CANDIDATE PRIVACY NOTICE

1. PURPOSE OF THIS NOTICE

1.1  This Candidate Privacy Notice (the “Notice”) details the Personal Data (defined below) Hellman & Friedman LLC, a limited liability company incorporated in Delaware with a principal place of business at 415 Mission Street, Suite 5700, San Francisco, CA 94105, Hellman & Friedman LLP, a limited liability partnership incorporated in England and Wales with registered address The Brunel Building, 2 Canalside Walk, London, W2 1DG and/or any other entity in the Hellman & Friedman Group (as further defined below) or its portfolio companies (collectively “H&F”, the “Firm”, “we”, us” or our”) receives from you or third parties (such as recruiters, or your references or referees) in connection with your candidacy, how we process it and any of your rights in relation to it. This Notice also applies to Personal Data we collect regarding any candidate’s Restricted Persons (defined below), including but not limited to a candidate’s dependents and household members. This Notice and the rights contained in it apply to individuals located in Europe (“Europe Candidates”) and to individuals who are California residents (“California Candidates”), unless otherwise This Notice uses the terms Personal Information and Sensitive Personal Information to describe certain information practices applicable to California Candidates and Special Category Data, as applicable to Europe candidates.  The term Personal Data may be used as applied to both Europe and California Candidates.  If you are a Candidate or Restricted Person (defined below) located in a different location outside the United States, your Personal Data may be subject to similar laws as candidates located in Europe. 

1.2 This Notice takes into account the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 and the UK Data Privacy Act 2018, as amended from time to time (together, the “UK GDPR”), the Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on theprotection of natural persons with regard to the processing of personal data and on the free movement of such data and any relevant local legislation (the “EU GDPR” and together with UK GDPR, the “GDPR”) and theCalifornia Consumer Privacy Act of 2018 (the “CCPA”), each as may be amended from time to time.

1.3  Should you be unable to access this Notice and wish to receive a copy in an alternative format, please contact [email protected] or your recruiter.

2. FIRM AND DATA CONTROLLER CONTACT DETAILS

2.1     The Firm may be contacted at the below for all questions relating to this Notice

             E-mail:   [email protected] 
             Phone:     +1 (415) 788-5111
             Post:        415 Mission Street, Suite 5700, San Francisco, CA 94105

2.2  The Firm is the data controller of Europe Candidates’ Personal Data and their Restricted Persons (defined below) for the purposes of the Europe Candidates and Restricted Persons and Restricted Persons may contact the Firm at the below with respect to matters relating to its responsibilities as the data controller:

             E-mail:    [email protected] 
             Phone:   +44 (0)20 78395111
             Post:       Hellman & Friedman LLP, The Brunel Building, 2 Canalside Walk, London, W2 1DG

3. SCOPE

3.1 This Notice applies to Europe Candidates whose Personal Data (defined below) is processed by the Firm and to California Candidates whose Personal Information (defined below) is collected by the Firm and any of their Restricted Persons (defined below). Certain sections of this Notice apply only to Europe Candidates and their Restricted Persons (Sections 2.2, 3.2, 4.4 (b)(i) and 9) and certain sections apply only to California Candidatesand their Restricted Persons (Sections 3, 4.4 (b)(ii) and 10). All other sections apply to Europe and CaliforniaCandidates and their Restricted Persons.  If you are a Candidate located in a different location outside the United States, your Personal Data may be subject to similar laws as candidates located in Europe.  This Notice also applies to candidates’ Restricted Persons (defined below), including but not limited to a candidate’s dependents and household members whose Personal Data is processed by the Firm. 

3.2      Europe Candidates and their Restricted Persons:

  1. Data Subject” means 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, anidentification number, location data, an online identifier or to one or more factors specific to the physical,physiological, genetic, mental, economic, cultural or social identify of that natural
  2. In relation to the GDPR, “Personal Data” means any information relating to a Data Subject who is a Europe Candidate or Restricted Person (defined below).
  3. The Personal Data that we collect from you will be transferred to, and stored in, destinations outside ofyour country and the European Economic Area or the UK. The Personal Data that we collect from youwill be transferred to, stored at and otherwise processed in the United States pursuant to contractual or other legally permissible protections. You may contact us for more information about this.
  4. The GDPR also provides Europe Candidates and Restricted Persons (defined below) with certain rights, asoutlined at Section 9 (GDPR Rights of Europe Candidates and their Restricted Persons in Relation to Their Personal Data Held by the Firm)

3.3      California Candidates and their Restricted Persons:

In relation to the CCPA, “Personal Information” includes information that identifies, relates to, describes, iscapable of being associated with, or could reasonably be linked, directly or indirectly, with a particular CaliforniaCandidate or their Restricted Persons.

