# Job Applicant Privacy Notice

Last updated: March 20, 2026

Traba Inc. ("Company," "we," "us," or "our") is committed to protecting the privacy of job applicants. This Job Applicant Privacy Notice ("Notice") describes how we collect, use, and share personal information about individuals who apply for employment with us.

This Notice applies to all applicants. California residents have additional rights under the California Consumer Privacy Act as amended by the California Privacy Rights Act (collectively, "CPRA"). New York City residents have additional rights under NYC Local Law 144 regarding automated employment decision tools. State-specific rights are described in the relevant sections below.

##### **Information We Collect**

We collect the following categories of personal information from and about applicants:

- **Identifiers** — such as your name, email address, phone number, mailing address, and any other contact information you provide
- **Professional and employment-related information** — such as your resume, cover letter, work history, references, skills, and qualifications
- **Educational information** — such as degrees, certifications, and academic history
- **Background check information** — such as criminal history records, employment verification, and identity verification, collected following a conditional offer of employment
- **Communications** — such as emails, messages, or notes exchanged during the recruiting process
- **Technical information** — such as IP address, browser type, and device information collected automatically when you interact with our application platform (Ashby)

We do not collect sensitive personal information beyond what is described above.

##### **How We Use Your Information**

We use applicant personal information for the following purposes:
- Evaluating your qualifications and suitability for open positions
- Communicating with you throughout the recruiting process
- Conducting background checks following a conditional offer of employment
- Complying with applicable legal obligations
- Maintaining records for legitimate business and legal purposes
- If hired, transitioning your information into our employment records for onboarding purposes

##### **Automated Decision-Making**

We use automated tools within our applicant tracking platform (Ashby) that apply AI-generated criteria to evaluate applicants against defined qualifications for open roles. These criteria may include factors such as educational background, relevant experience, and responses to application questions.

Automated evaluations are used to assist — not replace — human judgment. All hiring decisions are reviewed and made by a human member of our recruiting or hiring team.

**All Applicants:** You may request human review of any automated evaluation that affected your application by contacting us at Privacy@traba.work.

**California Residents:** You have the right to request human review of any automated decision-making process that produces legal or similarly significant effects concerning you, pursuant to the CPRA.

**NYC Applicants:** We do not currently use automated employment decision tools (AEDTs) as defined under NYC Local Law 144 to screen or evaluate candidates applying for New York City-based positions. All hiring decisions for NYC-based roles are made by human members of our recruiting or hiring team. If we implement AEDTs in the future, we will update this Notice and provide the advance notice required by Local Law 144 before any such tools are used in your evaluation.

##### **How We Share Your Information**

We do not sell or share your personal information for cross-context behavioral advertising. We may share your information with the following categories of third parties as necessary to carry out the purposes described above:
- **Recruiting and applicant tracking platform** — Ashby, which hosts and processes application data on our behalf
- **Background check provider** — Checkr, which conducts pre-employment screening following a conditional offer
- **Internal personnel** — hiring managers, HR staff, and relevant team members involved in the recruiting process
- **Legal and compliance advisors** — as needed to comply with applicable law or respond to legal process
- **Automated processing** — candidate application data, including names, resumes, and application responses, may be transmitted to Google's API for automated processing as part of our recruiting workflows. We use Google Workspace across our business operations, and this processing occurs within the same Google infrastructure.

All third-party service providers are contractually required to handle your personal information in a manner consistent with this Notice and applicable law.

##### **How Long We Retain Your Information**

We retain applicant personal information for a period of 5 years following the close of a recruiting process, whether or not an offer was extended. This retention period allows us to comply with applicable recordkeeping obligations and respond to any legal claims related to the recruiting process. If you are hired, your information is retained as part of your employment record in accordance with our employee privacy practices.

##### **Your Privacy Rights**

**All Applicants**  
Regardless of your state of residence, you may contact us at any time to:
- Request access to the personal information we hold about you
- Request correction of inaccurate personal information
- Request deletion of your personal information, subject to applicable legal exceptions
- Request human review of any automated evaluation affecting your application

We will not retaliate against you for exercising any of these rights.

**California Residents**  
In addition to the rights above, California residents have the following rights under the CPRA:
- **Right to Know** — You may request information about the categories and specific pieces of personal information we have collected about you.
- **Right to Correct** — You may request that we correct inaccurate personal information we hold about you.
- **Right to Delete** — You may request deletion of personal information we have collected about you, subject to certain legal exceptions.
- **Right to Opt-Out of Sale or Sharing** — We do not sell or share personal information for cross-context behavioral advertising, so this right is not currently applicable.
- **Right to Limit Use of Sensitive Personal Information** — We do not collect sensitive personal information beyond what is described in this Notice.
- **Right to Non-Discrimination** — We will not discriminate against you for exercising any of your privacy rights.

We will respond to verifiable requests from California residents within **45 days** as required by the CPRA, with the possibility of a single 45-day extension where reasonably necessary.

**New York Residents**  
New York residents have rights under the New York SHIELD Act, which requires us to maintain reasonable safeguards to protect your personal information. In the event of a data breach affecting your private information, we will notify you in accordance with applicable New York law.

##### **How to Exercise Your Rights**

To exercise any of the rights described in this Notice, please contact us at:

**Email:** Privacy@traba.work **Mail**: Traba Inc., 483 Broadway, 2nd Floor, New York, NY 10013

We will respond to verifiable requests within the timeframe required by applicable law, and no later than **45 days** of receipt.

This Notice applies to job applicants only and does not constitute an employment contract or guarantee of employment. We reserve the right to update this Notice at any time, and will post the revised version with an updated effective date.
