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Privacy Statement – Prospective Applicants (Avature)

At Novo Nordisk (“Novo Nordisk” or “Us” or “Our” or “We”), We strive to make a difference and improve the lives of millions of people living with diabetes, obesity and other serious chronic diseases around the world. Being an industry leader in Corporate Social Responsibility, We respect and value your personal privacy.

We want you – as someone interested in a career at Novo Nordisk – to understand who We are, what information We will collect from you, and how We process your personal data. This privacy statement (“Statement”) is designed to provide you with transparency into our privacy practices and principles and to inform you of your individual rights.

We also want you to understand that each Novo Nordisk entity complies with all applicable privacy laws and regulations in their respective locations. This means that you may have different privacy rights depending on the country in which you express interest in working and the specific Novo Nordisk affiliate processing your personal data.

We reserve the right to modify this Statement at any time. When We make changes to this Statement, you will be required to acknowledge that you have read and understand the revised privacy statement when expressing interest. If you are unable to review or access this Statement due to a disability, you may contact globalrecruitsupport@novonordisk.com to access this notice in an alternative format.

We ask that you read this Statement carefully and acknowledge that you have read and understand its terms by following the prompts at the end of this document. For purposes of this document, the legal bases of processing your Personal Data will follow the regulatory requirements at your country or region of residence and/or the Novo Nordisk location where you expressed interest in working (please refer to the section A.5 below).

A. Global Privacy Rights – Applicable to everyone accessing recruitment processes

This section sets forth prospects privacy rights that apply to all Novo Nordisk entities.

1. Who We Are

The company responsible for processing your personal data is:

Novo Nordisk A/S
Novo Allé
2880 Bagsværd
Denmark
CVR number 24256790
+45 4444 8888

The specific Novo Nordisk entity where you have expressed interest or that fits your profile and preferences will receive your personal data. That Novo Nordisk entity will also be a joint data controller with respect to the processing of your personal data. You can always contact Novo Nordisk A/S, the specific Novo Nordisk entity receiving your data or the Novo Nordisk Data Privacy Officer at privacy@novonordisk.com with questions or concerns about how We process your personal data.

If you reside in California, United States you can learn more about our privacy practices involving prospective applicants at https://www.novonordisk-us.com/privacy-notice/california-applicant-employee-privacy-notice.html.

2. Personal Data Held by Novo Nordisk

Novo Nordisk collects personal data submitted by you as part of the prospect recruitment process. As used in this Statement, “personal data” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual. In some jurisdictions, a link to solely a household may also be personal data. Your personal data is held on an externally hosted database located in the United States. Your personal data is also held in manual form and on other internal computer systems.

Further, your personal data, if necessary for the below purposes, will be transferred to non-affiliated parties providing products and services (such as agencies assisting Novo Nordisk in screening and interviewing prospective employees and recruitment process vendors) and IT system suppliers, as well as regulatory authorities if required by law. When these are acting as data processors, contractual agreements are put in place to safeguard your personal data.

3. Purposes for Which Personal Data is Held by Novo Nordisk

As part of the prospect recruitment process, your personal data may be transferred to Novo Nordisk entities located in a different country from your country of residence. We believe that it is beneficial to form an ongoing relationship with individuals who might be a good fit for current or future positions at Novo Nordisk. In order to further this effort, we work to provide you with information about Novo Nordisk and opportunities here as well as learn more about your career aspirations and preferences.

In order to foster the relationship described above, we provide the following recruitment services prior to the submission of an application:

Talent community communications – you may opt in to receive emails related to topics that might interest you as someone who is interested in opportunities at Novo Nordisk or that are related to a specific skill/field of work that you would like to pursue.
Proactive contact by our Talent Attraction team – our Talent Attraction team, or an external partner working on our behalf, may contact you pro-actively to discuss your interests related to future employment or to discuss specific opportunities.
Hiring or career fair event related communications – we will host and/or participate in a variety of hiring or career fair events. You may opt in to receive emails related to these events and also to receive follow-up communications if you participate in an event.

If you decide to apply for a position at Novo Nordisk, you will receive another Privacy Notice that details how we process your personal data during the hiring process in accordance with the legal requirements governing the Novo Nordisk location to which you apply.

