Privacy practices information

HERE Global B.V., including its affiliates (“HERE”), is committed to respecting your privacy and to complying with applicable data protection and privacy laws. HERE acts as the data controller for personal data processing during the recruitment process. For more information about our privacy approach, please visit our HERE Privacy Policy.

Introduction of HERE Recruitment process

This Privacy Notice explains how HERE collects and processes your personal data during recruitment. It informs you about the personal data categories we process, the purpose and legal basis for processing, the source of data, how long we keep it, the parties with whom we may share your data, and your rights under applicable data protection laws.

Our websites, products, or services may contain links to third‑party websites with their own privacy notices. HERE is not responsible for external privacy practices and encourages you to review those notices.

Purpose description

We collect personal data as a part of your application through our recruitment management system, either directly from you or via an agency or other third party involved in your application. We may use automated tools to help identify, summarize, prioritize candidates based on job-related criteria, and organize application materials. We do not make decisions solely by automated means.

We process your personal data for recruitment and resourcing activities, including:

• Assessing your suitability for a role

• Managing interviews and communication

• Conducting background checks where legally required

• Informing you about relevant vacancies

Legal basis

Depending on the purpose, HERE processes your data based on:

• Steps necessary prior to entering into an employment contract (Art. 6(1)(b) GDPR)

• Legitimate interests in managing recruitment operations - When we perform profiling in the recruitment process, we rely on HERE’s legitimate interests in efficiently managing applications and ensuring candidates are matched to relevant roles (Art. 6(1)(f) GDPR).

  • We conduct Legitimate Interests Assessment and apply safeguards, including human oversight, transparency, and the process for candidates to raise concerns or contest outcomes)

  • Where local law requires consent for specific assessments, we will obtain your consent (Art. 6(1)(a)) for that activity.

• Compliance with legal obligations (Art. 6(1)(c) GDPR)

• Your consent, for example, when you ask to receive notifications of future opportunities (Art. 6(1)(a) GDPR)

Data Subject category

HERE Job applicant (“Applicant”)

Personal data involved in the processing activity

In the recruitment context, HERE typically collects and processes the following categories of personal data for the purposes set out below:

Recruitment and resourcing activity:

When you create an account in our recruitment management system or otherwise interact with HERE (either directly or through an agency or other third party), you may be asked to provide HERE with:

Background check, and assessments as required or permitted by applicable local law:

Notification of vacancies that may be relevant to you:

HERE aims to minimize the collection of sensitive information and will only collect it where there is a lawful basis for doing so under applicable law.

HERE may use AI-enabled tools to support recruitment operations, including organizing applications, extracting skills from CVs, and producing relevance or match indicators to assist human reviewers. These tools do not make decisions solely by automated means; all evaluations and hiring decisions involve human recruiters and designated hiring teams.

HERE does not use automated decision-making in the recruitment process.

Retention period of the processing activity

HERE typically retains recruitment data for up to 12 months unless applicable law requires a shorter or longer period. Retention periods may differ by jurisdiction.

Profiling artifacts (e.g. extracted features, scores or rankings) are retained for the same period as your application file and are deleted at the end of that period.

Source of information

We obtain your personal data directly from you or through third parties such as recruitment agencies, background check providers, or professional advisers.

We may also derive features used for profiling (such as extracted skills/keywords or relevance indicators) from the information you provide or from any role-related assessments you choose to complete.

Categories of data recipients to whom we share your personal data

HERE may share personal data about you with other HERE companies or authorized third parties who process personal data for HERE for the purposes described in this Notice or otherwise provide recruitment-related services to HERE. In such cases HERE will ensure that there is a genuine need to transfer the personal data about you, and that measures are in place to safeguard the processing of the personal data through other HERE companies or authorized third parties.

Personal data may be shared with:

• HERE group companies

• Recruitment agencies

• Background check providers (only where legally required)

• Professional advisers

• Service providers supporting recruitment activities (including assessment platforms and vendors that host or operate tools used for CV parsing, skills extraction, candidate matching or scoring to support a human review).

Third parties act under contractual or statutory confidentiality obligations and may only process data as instructed by HERE. Where such providers are located outside of your country, HERE uses appropriate data transfer mechanisms.

HERE does not conduct credit reporting checks unless legally mandated.

Authorized third parties may technically have access to the personal data HERE processes about you in the course of providing their services but will be contractually restricted (or subject to a professional or statutory duty of confidentiality) from processing the personal data about you for other purposes. HERE also requires them to act consistently with this Notice and to use appropriate security measures to protect your personal data.

When required by law, HERE may disclose personal data to government authorities or other third parties—such as government agencies responsible for employment activities or statistical information, or law‑enforcement agencies (e.g., in connection with background checks). We may also disclose personal data where necessary to protect your vital interests or, in accordance with applicable law, to defend HERE’s legitimate interests (for example, in legal proceedings).

International transfers

As a global organization with affiliates, business processes, and technical systems operating across multiple countries, HERE may transfer your personal data to locations outside the country where you are applying. These countries may have different data protection laws or may not offer the same level of protection as your home jurisdiction. Whenever such international transfers occur, HERE ensures that a valid legal basis is in place and that appropriate safeguards, such as Standard Contractual Clauses or other mechanisms required by applicable law, are implemented to protect your personal data. For more details about how HERE manages international data transfers, please refer to the HERE Privacy Policy.

Profiling based on personal data

Profiling in recruitment:

As part of the recruitment process, HERE may perform profiling, which means automated analysis of certain aspects of your information (for example, skills/aptitude test results, resume data or job-match score) to help us manage applications efficiently.

Profiling does not involve decisions that are based solely on automated processing; any hiring decisions involve human review.

Automated decision-making based on personal data

HERE does not make hiring decisions that are based solely on automated processing, including profiling.

Data subject rights

You have certain rights under GDPR and local laws, including:

• Access

• Rectification

• Erasure

• Restriction

• Objection

• Data portability

• Withdrawal of consent (without affecting prior processing)

• Logding a complaint

Rights related to profiling: Where we use profiling in recruitment, you may have the right to object to this processing in certain circumstances (in particular where we rely on legitimate interests). You may also request information about the logic and criteria used to support recruitment decisions, request human intervention, express your point of view, and contest an outcome that you believe is inaccurate or unfair.

To exercise your rights, please submit a request via the following link: https://here.com/here-data-subject-request or write to us at privacy@here.com.

Exercising your rights will not result in any adverse treatment. You can access, review, and update your profile through HERE recruitment management system. You may also be able to delete your profile there; if not, you can request deletion through recruitment support.

However, withdrawing consent or deleting your profile may prevent HERE from continuing your recruitment process.

For more information, please visit Your Rights section in our Privacy Policy or submit a Data Subject request.

Personal data security

HERE applies appropriate technical and organizational measures to protect your data, including:

• Role‑based access controls

• Periodic quality check and, where feasible,

  bias monitoring of profiling tools

• Security and privacy engineering

• Proactive risk management

• Internal policies, training, and audits

• Access restricted to personnel with a legitimate need

Changes of Privacy Notice

HERE may update this Notice from time to time.

Material changes will be communicated through a notice posted at the top of this document and on our website for at least 30 days.