Recruitment and Applicant Privacy Policy

This privacy policy (“Policy”) describes how Adobe Inc. and its subsidiaries (“Adobe”) collect and process personal data from applicants and prospective employees (“Applicants and Candidates” or “you”) as part of the recruitment and job application process. This policy also includes a description of your data protection rights. This policy applies to our websites, forms, communications, and materials that display or reference this Policy, but it does not apply to any products, services, websites, or other materials that display or reference a different privacy notice or policy.

Personal Data We Collect

As part of the Adobe recruitment and application process, Adobe collects the following categories of personal data:

• Identifiers and contact information: including name, address, telephone number, email, and home address;

• Demographic information: including date of birth, gender, and signature;

• Administrative, professional, or employment-related information: including resume or CV, cover letter, previous work or military experience, professional training, certifications and registrations, language capabilities, academic and education background and qualifications, transcripts, information provided for and results of background checks (which may include public social media data), reference contact information, position preferences, work permit status (such as immigrations, residency, and related information), willingness to relocate, travel information (such as loyalty programs numbers; dates and length of travel; hotel names and locations; and travel routes and departures, stops, and destination points), desired salary, salary history (where permitted by law), and interests and aspirations;

• Internet or other electronic network activity: device and log-in Information, including log-in details and password, IP address and browser information to keep you logged into the Adobe Careers website, recording interactions with our website, remembering your preferences, and saving your changes to an in-process application (collected through Adobe and our provider’s cookies and similar technologies or by Adobe’s servers when you are logged into the website);

• Geolocation data: including your approximate location based on your IP address;

• Audio, electronic, visual, or similar information: including facial images and voice information such as from video or voice recordings and photos;

• Content and communications: including assessment responses, communications related to recruitment activities (e.g., recorded and stored contents of your communications with us via our website, chat features, phone calls, and other channels), and any documents or other files you provide to Adobe in connection with the recruitment and application process. If you send us email messages or other communications, we may collect and retain those communications.

• Inferences drawn from any of the information identified in this section to create a profile about you reflecting certain preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes;

• For Applicants and Candidates in California, characteristics of protected classifications under U.S. federal or state law, as described below as “sensitive information”

• Sensitive information (to the extent permitted or required by local law or voluntarily provided by you) including:
  • government issued identifiers, such as driver’s license information, state or national identification information, or student identification;
  • account log-in in combination with a security or access code, password, or credentials that allow access to an account;
  • racial or ethnic origin;
  • information related to health (e.g., disability information) or religion, such as information you may include as part of an accommodation request;
  • information relating to sex life or sexual orientation, or gender identity;
  • age; and/or
  • military or veteran status.

We also obtain personal data from other sources. These sources include:

• Data brokers from which we purchase demographic data to supplement the data we collect;
• Applications and services you choose to connect with on our recruiting platforms or that otherwise make users’ information available to others, such as LinkedIn Recruiter and social networks;
• Service providers, including those that help us effectively identify top talent for each role, travel partners, background check services, and website analytics and measurement providers;
• Recruiters, persons who you have named as referees, and partners with which we engage in joint recruiting activities; and
• Publicly-available sources or other data in the public domain.

Where we require personal data to comply with legal or contractual obligations, the provision of such data is mandatory. If such data is not provided, then we will not be able to complete your recruitment process, or to meet obligations placed on us. In all other cases, provision of requested personal data is optional.

Our Use and Retention of Personal Data

Adobe collects and processes each of the categories of personal data described above to administer and carry out the recruitment and hiring process, including for human resources purposes, and for operational and business, safety and security purposes, and for the lawful bases described in this policy and described below:

