Wacom Recruiting Privacy Statement

Wacom Recruiting and Hiring Privacy Statement
Wacom collects and processes your personal data when you express interest in or apply for
employment with Wacom. The information below explains how Wacom obtains, uses, shares,
and retains your personal data.
A full list of Wacom entities by country and their contact information appears at the bottom of
this Privacy Statement.
What personal data does Wacom collect?
Wacom collects the following categories of personal data:•••

Application and Recruitment Informationo Data you provide to us during the application process;o Data about your credit history, criminal records or other data revealed during
background screenings as permitted by applicable law;o Data generated by interviewers and recruiters, based on their interactions withyou or information publicly available about you on the Internet;
o Your offer letter or contract of employment and any amendments to it;
o Data provided by third-party placement firms, recruiters, or job-search websites,
where applicable;o Recommendations or references provided on your behalf by others; ando Data from third-party sites that you authorize to provide us information, such as
LinkedIn or Indeed.
Core Applicant Informationo Your personal details, meaning your name, contact information, such as yourpostal or residential address, email address, and telephone number, your IP
address, your emergency contact information, employment and educational
history, other records of professional achievement (including your resume, CV,
and other application materials), and biographical information;o Social Security number, driver’s license, state identification card or passportnumber, signature, physical characteristics (e.g., through a photograph, or video
camera);o Correspondence Wacom sends or receives from you;o Information needed to reimburse you for expenses; ando Usage data regarding your usage of Wacom’s information systems for purposesof data security, system performance monitoring, and system improvement.
Legal Compliance Informationo Information needed for monitoring our compliance with our equal opportunities
obligations, such as race, national origin, sex, sexual orientation, age, andveteranstatus;1

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Wacom Recruiting Privacy Statemento Documentation required under immigration laws, such as citizenship, and visa orpermanent resident status;o When permitted or required by applicable law, data about your health or
disability where (1) it relates to your ability or availability to work or to aworkplace accommodation; (2) is needed to comply with our legal obligations
about the health and safety of the workplace; or (3) is needed to administer sick
pay or other benefits; ando Where permitted by applicable law, data about race, ethnicity, religion,
disability, gender, sexual orientation, and other legally protected or significant
characteristics or statuses, for purposes of government reporting whererequired, as well as to understand the diversity characteristics of the Wacom
workforce;
You are not required to provide any requested information to Wacom, but failing to do so may
affect our ability to consider you for employment or prevent us from considering you for
employment.
You may read this Statement at any time by visiting https://www.wacom.com/aboutwacom/careers-at-wacom
What will Wacom do with your personal data?
Wacom will use your personal data for the following purposes and on the following legal bases:
PurposeLegal Basis

Assess your suitability for employment for
To take steps at the applicant’s request prior
the role for which you are applying, as well as to entering into an employment contract andfuture roles that may become available.
Wacom’s legitimate interest of hiring
appropriate employees.
Communicate with you.

To take steps at the applicant’s request prior
to entering into an employment contract andWacom’s legitimate interest of hiring
appropriate employees.

Perform administrative functions relating to
your candidacy (e.g. reimburse you forinterview-related expenses).

To take steps at the applicant’s request prior
to entering into an employment contract, tocomply with a legal obligation, and Wacom’s
legitimate interest of ensuring that it properly
accounts for interview-related expenses.

Analyze our applicant pool to better
understand who is applying to positions at
Wacom and how to attract top talent.

Wacom’s legitimate interest of ensuringcontinual improvement in its hiring andrecruitment processes.
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PurposeLegal Basis

Perform any legally-required reporting, andrespond to legal process.

Compliance with a legal obligation.

Where the above table states that we rely on our legitimate interests for a given purpose, we
consider how our use of your personal data could affect your interests, rights, and freedoms.
To the extent we collect special categories of personal data from applicants, our collection isnecessary for carrying out our employment-related legal obligations.
Wacom will not use your personal data for purposes that are incompatible with the purposes
listed in this Privacy Statement, unless it is required or authorized by law, you give consent, or it
is in your own vital interest (e.g. in case of a medical emergency) to do so.
From what sources will Wacom obtain your personal data?
Wacom may obtain data about you from the following sources:
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From you;
From previous employers;
From service providers that we engage to work with you or us, such as third-party
recruiters;
From a job search or professional networking website (e.g. monster.com, LinkedIn,
Indeed, etc.) where you may have made data about yourself publicly available;
From third-party recruiters, staffing companies, or websites in situations where you are
introduced to Wacom through one; andFrom background checks, where permitted by law. To obtain this personal data, Wacom
may contract with a third party to perform a pre-employment background screening.
The content of background check information varies by country to comply with local
requirements, but may include information gathered from publicly available sources,
your former employers or colleagues, schools you have attended, credit reporting
agencies, and criminal records databases. You will receive more detailed information
about the background check before it begins.