4. WHAT INFORMATION DOES THE FIRM COLLECT AND HOW IS IT USED?

4.1 We may receive and use the following Personal Data about you (and your Restricted Persons, where noted and as defined below) either directly from you, our affiliates or from other third parties in connection with yourapplication, and we may use it for the following purposes:

  1. Information you provide as part of your application.
    1. You will provide us information about you when you apply for or speak or correspond with us about a role. This may include some or all of the following:
      Identifiers — such as legal name and preferred name, so that we can properly address you, frequent travel or loyalty numbers, other unique ID numbers, like passport number and related information, where needed, so that we can book any travel for you;

      Contact Information — such as home and work address, phone number(s), email address(es), emergency contacts, so that we may communicate with you;

      Professional and Education information — such as qualifications, employment and educational history, previous career performance including compensation (to the extent permitted by Law, defined below), memberships in professional associations or other groups, references, language(s) spoken and other resumé or curriculum vitae data, to help us evaluate your candidacy ; where we have extended an offer, data with respect to onboarding preparation, such as tentative date of hire, personnel category, and full time or part-time status;

       Compliance information — citizenship, visa/right to work status, marital or family status and data from background checks (civil litigation, criminal records, regulatory matters, directorships, social media accounts, credit check information, confirmation of education and professional licenses), membership in professional bodies, details of current and historic business interests and directorships, political donations and investments including, once you receive an offer (and without limitation, name of broker, transaction and securities details, account holdings and balances, positions, amounts, account holder information and other account information), in respect of you or your spouse, registered domestic partner (or the equivalent), any child under the age of 18, any child under the age of 25 for whom you contribute materially to their support or any other relative residing with you (your “Restricted Persons”), to meet our or other Hellman Friedman Group member’s regulatory obligations, with Hellman Friedman Group defined below;

       Audio, electronic, visual and similar information ­— through mail, email, text messages (including through SMS, WhatsApp and similar channels), calls, voicemail and any other messages communicated through Firm devices to us or otherwise to the extent we have access (including through our Wi-Fi, as applicable), including for the purposes of monitoring or surveillance (where permitted by Law, as defined below); and any video or CCTV recordings, to meet our or other Hellman Friedman Group member’s regulatory compliance requirements to monitor and retain communications and for safety purposes, with Hellman Friedman Group defined below;

      Inferences — based on information concerning an individual to create a summary about you, for example, your skills and preferences, to evaluate your candidacy; and

      Voluntarily Disclosed Information — Any information about you that you disclose to us.

    2. We use this information to determine and validate your qualifications and suitability for a role and, where appliable, if you are a successful candidate, to create an employment record. This is necessary for our legitimate interests to properly evaluate candidates and to create employment records, to take steps at the request of candidates before offering them a position or entering an employment contract with them, as applicable, and on the basis of legal compliance.
  2. Special Categories of Data or Sensitive Personal Information you may provide.

    1. Europe Candidates may provide certain Special Category Personal Data under the GDPR or other local law, with your consent, such as race or ethnic origin, sexual orientation or disability status, for the purposes of equal opportunities monitoring and diversity disclosures, to the extent permitted or required by applicable Law (defined below). If you decide not to provide this data, your application will not be prejudiced. To the extent permitted by Law (defined below), you may be required to, or you may otherwise disclose certain health information, like vaccination status or other occupational health and safety-related information, food allergies, meal preferences, as applicable, should you attend an H&F or other event or visit an H&F office.
    2. California Candidates may provide the following types of Personal Information which are Sensitive Personal Information under the CCPA:

      Citizenship and Immigration status — As applicable for right to work and immigration matters.

      Government ID — Social Security or passport number (if we are arranging or reimbursing you for travel)

      Race and ethnicity — Racial or ethnic origin, which may be revealed by a Government ID, or when disclosed by you or a recruiter for you voluntarily.

      Health — vaccination-related information or other occupational health and safety-related information, disabilities, reasonable accommodation requests, food allergies, meal preferences, as applicable, should you attend an H&F or other event or visit an H&F office.

    3. We will use the minimum necessary of such Special Category Data or Sensitive Personal Information, as permitted or required by Law (defined below), for our legitimate interests (or, where required, on the basis of consent) to conduct equal opportunities and diversity monitoring and disclosures, for health and safety purposes or as otherwise requested or required by Law (defined below).

      If you fail to provide certain personal data to us on request, we may not be able to consider your candidacy for employment, make you an offer or employment or enter an employment contract with you, as applicable, and/or provide you with information you may have requested from us.

