUR RIGHTS

If you have declared your consent regarding certain types of processing activities (for example, via a separate specific consent form), you can withdraw this consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal.

Pursuant to applicable data protection law, you also have the right to: (1) request access to your Applicant Data; (2) request rectification of your Applicant Data; (3) request erasure of your Applicant Data; (4) request restriction of processing of your Applicant Data; (5) request data portability of your Applicant Data; and/or (6) object to the processing of your Applicant Data. Please note that these aforementioned rights might be limited under the applicable national data protection law.

(i) Right of access: Under certain circumstances, you have the right to obtain from us confirmation as to whether or not Applicant Data about you is processed, and, where that is the case, to request access to such Applicant Data. The access information includes, inter alia, the purposes of the processing, the categories of Applicant Data, the recipients or categories of recipients to whom the Applicant Data has been or will be disclosed, the sources of the Applicant Data, the duration of retention of the Applicant Data, and the technical security measures put in place to safeguard the Applicant Data in case of transfer outside the EEA. However, this is not an absolute right and the interests of other individuals may restrict your right of access. Most information is set out in this Applicant Data Protection Notice, but supplementary information will be provided where necessary. In addition to access, you have the right to obtain a copy of the Applicant Data. Note that, for additional copies requested by you, we may charge a reasonable fee based on administrative costs.

(ii) Right to rectification: Under certain circumstances, you have the right to obtain from us the rectification (i.e., correction) of inaccurate Applicant Data about you. Depending on the purposes of the processing, you have the right to have incomplete Applicant Data completed, including by means of providing a supplementary statement.

(iii) Right to erasure (right to be forgotten): Under certain circumstances, you have the right to obtain from us the erasure of Applicant Data about you. In such cases, we will erase, or render permanently unintelligible, such Applicant Data.

(iv) Right to restriction of processing: Under certain circumstances, you have the right to obtain from us the restriction of processing of your Applicant Data. In this case, the respective data will be marked and may only be processed by us for certain purposes. However, as Nasdaq processes and uses your Applicant Data primarily for purposes of carrying out a contractual employment relationship with you, Nasdaq will in principle have a legitimate interest for the processing which will override your restriction request, unless the restriction request relates to marketing activities (which generally do not apply in the employment context).

(v) Right to data portability: Under certain circumstances, you have the right to receive the Applicant Data about you that you have provided to us, in a structured, commonly used and machine-readable format so you can transmit this Applicant Data to another entity.

(vi) Right to objection: Under certain circumstances, you have the right to object, on grounds relating to your particular situation, to the processing of your Applicant Data by us. Where such right applies, we will no longer process the relevant Applicant Data. This is not an absolute right and does not apply in certain situations, such as when processing is necessary to perform the employment contract, to comply with applicable EU or member state law, or to defend legal claims.

You also have the right to lodge a complaint with the competent data protection supervisory authority.
 

VI. QUESTIONS

If you have any questions about this Applicant Data Protection Notice, or if you would like to request rights or a copy of the appropriate safeguards concerning your Applicant Data, you should contact our Privacy Team at privacy@nasdaq.com or by postal mail at:

Office of General Counsel - Privacy Team
Nasdaq, Inc.
805 King Farm Blvd
First Floor
Rockville, MD 20850

or

Office of General Counsel - Stockholm Office
Tullvaktsvägen 15,
10578 Stockholm
Sweden

In addition, Nasdaq's Nordic and Baltic Regulated Entities* have appointed Caroline Olstedt Carlström as their Data Protection Officer.  If you are an applicant for employment with any such entity, you may also contact the Data Protection Officer at DataProtectionOfficer@nasdaq.com or by postal mail at:

Advokatfirman Lindahl KB,
Box 1065,
101 39 Stockholm,
Sweden
Attn: Caroline Olstedt Carlström - Nasdaq Data Protection Officer

* Regulated Entities that have appointed a Data Protection Officer are European exchanges
(Nasdaq Copenhagen A/S, Nasdaq Helsinki Ltd, Nasdaq Iceland hf., Nasdaq Oslo A/S, Nasdaq Riga AS, Nasdaq Stockholm AB, Nasdaq Tallinn AS and AB Nasdaq Vilnius), the clearinghouse Nasdaq Clearing AB, central shares depositories (Nasdaq CSD SE and Nasdaq CSD Iceland hf.), our Estonian pension administrator company (AB Pensionkeskus), and the broker-dealer/investment firm Nasdaq Broker Services AB.

With respect to Personal Information processing subject to European Union jurisdiction, in addition to contacting
our business contacts and Data Protection Officer (for our EEA Regulated Businesses), you may also contact a data
protection supervisory authority. Within Europe, Nasdaq's headquarters is located in Sweden, making the
responsible data protection supervisory authority The Swedish Data Protection Authority. Contact details for the
authority are:

Telefon: 08-657 61 00
E-post: datainspektionen@datainspektionen.se
Fax: 08-652 86 52

Postadress:
Datainspektionen
Box 8114
104 20 Stockholm