In addition to the purposes identified above, Novo Nordisk will also use the data as we believe to be necessary or appropriate:

(a) to comply with applicable law, including laws outside your country or region of residence;
(b) to comply with legal process;
(c) to respond to requests from public and government authorities including public and government authorities outside your country or region of residence if it complies with relevant legislation;
(d) to enforce our terms and conditions or policies and procedures if it complies with relevant legislation;
(e) to protect or defend our operations or those of any of our affiliates if it complies with relevant legislation;
(f) to protect or defend our rights, privacy, safety, or property, and/or that of our affiliates, you, or others if it complies with relevant legislation; and
(g) to allow us to pursue available remedies or limit the damages that we sustain if it complies with relevant legislation.

4. What Personal Data We Process About You

To facilitate the recruitment related processes highlighted above, We collect and process information in Our talent acquisition systems, which contain:

All areas except US and Canada will collect some or all the information listed below:

Contact information (name, address, telephone number, e-mail address).
Curriculum Vitae or resume, including work experience, qualifications, skills, and education history.
Nationality, languages spoken, gender, are you located in Denmark and able to attend a career fair, are you a current or former Novo Nordisk employee, current job search status, salary expectations, current salary.
Willingness to relocate, opportunities of interest, where did you hear about Novo Nordisk, preferred job location (country and city), required notice period, where your information was obtained, whether you have acknowledged the data privacy statement.
Educational background, number of countries studied in, career fair information.
Whether you have been a finalist for a position already and why you were not selected, your functional area of expertise and additional sub-specialty, name of Novo Nordisk contact, the number of opportunities you are being considered for.

US and Canada will collect some or all the information listed below:

Contact information (name, address, telephone number, e-mail address).
Curriculum Vitae or resume, including work experience, qualifications, skills and education history.
Career fair information, including: how did you hear about the event.
Information regarding your current situation and interests: career level, area of interest, whether you have pharmaceutical experience, years of experience, current company, type of position, desired compensation, timeline for making a job change.

The information that you submit to our online recruiting system will be used for Novo Nordisk’s recruitment processes, as permitted by local law, including to:

Assess your capabilities and qualifications for a job;
Provide you updates/notifications about opportunities that match your capabilities and qualifications if you have agreed to receive these updates;
Comply with or monitor compliance with any applicable law or regulation or Novo Nordisk policies or procedures.

5. The legal basis for the processing of your personal data

Our processing of your personal data requires a legal basis. Consent is the primary legal basis on which Novo Nordisk relies to process your personal data across all jurisdictions covered by this Statement, given that your engagement with our talent community is entirely voluntary. In limited circumstances, we may also rely on legal obligation where required by applicable law, or legitimate interest where necessary to protect the security and integrity of our systems and operations. If you would like to know more about the legal basis applicable to your location, please contact privacy@novonordisk.com.

As a general matter, your personal data will be disclosed only in limited circumstances. If your personal data must be transferred outside of the country or region in which you reside, we will protect your personal data and will implement certain safeguards consistent with applicable privacy laws. Those safeguards are as follows:

Transfers of EU personal data to a Novo Nordisk entity are covered by Novo Nordisk’s Binding Corporate Rules, available at novonordisk.com/content/dam/nncorp/global/en/data-privacy/novo-nordisk-binding-corporate-rules.pdf
Some transfers will be limited to destination countries that are deemed by applicable privacy laws (such as by the EU Commission under the EU General Data Protection Regulation) as having an adequate level of protection of personal data.
Where legally required, we will make sure to have entered into Standard Contractual Clauses that are prescribed under applicable privacy laws (such as those prescribed by the EU Commission or the UK Information Commissioner’s Office) before we transfer personal data to any entities located in third countries. You can get a copy of the clauses by contacting us as described in section 1.
In certain situations, we will also implement other mechanisms approved by relevant regulators under applicable privacy laws.

As described above, you also understand that your personal data will be stored in the United States and will be subject to the data privacy and protection laws and regulations governing the Novo Nordisk entity to which you’ve expressed interest.

6. Disclosure of Personal Data

As a general matter, your personal data will be disclosed only in limited circumstances. Personal data will be disclosed to the extent required for the purposes listed in section 3 above to Novo Nordisk entities/Talent Acquisition supporting teams globally, including affiliates located in countries other than where you reside. These locations may have different data privacy laws and regulations from your country or region of residence.

Additionally, your personal data will be disclosed to external vendors as described in section 2, public authorities and law enforcement agencies as required or permitted by all applicable laws.