  3. Information from third parties.
    1. We receive information from third parties in connection with your application, such as references, referees, recruiters or recruitment platforms and organizations that provide background or sanctions checks (this will include right to work, criminal, civil and regulatory reference checks, sanctions lists, credit history, past work history, educational history, social media and professional licenses where applicable) some of which is Special Category Data. This may also include drugscreening, to the extent permitted by Law (defined below).
    2. We collect information from government agencies in connection with sanctions screening, a form of background check.
    3. We use this information to identify and evaluate you for positions, and to identify potential conflicts of interest. This is necessary for our legitimate interests to properly evaluate and contact candidates and to properly screen candidates.

5. DISCLOSURES OF CANDIDATES’ PERSONAL DATA TO THIRD PARTIES

5.1   We disclose your information with selected third parties. These categories of third parties include, for the following purposes:

  1. Members of the Hellman & Friedman Group (defined below), for the purposes set out in Section 4 (What Information Does the Firm Collect and How Is It Used?);
  2. Information Technology service providers that provide us with email, archiving, data management, data storage, archiving and general IT support services;
  3. Human Resources and Compliance service providers, including background check providers, to verify the information that you provided as part of your application and as permitted or required by Law (defined below), to assess your creditworthiness, to perform sanctions screenings and to determine any other regulatory, litigation or criminal history;
  4. if we are working with recruiting agencies, recruiters;
  5. event organizers, to host or organize recruiting events;
  6. consultants providing assessment services related to your candidacy;
  7. where applicable, travel agencies, hotels, airlines, and relocation services, to help interview or relocate you for a role;
  8. referees or references identified by you, to identify you and provide a reference;
  9. cloud and other data storage providers, to store the Personal Data you provide and for disaster recovery services, as well as destruction of information;
  10. depending on the role, our current and target portfolio companies, to assess your candidacy.
  11. other third parties (to defined or exercise a legal claim, in response to legal or judicial process, or for regulatory or investigation purposes).

Hellman & Friedman Group” means the Firm and any entity controlled by or under common control with the Firm, excluding any Portfolio Companies. “Portfolio Companies” means any portfolio companies in which fundsaffiliated with the Firm or any members of the Hellman & Friedman Group are invested or propose to invest.

5.2  We do not, and will not, sell or share Personal Information, as those terms are used in the CCPA, including on individuals under age 16.

6. CANDIDATES’ OBLIGATIONS IN RELATION TO PERSONAL DATA

6.1  It is important that you update us with respect to changes in your personal circumstances as soon as possibleby contacting your contact at the These include changes to the following:

  1. name;
  2. contact details (address, phone number(s), email address(es)); and
  3. Restricted Person information.

6.2 Further, it is your responsibility to inform your Restricted Persons, referees and references about the processing of their Personal Data pursuant to this Notice and to confirm that they have given their permission for such processing.

7. SECURITY OF PERSONAL DATA

7.1 Unfortunately, the transmission of information via the internet is not completely secure. Although we will take commercially reasonable precautions to protect your Personal Data, we cannot guarantee the security of yourinformation transmitted through electronic means; any transmission is at your own Once we have receivedyour information, we will take appropriate technical and organizational measures to safeguard your Personal Data against loss, theft and unauthorized use, access or modification.

8. PERSONAL DATA RETENTION

8.1 Your Personal Data will be retained in accordance with the policies and procedures of the Firm adopted from timeto time, including for effective management of firm practices (“Policies”) and (a) as required by law, regulation,legal or judicial process or audit, decision of a court or arbitral tribunal, decision of a governmental authority with relevant powers, or by the rules of applicable stock exchange or recognized market place, or by a regulator,bank examiner or self-regulatory organization or pursuant to mandatory ethics rules applicable to the Firm or itsaffiliates (collectively, “Law”) or (b) as reasonably required in relation to any claim or investigation pursuant toany Law and/or any matter which may lead to such a claim or investigation (a “Claim or Investigation”).  We will only retain your Personal Data for as long as reasonably necessary to fulfill the purposes under the “How We Use Personal Data” section above. Exceptions to this are where:

  1. The law requires us to retain your personal data for a longer period, or delete it sooner; or
  2. You exercise a legal right, where applicable, to have your Personal Data erased and we do not need to retain it in connection with any of the reasons permitted or required by Law.
  3.  

9.  RIGHTS UNDER GDPR AND SIMILAR INTERNATIONAL LAWS

9.1  Right to Access: Depending on your location, you may have the right to ask the Firm to access the Personal Data we hold about you and be provided with certain information about how we use your Personal Data and who we disclose it to.

9.2 Right to Correct: You may also have the right to ask us to correct your Personal Data where it is inaccurate or incomplete.

9.3 Right to Data Portability: Where you have provided your Personal Data to us in connection with our consideration of your candidacy, you may have the right to ask us for a copy of this data in a structured, machine-readable format and to ask us to share (port) this data to another data controller.