Who will have access to your personal data? Where are they located?
In general, access to your personal data will be restricted to minimize the number of people in
Wacom’s global organization who need it for the purposes set out in this Privacy Statement.
As a global organization with global information technology systems, your personal data may betransferred to other offices in Wacom’s worldwide organization. Wacom has internal policies toensure personal data are protected across Wacom’s worldwide organization. Any transfers ofyour personal data from within the European Economic Area (EEA) to other Wacom entities
outside the EEA will be governed by Wacom’s Data Transfer Agreement-EU (which incorporates
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Wacom Recruiting Privacy Statement
EU standard contractual clauses). A list of the Wacom entities that may process your personaldata, and their contact information, can be found here at the bottom of this statement.
Furthermore, when Wacom shares your personal data with third parties, Wacom takes steps toprotect your personal data. Any service providers to whom your personal data are disclosed are
expected and required to protect the security of your personal data and may only use yourpersonal data in compliance with applicable data protection laws. The following categories ofthird parties will have access to a subset of your personal data appropriate for their purposes oras prescribed by law:•••

Authorized personnel at our service providers, including:o Information system service providers ando Background check service providers, where applicable. These companies may bebased in another country, and may obtain data from other countries where you
have lived, worked or studied, as may be relevant as part of a background check;
Government officials where legal reporting requirements exist, or law enforcement
agencies or private litigants in response to valid law enforcement process (warrant,
subpoena, or court order); andA third party in connection with any proposed or actual reorganization, merger, sale,joint venture, assignment, transfer or other disposition of all or any portion of Wacombusiness, assets or stock (including in connection with any bankruptcy or similar
proceedings).

How long will Wacom retain my personal data?
When you are given and accept an offer of employment by Wacom, personal data collectedduring your pre-employment period becomes part of your Wacom personnel records and ourpractices regarding your data will be governed by the Wacom Employee Privacy Notice.
Otherwise, Wacom determines the retention period of your information based on the following
retention criteria:•••

Wacom retains your personal data as long as it has an ongoing relationship with you;
Wacom retains your personal data where it is required to do so by a legal obligation towhich it is subject; andWacom retains your personal data where this is advisable to safeguard or improve
Wacom’s legal position (for instance in relation to statutes of limitations, litigation, or
regulatory investigations).

How Wacom protects your personal data
Wacom employs organizational, technical, and physical security measures in order to protect
your data from loss or misuse. When we retain third parties to provide services to us that
require them to have access your personal data, we require them by contract to have security
controls in place that are comparable to our own security controls.
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How to request access to your personal data or contact us with questions or feedback
If you have a question, comment, complaint, or wish to make a request relating to yourpersonal data rights, you may contact us by email or by mailing to the address of the
responsible entity listed below.
Subject to certain exceptions set forth in the applicable law, you have the right to:
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request access to your personal data: this right entitles you to request access topersonal data we process about you, as well as to certain information on suchprocessing;request rectification of your personal data: this right entitles you to request therectification or completion of any of your personal data that you view as inaccurate,
outdated, or incomplete;request erasure of your personal data: this right entitles you to request the erasure ofyour personal data, except data that we are legally required to maintain for a certain
period of time, including where such personal data would no longer be necessary toachieve the purposes;
object to the processing of your personal data: this right entitles you to request that we
no longer process your personal data, except as required to maintain our employment
relationship;
request the restriction of the processing of your personal data: this right entitles you torequest that we only process your personal data in limited circumstances, including withyour consent; andrequest a copy or the portability of your personal data: this right entitles you to receive
a copy of personal data that you have provided to us.

If, despite Wacom’s commitment and efforts to protect your personal data, you believe yourdata protection rights have been violated, you have the right at all times to lodge a complaint
with a supervisory authority, either in the country where you live, the country where you workor the country where you believe that data protection law has been infringed.

Additional Provisions required by Local Laws
Japanese Law Disclosure - for applicants of Wacom Co., Ltd.
In accordance with the "Act on the Protection of Personal Information" of Japan, certain itemswith regard to the way of processing personal data obtained by Wacom, including the purposeof use and the details of joint use, are disclosed at https://www.wacom.com/ja-jp/privacypublic-notice
California Consumer Privacy Act (CCPA) Disclosure
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Wacom Recruiting Privacy Statement
In 2018, the state of California enacted the California Consumer Privacy Act, and amended it in 2020
under the California Privacy Rights Act (collectively, “CCPA”), which affords certain rights for
California employment candidates. This section specifically addresses the rights of California
employment candidates under the CCPA.
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A. Collection Categories

As explained above, and incorporated here, we collect a variety of categories of information,
including sensitive personal information, in connection with providing employment, which includes:

