Last Updated: February 15, 2024

1. Introduction

ATEC/EOS Group (“ATEC/EOS” or “we” or “us”) is committed to collecting and processing personal data responsibly and in compliance with the applicable data protection laws in all countries in which it operates.  This notice is designed to describe how and why your personal information is collected, the purpose(s) of its use, the parties that it might be shared with and how long it will be retained for as part of the recruitment process at ATEC/EOS.

2. Information We Collect

We collect and process personal information as a necessary part of the recruitment cycle. The information collected is required to manage the recruitment process, assess the candidate’s qualifications and suitability for employment. 

The information we collect from you will primarily come from your resume, cover letter, third parties and any other information you provide through the recruitment process. Some categories and examples of the types of personal information that may be collected include, but not limited to: 

Category	Examples of Data Collected
Identifiers	First and last name, email address
Personal information categories listed in the California Customer Records statute	Date of birth, age, phone number, home address, signature, national identity card details, social security number, citizenship status, nationality, gender identity
Protected classification characteristics under California or federal law	Racial / ethnic origin
Professional or employment-related information	Employer name, employment status, employment authorization, employment history and experience including job title and department, desired compensation, education & training, educational degrees, academic transcripts, grade, background screening results, criminal records, criminal history, references.
Non-public education information	Education, Educational degrees, certifications, training history, languages spoken for job applicants and employees, other skills, or information you voluntary choose to provide in connection with your job application.

 

3. Sources of Information 

We obtain the categories of personal information listed above from the following categories of sources:

• From you: The candidate.
• References: We may obtain information from professional references provided. 
• Networking Sites: For example, LinkedIn.
• From third party Service Providers that provide services to us in connection with our business operations: For example, we may obtain information from background check providers.

4. Who Do We Share Your Information With

Your personal information may be reviewed internally at ATEC/EOS as part of the recruitment cycle. This includes, but is not limited to managers, HR, recruiting teams and other internal groups at ATEC/EOS.

We may also share your personal information with service providers as part of the recruitment cycle. These service providers may process your personal information on ATEC/EOS’s behalf for the purposes of providing a required service to ATEC/EOS. These service providers include but are not limited to human resource information system providers, background check providers, and employee benefits providers (if applicable). 

5. How Long is Your Data Retained

Your personal information will be stored in accordance with applicable laws and kept as long as needed to carry out the purposes described in this Notice (or as otherwise required by applicable law). 

If you are successful with your application your personal information will be kept in accordance with our Employment Privacy Notice. If you are unsuccessful your personal information will be kept for the duration of the application process plus a reasonable period after confirmation that your application was unsuccessful to allow us to record the reasons for our decision in relation to your application. 

We may also retain your personal information to consider you for other suitable openings within ATEC/EOS in the future. 

Contact Information

If you have any questions or comments about this notice, the ways in which ATEC/EOS. collects and uses your information described below, your choices and rights regarding such use, or wish to exercise your rights, please do not hesitate to contact us at:

Phone: (844) 222-6773.

Website: ATEC/EOS

Email: privacy@atecspine.com

6. Changes to This Notice

We reserve the right to amend this notice at our discretion and at any time. When we make material changes to this privacy notice, we will update the notice's Effective Date and post the updated notice where other similar notices are located. 

CCPA Considerations: The California Consumer Privacy Act (“CCPA”) provides California residents with specific rights regarding their personal information.  This section describes the CCPA rights to know and to delete and explains how to exercise those rights. We will not discriminate against you for exercising your CCPA rights.   

Right to Know: You may have the right to send us a request, no more than twice in a 12-month period, for any of the following:

• The categories of personal information (PI) we collect about you.
• The categories of sources for the PI we collect about you.
• Our business or commercial purposes for collecting that PI.
• The categories of third parties with whom we share that PI, and categories of PI that each recipient received.
• The specific pieces of PI we collect about you.

Right to Delete: You have the right to request that a company delete any of your Personal Information that it has collected from you and retained, subject to certain exceptions.

For example, we may deny your deletion request if retaining the information is necessary for us to complete the transaction or service that you requested, detect security incidents, or enable internal uses that are reasonable aligned with your expectations.

How to Exercise your California Privacy Rights 

To exercise the right to know and the right to delete, please submit a verifiable request to us by either:

• • Sending us an email at: privacy@atecspine.com
  • Calling us at: (844) 222-6773

Please, describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Process: Once the initial identification and verification process is complete, we will send you an acknowledgement of receipt within 10 days from receiving your request and a reference number.

Any request that you submit to us is subject to an identification process to verify your identity or authority to make the request.