9.4  Right to Delete: In certain circumstances, you may have the right to ask us to delete the Personal Data we hold about you:

  1. where you believe that it is no longer necessary for us to hold your Personal Data (for example, when you are no longer in employment with us, subject to any requirement for us to retain your data pursuant to Law, our Policies or as reasonably required in relation to any Claim or Investigation);
  2. where we are processing your Personal Data based on our legitimate interests and you object to suchprocessing, and we cannot demonstrate an overriding legitimate ground for the processing; or
  3. where you believe the Personal Data we hold about you is being unlawfully processed by us.

9.5   Right to Restrict Certain Processing: In certain circumstances, you may have the right to ask us to restrict (stop any active) processing of your Personal Data:

  1. where you believe the Personal Data we hold about you is inaccurate and while we verify accuracy;
  2. where we want to erase your Personal Data as the processing is unlawful, but you want us to continue to store it;
  3. where we no longer need your Personal Data for the purposes of our processing, but you require us toretain the data for the establishment, exercise or defense of legal claims; or
  4. where you have objected to us processing your Personal Data based on our legitimate interests and we are considering your

9.6  Right to Object: You may have the right to object to our processing of your Personal Data based on our legitimate interests and we will no longer process your Personal Data unless we can demonstrate an overriding legitimate ground.

9.7  Right to Contest Decision-making Based Solely on Automated Processing: While you may contest a decision made about you based solely on automated processing, the Firm does not currently use automated decision making related to your candidacy.  Accordingly, this right is inapplicable. ‘

9.8  Right to Withdraw Consent: Where you have provided your consent to us processing your Personal Information, you may withdraw your consent, but this does not affect the validity of processing carried out prior to your withdrawal.

9.9  How to Exercise these Rights: To exercise any of the above rights, please contact [email protected]. In addition, you have the right to complain to the Information Commissioner’s Office or other applicable data protection supervisory authority, depending on your location.

9.10      Limitations: Please note that these rights are limited, for example, where fulfilling your request would adversely affect other individuals or the interests of any member of the Hellman & Friedman Group (including their proprietary information, trade secrets or intellectual property), where there are overriding public interest reasons or where we are required by Law, Policies or in relation to any Claim or Investigation to retain your Personal Data. 

10. RIGHTS UNDER THE CCPA

10.1      Request to Know:

If you are a California resident, you have the right to request that we disclose Personal Information that we have collected, sold or shared about you. Subject to verification and any limitations under the CCPA, we will disclose the following:

  1. The categories of personal information we have collected;
  2. The categories of sources from which the personal information was collected;
  3. The business or commercial purpose for which we collected the personal information;
  4. The categories of third parties with whom we disclose personal information; and
  5. Specific pieces of personal information that we have collected about you.

10.2     Right to Delete: If you are a California resident, you have the right to delete Personal Information that we collected from you, subject to exceptions.  

10.3     Right to Correct: If you are a California resident, you have the right to request that we correct inaccurate Personal Information that we maintain about you.

10.4     Right to Limit Use of Sensitive Personal Information: If you are a California resident, you have the right to request that we limit the use and disclosure of your Sensitive Personal Information. We do not use or disclose your Sensitive Personal Information other than as permitted for purposes specified in section 7027, subsection (l) of the CCPA.  Accordingly, this right is inapplicable.

10.5     Right to opt-out of sale/sharing: If you are a California resident, you have the right to opt out of the sale/sharing of your Personal Information.  We do not sell or share your Personal Information with third parties as those terms are used in section 7013, subsection (g) of the CCPA.  Accordingly, this right is inapplicable.

10.6     Equal Treatment: If you are a California resident, you have the right not to be retaliated against for the exercise of your CCPA rights

10.7     How to Exercise these Rights: To exercise any of the above rights, you may submit a request by:

  1. Calling us toll-free at +1 (877) 215-0023;
  2. Visiting https://hf.com/your-california-consumer-privacy-act-rights/; or
  3. Emailing us at [email protected].

10.8   We will verify your identity prior to addressing or fulfilling a request made pursuant to the CCPA. The request must provide sufficient information that allows us to reasonably verify that you are the individual about whom we hold the Personal Information.

10.9  Only you or someone legally authorized to act on your behalf, may make a verifiable request under the CCPA.  Any such authorization must be in accordance with California Civil Code section 1633.1 et seq., the Uniform Electronic Transactions Act. To act on such request, your authorized agent must provide sufficient information that allows us to reasonably verify that they have been authorized by you to act on your behalf.

11. CHANGES TO THIS NOTICE

We may update this Notice from time to time. This Notice was last updated on October 11, 2024.   Any updated Notice will be available at hf.com.