•

•

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Application and Recruitment Informationo Data you provide to us during the application process;o Data about your credit history, criminal records or other data revealed during
background screenings as permitted by applicable law;o Data generated by interviewers and recruiters, based on their interactions withyou or information publicly available about you on the Internet;
o Your offer letter or contract of employment and any amendments to it;
o Data provided by third-party placement firms, recruiters, or job-search websites,
where applicable;o Recommendations or references provided on your behalf by others; ando Data from third-party sites that you authorize to provide us information, such as
LinkedIn or Indeed.
Core Applicant Informationo Your personal details, meaning your name, contact information, such as yourpostal or residential address, email address, and telephone number, your IP
address, your emergency contact information, employment and educational
history, other records of professional achievement (including your resume, CV,
and other application materials), and biographical information;o Social Security number, driver’s license, state identification card or passportnumber, signature, physical characteristics (e.g., through a photograph, or video
camera);o Correspondence Wacom sends or receives from you;o Information needed to reimburse you for expenses; ando Usage data regarding your usage of Wacom’s information systems for purposesof data security, system performance monitoring, and system improvement.
Legal Compliance Informationo Information needed for monitoring our compliance with our equal opportunities
obligations, such as race, national origin, sex, age, and veteran status;o Documentation required under immigration laws, such as citizenship, and visa orpermanent resident status;o When permitted or required by applicable law, data about your health or
disability where (1) it relates to your ability or availability to work or to aworkplace accommodation; (2) is needed to comply with our legal obligations
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about the health and safety of the workplace; or (3) is needed to administer sick
pay or other benefits; ando Where permitted by applicable law, data about race, ethnicity, religion,
disability, gender, sexual orientation, and other legally protected or significant
characteristics or statuses, for purposes of government reporting whererequired, as well as to understand the diversity characteristics of the Wacom
workforce;•

B. Information Sources

As explained above, we collect personal information from employment candidates themselves;
their previous employers; from service providers that we engage to work with you or us, such as
third-party recruiters; from a job search or professional networking website (e.g. monster.com,
LinkedIn, Indeed, etc.) where you may have made data about yourself publicly available; from thirdparty recruiters, staffing companies, or websites in situations where you are introduced to Wacomthrough one; and from background checks, where permitted by law.
To obtain this personal data, Wacom may contract with a third party to perform a pre-employment
background screening. The content of background check information varies by country to comply
with local requirements, but may include information gathered from publicly available sources, yourformer employers or colleagues, schools you have attended, credit reporting agencies, and criminal
records databases. You will receive more detailed information about the background check before
it begins.
•

C. Personal Information Use and Sharing for Employment-candidacy and Application
Purposes

As explained in greater detail above, we use personal information collected for a wide variety of
employment-placement purposes:• To take steps at the applicant’s request prior to entering into an employment contract,• to facilitate Wacom’s legitimate interest of ensuring that it properly accounts for interviewrelated expenses;• to comply with a legal obligation;• to improve our hiring and job-candidate processes.
We disclose and share your personal information only for the purposes described above to thefollowing categories of third parties:• Service providers, as explained above, and with Affiliates.
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D. Sales of Personal Information

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We do not engage in any selling or sharing of Wacom employment candidates’ personal
information.
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F. Your California Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information.
This section describes your CCPA rights and explains how to exercise those rights.
i. Access to Specific Information.
You have the right to request that we disclose certain information to you about our collection anduse of your personal information over the past 12 months. Once we receive and confirm yourverifiable consumer request (see Exercising Consumer Rights, below), we will disclose to you:
• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you.
• If we sold or disclosed your personal information for a business purpose, two separate lists
disclosing:o sales, identifying the personal information categories that each category of recipientpurchased; ando disclosures for a business purpose, identifying the personal information categories
that each category of recipient obtained.
Under the CCPA, you also may request that we disclose certain information to you about ourcollection and use of your personal information beyond the past 12 months. Wacom, however,may decline to provide you that information if doing so would require a disproportionate effort on
our part.

ii. Deletion and Correction Request Rights
You have the right to request that we delete or correct any of your personal information that wecollected from you, subject to certain exceptions. Once we receive and confirm your verifiableconsumer request (see Exercising Consumer Rights, below), we will delete (and direct our service
providers to delete) or correct your personal information from our records, unless an exception
applies.
We may deny your deletion request if retaining the information is necessary for us or our service
provider(s) to:8
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Wacom Recruiting Privacy Statement• Complete the transaction for which we collected the personal information, provide a goodor service that you requested, take actions reasonably anticipated within the context of ourongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity,or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speechrights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546
et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public
interest that adheres to all other applicable ethics and privacy laws, when the information’sdeletion may likely render impossible or seriously impair the research’s achievement, if you
previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations basedon your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with thecontext in which you provided it.
iv. Exercising Consumer Rights
To exercise the rights described above, please submit a verifiable consumer request to us by one of
the following methods:• Emailing us at privacy-wtc@wacom.com;• Calling us toll free at 1-855-669-2266; or• Submitting a request through our webform accessible here.
Only you, or a person registered with the California Secretary of State that you authorize to act on
your behalf, may make a verifiable consumer request related to your personal information. You
may also make a verifiable consumer request on behalf of your minor child. You may only make averifiable consumer request for access or data portability twice within a 12-month period.
To verify the identity of an individual making a request, a two-step process will need to becompleted. A verifiable consumer request must:• Describe your request with sufficient detail that allows us to properly understand, evaluate,
and respond to it.
• Separately provide sufficient information that allows us to reasonably verify you are theperson about whom we collected personal information or an authorized representative.

