Progress Software Corporation Candidate Privacy Notice for California Residents

June 20, 2023

Effective as of July 1, 2023

Introduction

Progress Software Corporation, together with all of its affiliates and subsidiaries (“Progress”) provides this Candidate Privacy Notice for California Residents (the “Notice”) as part of its effort to comply with the California Consumer Privacy Act (“CCPA”) and California Privacy Rights Act (“CPRA”). It is important for you to understand how Progress collects, processes, and stores your personal data in relation to your candidacy for employment.

This page provides additional details on Progress’ privacy practices associated with the submission and processing of personal information submitted by job applicants ("candidates").

What do we collect?

• Personal information provided by you, including first and last name, address, email address, phone number, gender, race/ ethnicity info/ veteran and disability status through the OFCCP form (when applicable) nationality/citizenship. Some of this information may be considered as Sensitive Personal Information under the California Privacy Rights Act (“CPRA”). However, your Sensitive Personal Information such as Social Security number and/or passport is not used for any other purposes than the described in this Privacy Notice.
• Personal information provided by you regarding your working skills, education, certifications, curriculum vitae and employment qualifications, including information provided by previous employers and other references, if permitted under applicable law and/or proactively shared by the candidates.
• Personal information provided by you when choosing to complete your professional profile in any recruiting platform utilized by Progress, including voluntarily updating your professional experience, business title, education, skills, etc.
• Personal information obtained from a third-party when performing authorized reference checks, background checks, or verifying personal information you provided to us if permitted under applicable law.

Guided by this Notice, our Employee Privacy Notice for Residents of California, internal Progress record retention schedules, and applicable legal obligations, we will not retain your personal information longer than necessary.

Why do we collect it?

• To fulfill our obligations as your current or prospective employer.
• For making recruitment or employment decisions.
• To advance or defend Progress’ legal rights.
• To prevent or detect fraudulent or other unlawful activities.
• To comply with a law, regulation or valid legal process and, in appropriate circumstances, cooperating with law enforcement.
• For business planning and improving our operations.
• For access control and company security.
• To meet our legal obligations.

Any or all of the above may include using this information to communicate with you, internally evaluate your qualifications and skills, prepare for interview or screening discussions (including arranging travel where applicable or reimbursing candidates for expense), and may entail background checks for certain roles which will be conduct with additional notice and in accordance with applicable laws. During the hiring process, we may obtain information about you from publicly available sources or from third parties including references, background check suppliers, and the like, to the extent allowable by law. We take steps to confirm that the information we receive from these third parties has been collected with your consent or that these parties are otherwise legally permitted to disclose your personal information to us.

Also, if you accept an offer of employment from Progress, any relevant personal data collected during your pre-employment period will become part of your personnel record and will be retained in accordance with our Employee Privacy Notice for Residents of California. If we do not employ you, we may nevertheless continue to retain and use your personal data for a period of time for system administration purposes, to consider you for potential future roles, and to perform research. Unless required for tax or other legal purposes or in connection with employment as specified above, your data will only be retained for as long as it is needed for the purposes outlined in this Notice (or less where required by law).

Who else might receive it?

• Your personal information is only to be processed by persons working for and on behalf of Progress on a need-to-know basis for the purposes described in this Notice.
• When Progress engages third-party service providers for the processing of your personal information, they solely process your personal information based on our contract with them and for no other purposes.
• Progress does not share your personal information with third parties unless required to do so by law (including external/governmental bodies), or as reasonably necessary with trusted service providers working for us to help us administer the recruitment process.

To operate our global business, we may need to transfer your personal information to countries other than your country of residence, and your personal information may be transferred to, processed in, or shared with employees outside the United States. We make such transfers always in accordance with this Notice and our Employee Privacy Notice for Residents of California.

How do we protect your information?

We use commercially reasonable physical, procedural, and technical safeguards to deter unauthorized access, destruction, use, modification, or disclosure of your personal information. We instruct our employees that information must be handled in accordance with our policies which contain clear confidentiality obligations. Any misuse of applicant or employee personal information by employees will subject them to disciplinary action, up to and including termination.

How long do we keep your personal information?

Progress may retain your information for a period of time consistent with the original purpose of collection. For instance, we may retain your information during the time in which you have an account to use our recruitment platform and for a reasonable period of time afterward. We may keep your application and the associated records for at least 2 years from the initial creation or receipt of the records and files. We also may retain your information during the period of time needed for Progress to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.

If you make a request to know, erase, correct your personal information, we may be required to maintain records of these requests and how responded to the requests for at least 24 months.

Your Rights

The CCPA/ CPRA allows you to request, twice in any 12-month period, information about how we collect, store, disclose share or sell your personal information. You can submit such requests online by clicking here or by calling +1 (888) 914-9661 (toll-free) and entering the Progress unique PIN 689 150 when prompted. We will evaluate the request and take action where required to do so.