Talent Acquisition Privacy Policy

Last Updated: [2.15.2019]

Glaukos Corporation values your trust and is committed to the responsible management, use, and protection of personal information. This Talent Acquisition Privacy Policy (“Policy”) describes our practices in connection with the information that Glaukos, located in the United States of America, collects from you online through our Careers Site website or offline in connection with your application for a job with us or one of our international subsidiaries.

Personal Information We Collect

INFORMATION YOU PROVIDE

We collect various types of information from you in connection with your application. The information we collect includes:

• Name, address, telephone number, e-mail address, and other contact information;
• Username and password;
• Work authorization status;
• CV, résumé, cover letter, previous work experience and education information;
• Skills;
• Professional and other work-related licenses, permits and certifications held;
• Information relating to references; and
• Any other information you elect to provide to us (e.g., employment preferences, willingness to relocate, current salary, desired salary, awards or professional memberships).

In certain cases, we will ask questions about race/ethnic origin, gender, veteran status and disability of our applicants, for the monitoring of equal opportunity compliance. We may also inquire about criminal records, where permitted by applicable law. Except as specifically requested or legally required, we ask that you avoid submitting information which may qualify as sensitive information under applicable law. Sensitive information includes data about race, religion, ethnicity, nationality or national origin, age, gender identity, sex life or practices or sexual orientation, marital status, medical or health information (including disability status), genetic or biometric information, biometric templates, political or philosophical beliefs, political party or trade union membership, background check information, judicial data such as criminal records or information on other judicial or administrative proceedings.

Any information you submit through the Careers Site must be true, complete, and not misleading. Purposely submitting inaccurate, incomplete, or misleading information may lead to rejection of your application during the application process or, if identified after employed with the company, disciplinary action including immediate termination of employment. In addition, it is your responsibility to ensure that information you submit does not violate any third party’s rights.

If you provide us with personal information of a reference or any other individual as part of your application, it is your responsibility to obtain consent from that individual prior to providing the information to us.

INFORMATION FROM OTHER SOURCES

For the purpose of background check reports in connection with your application, and as permitted by applicable law, Glaukos will obtain information about you from other sources:

Other sources may include, without limitation:

• Your references;
• Prior employers;
• Educational institutions you attended.

Use of Information

We collect and process information about you for one or more of these reasons:

• Because you voluntarily provide this information and consent for us to process it;
• Because this information is necessary to take steps at your request prior to your employment;
• Because this information is of particular importance to us, and we have a specific legitimate interest under law to process it;
• To comply with a legal obligation; or
• Where necessary to protect the vital interests of any person.

Where the collection or processing is based on your consent, you may withdraw your consent at any time to the extent permitted by applicable law.

The information that you submit on the Careers Site will be used for Glaukos’ global personnel recruitment, management, and planning purposes, as permitted by applicable law:

• To process your application – We will engage in these activities to manage our prospective contractual relationship with you, based on our legitimate interests;
• To assess your capabilities and qualifications for a job. We will engage in these activities to manage our prospective contractual relationship with you, based on our legitimate interests;
• To conduct reference checks. We will engage in these activities to comply with a legal obligation, as applicable, or based on our legitimate interests;
• To respond to your inquiries and communicate with you about your application, and to send you information regarding the Careers Site and changes to our terms and policies. We will engage in these activities to manage our prospective contractual relationship with you;
• To comply with or monitor compliance with any applicable law or regulation. We will engage in these activities to comply with legal obligations;
• To conduct background checks if we offer you a position. We will engage in these activities to comply with a legal obligation, where applicable, or based on our legitimate interests; and
• To preserve other legitimate interests, for example, for Glaukos’ administrative purposes, aggregate management reporting, internal training, and as generally required to conduct our business and that of our subsidiaries.

The information about you will be added to our Careers system(s) or database(s), and can be retained and used to consider you for opportunities at Glaukos and its subsidiaries other than the one(s) for which you apply. If you do not wish us to do this, please contact us at hr@glaukos.com. If we hire you, personal information we collect in connection with your application may be incorporated into our human resources system and used to manage the new-hire process; any such information can become part of your employee file and used for other employment-related purposes.

Providing personal information to us through the Careers Site is voluntary, but necessary for the recruiting process. If you do not provide sufficient information, Glaukos Corporation may be unable to consider your employment application or, if you are hired, your subsequent promotion, transfer or relocation.

Disclosure and Transfer of Information

Glaukos shares personal information of candidates with its subsidiaries that are involved in evaluating candidates for a given position.