• Contractual necessity: As required to take steps which are necessary before Adobe can enter into an employment contract with you (if applicable) and to reimburse you for any agreed expenses incurred in the recruitment and application process.
• For purposes which are in Adobe’s legitimate interests (if appliable), as further listed here, including:
  • to make informed decisions on recruitment and assess your suitability for the role (including background checks as permitted by local law, about which we will provide more information before they are carried out);
  • using automated systems to analyze your application information using techniques such as machine learning in order to select and retain candidates, as well as to improve our recruitment processes and the applicant experience (where your consent is not required);
  • to manage, measure, analyze, monitor, protect, and improve our website, systems, processes, assets, and resources, including managing and protecting unauthorized access and use of our data, devices, systems, and infrastructure; and protecting our systems and network from intrusions;
  • to manage, measure, analyze, monitor, protect, and improve campus, parking, buildings, office space, conference rooms, facilities, catering and café services, including monitoring and administering building occupancy and campus parking and transportation; operating and monitoring physical security systems, such as CCTV, key card entry systems, and guest logs; registering personal vehicles and logging exit and entry times; and emergency notification services;
  • using cookies and similar technologies on our websites and services , to track performance and your interaction with the website, develop inferences, combat fraud, and fulfil other legitimate purposes (unless we rely on your consent for this). We and/or our providers also disclose the data we collect or infer with other providers for these purposes as described in the “Disclosures of Personal Data” section below.
  • to host, administer, and communicate information related to Adobe’s recruitment activities, which may include recording and storing the contents of your communications with us via our website, chat features, phone calls, and other channels
  • to keep you in mind for future roles (unless we rely on your consent for this); to answer your queries; improve our recruitment processes and activities as well as communicate with you about future career opportunities at Adobe.
    
• Compliance with legal obligations: As required to comply with applicable laws and protect our legal rights including, but not limited to, in connection with legal claims, (including disclosure of information in connection with legal process or litigation). If you are a successful candidate for employment, this will include verifying whether you have the right to work in the country in which you are applying for a job with Adobe and checking whether the information you have provided in the application is correct and carrying out other background checks required by or otherwise permitted by local law. We will provide more information about these checks before they are carried out.
• Consent: Where required by applicable law, we will seek your consent for our collection and use of personal data as explained on the Career Opportunities website. You can withdraw your consent at any time. In countries where legitimate interest is not recognized under applicable law, our processing activities described above on the basis of legitimate interests will be based on your consent.

Adobe will retain personal data during the recruitment and application process in accordance with our legal obligations and for as long as we have a business or legal need to retain it. Upon completion of the recruitment and application process, an Applicant or Candidate who does not enter employment with Adobe can request that we schedule their personal data for deletion . Certain information will be retained as permitted or required by law, such as to meet our record keeping obligations under applicable employment or other law.

If you become an Adobe employee, personal data that we collect as part of the recruitment and application process, including from LinkedIn and background checks, will become a part of your employee file and may be used later for the management of the employment relationship. Retention of such information will be governed by the Adobe Employee Privacy Policy.

Protection of Personal Data

Adobe uses appropriate and reasonable technical, physical, and organizational measures designed to protect personal data against accidental or unlawful destruction, accidental loss or alteration, or unauthorized disclosure or access.

Disclosure of Personal Data

Adobe discloses the personal data described in this Policy for its own business purposes to the following recipients:

• Affiliates and Subsidiaries. Adobe transfers and discloses personal data between Adobe group companies, its affiliates and contractors, in the US and other countries, including outside your country of residence, and will be stored and processed manually and electronically through global systems and tools for the purposes above.
• Service Providers. Personal data may be disclosed with companies that help us run our business by processing personal data on behalf of Adobe or its Applicants and Candidates for the purposes disclosed in this Policy. Such companies include, but are not limited to, data storage, machine learning services, user interaction technology providers (including chatbots that may record or store communications), analytics providers, background check services, fraud monitoring and prevention, recruiting services, email and social media, IT service, travel agencies and travel service providers.
• Analytics Providers. Personal data may be disclosed to analytics providers who act on our behalf to collect personal data through our website including identifiers and device information (such as cookie IDs, device IDs, and IP address), geolocation data, usage data, and inferences based on and associated with that data.
• Corporate Transactions. We may also disclose and transfer personal data as part of a corporate transaction such as a merger, transfer, divestiture, or sale of all or a portion of our business or assets.
• Legal and Law Enforcement. We will also access, transfer, disclose, and preserve personal data when we believe that doing so is necessary to:
  • comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies;
  • operate and maintain the security of our network and systems, including to detect, prevent, or stop an attack on our computer systems or networks;
  • protect the rights or property of ourselves or others, including enforcing our agreements, terms, and policies; or
  • act in urgent circumstances such as protecting the health or personal safety of an Applicant, Candidate, employee, agent, customer, user of Adobe’s services, or member of the public.