Time period: We will make every effort to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time, we will inform you in writing.

Designating an authorized agent: To exercise any of these privacy rights you can also designate another person to act on your behalf. In this case, we will need this person to provide us with a written authorization (such as a Power of Attorney). 

Fees: We will typically not charge a fee to fully respond to your requests. However, if we determine that the request warrants a fee according to the CCPA, we will tell you why and a cost estimate before completing your request.

To obtain this information in an alternative format: If you require this notice to be provided in a different format, please contact us at: privacy@atecspine.com

Policy towards Children

ATEC/EOS does not collect personal information of minors. If we learn we have collected or received personal information from a minor without verification of parental consent, we will delete that information. If you believe we might have any information from or about a minor, please contact us.

Sale of Personal Information

ATEC/EOS does not sell or lease candidate personal information to third parties as defined by the CCPA.  ATEC/EOS does use cookies and similar technologies on our websites to analyze and improve performance, enhance visitor or member experience, and offer customized experiences.  These cookies and technologies may share information with other parties; however, we provide visitors with the ability to block any cookie which is not strictly necessary for our site to operate.  For more information on how to block cookies and modify your settings, please see our Cookie Policy. 

GDPR Considerations: Under the General Data Protection Regulation (“GDPR “), if you are a Candidate in the United Kingdom (“UK”), Switzerland or the European Economic Area (EEA), we are required to provide you with additional information about our processing of your personal information. 

Lawful Basis for Processing Your Personal Information

The purpose of processing your personal information is for both ATEC/EOS’s and your legitimate interests. ATEC/EOS will not infringe on your data protection rights and interests. 

We may also process your personal information provided to comply with legal or regulatory requirements. 

This section describes the rights applicable to users covered by GDPR. If you are unsatisfied with our response to your complaint, you have a right to raise questions or complaints with your local data protection authority at any time.

Right to Withdraw Consent: Where we rely on your consent to process your personal information, you have the right to withdraw consent at any time. This will not affect the lawfulness of processing prior to the withdrawal of your consent. At any time, you can request that we stop using your personal information for recruiting purposes.

The right to access: We will send you an explanation of the following and a copy of all specific personal information we store about you:

• The categories and specific pieces of personal information we collect.
• The categories of sources from which we collect personal information.
• The purposes for which we use personal information.
• The categories of third parties with whom we share personal information or to whom we sell personal information.

The right to rectification: We will make corrections to certain pieces of personal information we store about you.

The right to erasure: We will delete certain personal information we have stored about you, with some possible exceptions, and will tell our service providers to do the same.

The right to restriction: We will refrain from processing your personal information for a period under certain circumstances.

The right to object: Instead of deleting your personal information, we will refrain from processing it going forward.

The right to data portability: We will send you an explanation of the following and a copy of all specific personal information we store about you. We will send it to you in a commonly used and machine-readable format.

• The categories and specific pieces of personal information we collect.
• The categories of sources from which we collect personal information.
• The purposes for which we use personal information.
• The categories of third parties with whom we share personal information or to whom we sell personal information.

Right to Object to Automated Decisions: We will refrain from processing your personal information as part of automated decision-making or profiling under certain circumstances.

Right to Opt-out of Marketing: We will refrain from sending future marketing information to the e-mail address you provide.

Right to Export Information to another Controller: Upon request, we will export your information to another controller.

How to Exercise your GDPR Privacy Rights 

To exercise the right to know and the right to delete, please submit a verifiable consumer request to us by either:

• • Sending us an email at: privacy@atecspine.com
  • Calling us at: (844) 222-6773

Please, describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Process: Once the initial identification and verification process is complete, we will send you an acknowledgement of receipt within 10 days from receiving your request and a reference number.

Any request that you submit to us is subject to an identification process to verify your identity or authority to make the request.

Time period: We will endeavor to respond to a verifiable consumer request within 30 days of its receipt.  If we require more time, we will inform you in writing.

Designating an authorized agent: To exercise any of these privacy rights you can also designate another person to act on your behalf. In this case, we will need this person to provide us with a written authorization (such as a Power of Attorney). 

Fees: We will typically not charge a fee to fully respond to your requests. However, if we determine that the request warrants a fee according to the GDPR, we will tell you why and a cost estimate before completing your request.

Transfer of Data outside EEA: We do not transfer personal data outside of the EEA unless there is an adequacy decision or appropriate safeguards in place.

Controller of your personal information

If you are a Candidate located in the UK, Switzerland or EEA, ATEC/EOS is the controller of your personal information. As data controller, ATEC/EOS is responsible for ensuring that the processing of your personal information complies with applicable data protection laws.