We will limit access to such personal information to personnel that need to know the information for the purposes described in this Policy, including personnel in the recruiting, human resources, and information technology departments, and in the department responsible for the position for which you are applying.

Glaukos also shares personal information with approved third-party service providers to facilitate services they provide to us, including hosting and operating the Careers Site, recruiting assistance, and background check processing.

If you disclose your personal information to us, we may transfer your personal information to other countries, including, without limitation, any other country in which we or our service providers have or may in the future have operations. If you are located in the European Economic Area (the “EEA”), this may include countries outside of the EEA.

Other Uses and Disclosures of Information

We also use and disclose your personal information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

• To comply with applicable law.
  • This can include laws outside your country of residence.
• To respond to requests from public and government authorities.
  • These can include authorities outside your country of residence.
• To cooperate with law enforcement.
  • For example, when we receive law enforcement requests and orders.
• For other legal reasons.
  • To enforce our terms and conditions; and
  • To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
• In connection with a sale or business transaction.
  • We have a legitimate interest in disclosing or transferring your personal information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

Data Retention

We will retain Personal Information for the period necessary to fulfill the purposes outlined in this Policy.

The criteria used to determine our retention periods may include one or more of the following: as long as we have an ongoing relationship with you; as required by a legal obligation to which we are subject; and as advisable in light of our legal position (such as with respect to applicable statutes of limitations, litigation, audits, or regulatory investigations).

Passive Information Collection: Cookies and Similar Technology

We and our approved service providers use “cookies” and similar technologies on the Careers Site. Please see our Cookie Policy for more information.

Choices and Access

If you register on the Careers Site, you may access, review, and change your personal information stored therein by logging into the Careers Site and updating your account information, as appropriate. The updated profile will be used as the default the next time you apply for a job using your account online. To change personal information that you have already submitted for consideration for a specific position, please update your profile and resubmit your application for that position. We encourage you to promptly update your personal information if it changes or is inaccurate.

You may, where permitted by applicable law, request to review, access, correct, update, restrict, suppress, or delete your personal information; request that we cease using your personal information, as permitted by applicable law; or request a copy or portability of your personal information. You may make your request by contacting us as indicated below in the “Contact Us” section. We will respond to your request consistent with applicable law.

If you make such a request, please make clear what personal information you would like to access or have changed, whether you would like to have personal information that you have provided to us suppressed from our database, or otherwise let us know what limitations you would like to put on our use of your personal information.

For your protection, we only implement requests with respect to the information associated with the email address that you use to send us your request, and we may need to verify your identity before processing your request. Please note that certain personal information may be exempt from such requests pursuant to applicable data protection laws or other laws and regulations.

Additional Information for the EEA Only

You also may:

• Contact our Compliance Officer at dscherer@glaukos.com with any questions about this Policy.
• Lodge a complaint with a data protection authority for your country or region, or in the place of the alleged misconduct: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

Security

Glaukos will endeavor to take the appropriate administrative, physical, and technical measures to protect your personal information consistent with applicable privacy and data security laws and regulations.

Links to Third-party Websites

The Careers Site may contain links to other sites. This Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or service to which the Careers Site links. The inclusion of a link on the Careers Site does not imply endorsement of the linked site or service by Glaukos or its subsidiaries. Candidates are encouraged to read the privacy policies or terms of use of those sites when accessing those sites.

Law Applicable to Job Application

The Careers Site allows you to apply for jobs world-wide, as a benefit of Glaukos’s centralized global recruitment function. This Careers Site is operated from the United States. Accordingly, any personal information you submit to the Careers Site will be collected in the United States and will be subject to U.S. laws. However, if we share your personal information with an affiliate located in another country in its capacity as a potential employer, the affiliate will handle your personal information in accordance with this Policy. Any hiring or other employment-related decisions will be made by the hiring affiliate in accordance with the laws of the country where the job will be located.

Changes to the Policy

We reserve the right to amend this Policy at any time in order to address future developments of Glaukos, the Careers Site, or changes in industry or legal trends. The “Last Updated” legend at the top of this Policy indicates when this Policy was last revised. Any changes will become effective when we post the revised Policy on the Careers Site.

Contact Us

If you have questions or requests, please feel free to contact us at hr@glaukos.com.

Because email communications are not always secure, please do not include sensitive information in your emails to us.

Acknowledgement

I acknowledge that I have received, reviewed and understood this Policy.
With your consent, we will use your information to send communications about our opportunities in Talent Acquisition tailored to your interests via email and telephone.