We may also disclose personal data where we have your consent. Finally, we may disclose de-identified information in accordance with applicable law.

Your Privacy Rights

According to applicable laws, you may have rights with respect to your personal data, such as:

• to access personal data that relates to you;
• to request, correction, erasure or restriction of our processing of personal data that relates to you or to ask us to pass data to another organization
• to object to the processing of such data and to request an explanation about the processing;
• to withdraw any consent you have provided (without affecting the lawfulness of processing before your consent was withdrawn);
• to provide instructions regarding the management of your personal data after your death.

Additional rights for California based Applicants and Candidates

In addition to the right to access, request correction and deletion of personal data that relates to you (as described above), you have the right:

• to opt-out from the “sale” or “share” of personal data as defined by the CCPA (California Consumer Privacy Act). Note that we do not “sell” or “share” personal data as defined by the CCPA. And, we do not knowingly sell or share the personal data of minors under 16 years of age;
• to limit our use and disclosure of sensitive personal data for the purpose of inferring individual characteristics. Note that we use and disclose sensitive personal data for the limited purposes permitted under CCPA and not for the purposes of inferring characteristics about you;
• to designate an authorized agent to exercise some of your rights; however, to help protect the security of your personal data, the authorized agent must follow the same authentication procedures that are required if you exercise your rights without using an agent. Adobe will verify requests made through authorized agents to help ensure the safety of your account and to comply with our policies and procedures;
• to not be discriminated against for exercising your rights set out in the CCPA;
• to receive notice of our practices at or before collection of personal data;
• to exercise the rights described in this Policy free of charge or penalty, but we may limit the number of requests you make or charge reasonable fees as legally permitted.

Further, to provide access to, correct, or delete specific pieces of personal data we will need to verify your identity to the degree of certainty required by law. We will verify requests by asking you to send it from the email address associated with your application or require you to provide other information necessary to permit us to verify your identity.

If you would like to exercise these rights, or have any questions or would like additional information about your personal data, please refer to the Adobe Inc. Career Search and Resume Submission Policy or contact the Employee Resource Centre by email at ERC@adobe.com at any time. You can also contact Adobe's data protection officer. Details of Adobe's data protection officers are available at https://www.adobe.com/privacy/adobe-dpo.html.

If you have unresolved concerns, you may also have the right to complain to relevant supervisory authorities or, where applicable, file a lawsuit with the court in accordance with applicable law, but we encourage you to first contact us with any questions or concerns.

Personal Data Transfers

Certain countries restrict transfers of personal data to other countries. Adobe carries out these transfers in compliance with applicable law, including with consent where the law requires. Where Adobe transfers EU, EEA, UK, or Swiss personal data to a third country not deemed adequate by the European Commission, we rely on legal mechanisms approved by the European Commission, including standard contractual clauses, binding corporate rules, and consent. And, where required by other countries, we may also rely on the use of the country-specific transfer mechanisms such as standard contracts.

United Kingdom, Switzerland, European Union and European Economic Area, and China Applicants and Candidates

For Applicants and Candidates based in the UK, Switzerland, EU, EEA, and China:

If you have unresolved concerns you also have the right to complain to data protection authorities in the country where you live or work, or where you consider a breach of data protection law has occurred but we encourage you to first contact us with any questions or concerns. Applicants from the European Union and European Economic Area can find the contact information for your country's data protection authority on the following link: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

The specific data controller for your personal data we collect, use, and disclose as part of the recruitment and application process will depend on the country, recruitment activity, and location of the role and the Adobe subsidiary which is performing the recruitment activity or offering the role, and are as follows.