7. Data Retention

Novo Nordisk will retain personal data for the period necessary to fulfil the purposes outlined in this Statement unless a longer retention period is required or permitted by law. Where you have provided your consent to be part of our talent community, we will also retain your personal data to identify opportunities that match your profile and preferences, and to contact you about roles that may be of interest to you.

Your personal data will be retained for the following periods depending on your jurisdiction:

For prospects in India, your personal data will be retained for up to 3 years. For prospects in the EU/EEA, Switzerland, United Kingdom, Australia, Bangladesh, Japan, South Korea, Malaysia, Brazil, Argentina, Colombia, and Mexico, your personal data will be retained for up to 4 years. In jurisdictions where local legal requirements mandate or permit a longer retention period (the United States and Canada), your personal data will be retained for up to 8 years after submission.

These retention periods apply unless you withdraw your consent before the applicable period expires, in which case your personal data will be deleted in accordance with your request and applicable law.

Furthermore, Novo Nordisk may delete personal data about you (including your CV/resume) from our database at any time and without providing any reason. Therefore, please retain a copy of your personal data.

8. Storage and Deletion of Data

We ask you to provide accurate and up-to-date information and you may request to update it or delete it at any time by contacting us as described in Section 9 below.

9. Your Privacy Rights

Because Novo Nordisk values the importance of your personal data that it collects from you and strives to give you as much control over it as possible, we recognize that you may be entitled to one or more of the following data subject rights depending on the applicable laws in countries or regions where you reside. Please note that some rights only apply to residents of certain geographies. In those instances, we have added language indicating which rights only apply to residents of certain geographies:

Right to Receive Information on Privacy Practices: You have the right to receive certain legally required information at or before the point of collection or in response to your request.
Right to Erasure: You may request that we delete any personal data about you that we Collected from you, subject to certain exceptions.
Right to Rectification: You may request that we correct any inaccurate personal data we maintain about you.
Right to Know and Access: You may request that we provide you with specific information about how we have handled your personal data, including providing you with a copy of the specific pieces of personal data we have collected about you in a portable format.
Right to Non-Discrimination (for California Residents only): You have the right not to be discriminated against for exercising your data subject rights. That means not retaliating against you as a result of you exercising your data subject rights.
Rights to Opt-Out (for California Residents only): You may request to opt-out of the sale and sharing of your personal data, cross-context behavioral or targeted advertising, automated decision making or profiling, to the extent such activities are defined and restricted under applicable laws. When we collect your personal data during the recruitment process, we do not use your personal data for any of these restricted purposes.
Right to Restrict or Object to Processing (for EU Residents only): You may request us to suppress or cease the processing of some of your personal data but we may still store your personal data.
Right to Lodge a Complaint: You have the right to file a complaint with your local data protection authority if you consider that the processing of personal data relating to you infringes upon your rights.
Right to Withdraw Consent Please note that if you apply for a position in a country or region where the legal basis for the processing of your personal data includes consent, you reserve the right to withdraw your consent at any time. Novo Nordisk will honor this request for any future processing to the extent required by applicable laws, but will not be able to modify any previous processing of personal data done before we have received your revocation of your consent.

For further information about what local requirements apply to you and to exercise your privacy rights, you can always contact us as follows:

For prospects in the United States: Please e-mail the Novo Nordisk US Privacy Office at NNIPrivacy@novonordisk.com

For prospects everywhere else: Please e-mail the Novo Nordisk data privacy officer at privacy@novonordisk.com

10. Statistics

We may anonymize or aggregate your personal data as permitted by applicable laws for internal purposes only, including, but not limited to, statistical analysis about trends relating to responses to job postings and for other statistics and reporting purposes.

11. Data Security

Novo Nordisk implements organizational, technical, and administrative measures to protect personal data within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contact us” Section above.

Do not send sensitive data to us via e-mail. It is your sole responsibility to use the appropriate level of care whenever you communicate with us.

12. Links to Non-Affiliated Websites

This online recruiting system may contain links to other websites. This Privacy Statement does not address, and we are not responsible for, the privacy, data, or other practices of any non-affiliated parties, including any non-affiliated party operating any website or service to which this online recruiting system links. The inclusion of a link on this online recruiting system does not imply endorsement of the linked site or service by Novo Nordisk or our affiliates. We encourage you to read the legal notices posted on those sites, including their privacy policies.

13. About Children

This online recruiting system is not intended for minors under the age of 16.