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We cannot respond to your request or provide you with personal information if we cannot verify
your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. We will
only use personal information provided in a verifiable consumer request to verify the requestor’s
identity or authority to make the request.
iv. Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require
more time, we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do nothave an account with us, we will deliver our written response by mail or electronically, at youroption.
Unless otherwise requested, any disclosures we provide will cover only the 12-month period
preceding the verifiable consumer request’s receipt. The response we provide will also explain thereasons we cannot comply with a request, if applicable. For data portability requests, we will selecta format to provide your personal information that is readily useable and should allow you totransmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it isexcessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, wewill tell you why we made that decision and provide you with a cost estimate before completingyour request.
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F. Non-Discrimination

We will not discriminate against you for exercising your CCPA rights. Unless permitted by the CCPA,
we will not:• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting
discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different
level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result indifferent prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer willreasonably relate to your personal information’s value and contain written terms that describe theprogram’s material aspects. Participation in a financial incentive program requires your prior opt inconsent, which you may revoke at any time. However, we do not currently provide any financial
incentives.

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G. Shine the Light Disclosure

We have not shared any personal information with other companies for their direct marketing use
within the immediately preceding calendar year. Accordingly, California’s “Shine the Light” law, Cal.
Civil Code § 1798.83 to § 1798.84, does not apply to us and we have not established any mechanism
for you to request information on our sharing of information for third parties’ marketing purposes.

You are not required to provide any requested information to Wacom, but failing to do so may
affect our ability to consider you for employment or prevent us from considering you for
employment.
You may read this Statement at any time by visiting https://www.wacom.com/aboutwacom/careers-at-wacom
Changes to this Privacy Statement
Wacom reserves the right to update or amend this Privacy Statement at any time. If we make amaterial change to this Privacy Statement, we will notify you by email or by means of a noticeon our websites/intranet prior to the changes taking effect.
List of Wacom Entities and Contact Information
Wacom Co., Ltd.
privacy-wcl@wacom.com
Attention: Privacy Officer, Senior Director, Risk Management, Corporate Administration
Sumitomo Fudosan Shinjuku Grand Tower 31F, 8-17-1 Nishi-shinjuku, Shinjuku-ku,
Tokyo, 160-6131, Japan
Wacom Technology Corporation
privacy-wtc@wacom.com
Attention: Privacy
1455 NW Irving St Portland, OR 97209, USA

Wacom Europe GmbHprivacy-weg@wacom.com
z. Hd. Datenschutzbeauftragter
Völklinger Str. 1, 40219 Düsseldorf, Deutschland
You may also contact WEG’s Data Protection Officer at dpo-weg@wacom.com.
Wacom China Corporation
privacy-wcc@wacom.com
Attention: Privacy
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518, West Wing Office, China World Trade Center, No. 1 Jianguomenwai Avenue,
Chaoyang District, Beijing 100004, China
Wacom Hong Kong Limited
privacy-whk@wacom.com
Attention: Privacy
Unit 1610, 16/F., Exchange Tower, 33 Wang Chiu Road, Kowloon Bay, Hong Kong
Wacom Korea Co., Ltd.
privacy-wkr@wacom.com
Attention: Privacy
Rm #1211, 12FL, KGIT Sangam Center, 402 Worldcup bukro, Mapo-gu, Seoul 03925, Korea
Wacom Taiwan Information Co., Ltd.
privacy-wtw@wacom.com
Attention: Privacy
9F-1, No.237 Songjiang Rd., Zhongshan Dist. Taipei 104 Taiwan
Wacom Singapore Pte. Ltd.
privacy-wsp@wacom.com
Attention: Privacy#12-09 Suntec Tower Five, 5 Temasek Boulevard, Singapore 038985
Wacom India Pvt. Ltd.
privacy-win@wacom.com
Attention: Privacy
426, DLF Tower B, Jasola District Center, Mathura Road, New Delhi 110025, India
Wacom Australia Pty. Ltd.
privacy-wau@wacom.com
Attention: Privacy
Ground floor, Building 1, 3 Richardson Place, North Ryde, NSW, 2113 Australia

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