Privacy Notice – Employees, Applicants, Officers, Directors, and Contractors
PRIVACY NOTICE – EMPLOYEES, APPLICANTS, OFFICERS, DIRECTORS, AND CONTRACTORS
UPDATED AND EFFECTIVE DATE: August 4, 2026
This notice (“Notice”) applies to you if you are a job applicant to, employee of, director of, officer of, or individual contractor of Philo (collectively “you”). It informs you about (1) the categories of Personal Information that we may collect about you, (2) the sources from which we collect Personal Information, (3) the purposes for which we may use that Personal Information, and (4) the third parties to whom Personal Information may be disclosed. “Personal Information” has the definition as set out in applicable data protection and privacy laws, including similar terms such as "Personal Data" and "Personally Identifiable Information."
Please note that we may use automated employment decision tools and automated decision-making technologies to process your personal data. For more information, including our pre-use notice, please see below or click here.
1. Categories of Personal Information We Collect
Depending on the circumstances, we may collect the following categories of Personal Information from you:
Identifiers such as your real name, alias or nickname, postal address, phone number, unique personal identifier, online identifier, internet protocol address, email address, social security number, driver's license number, passport number, and any other identifiers required by law. We may also need to collect the name, postal address, and email address of your emergency contacts, dependents, and beneficiaries. | |
Categories of Sources from which the Information was Collected | We may collect this type of information from: - you - through other Philo workforce members - external sources (such as data that you have posted publicly) - tracking technologies (such as cookies, web beacons, and pixel tags) - third party social media companies - third party career portals |
Business or Commercial Purpose(s) for which Information is Collected | We may use this type of information for: - recruiting - background screening and checks - making employment and staffing decisions - confirming your eligibility for employment under applicable law - assisting with immigration matters on your behalf - administering benefits and insurance - managing payroll and other forms of compensation - managing, awarding, and distributing equity - paying or reimbursing expenses - conducting performance reviews and managing career planning - providing human resources management services, including providing data maintenance and support services, administration of separation from Philo, approvals and authorization procedures, administration and handling of worker claims, and travel administration - maintaining your contact information - assessing training needs and conducting training - improving our culture and working environment, including conducting staff surveys and providing senior management with information about other employees - assisting you in an emergency, including maintaining contact details for you and your dependents or emergency contacts - handling any disputes related to your relationship with Philo - managing the work environment, which includes information collected relating to disciplinary actions and code of ethics conduct processes and investigations - conducting our business, including recording audio and audiovisual recordings of meetings and calls - providing technical support services for devices used for work - managing security on our systems and infrastructure and conducting investigations, which includes managing our software and hardware computer assets; systems testing, such as development of new systems and end-user testing of computer systems; training; monitoring email, internet access and usage of devices and accounts used for work; and monitoring and managing physical access to company facilities - obtaining financing, recapitalizing the company, or the purchase or sale of all or part of a business - complying with applicable law or regulatory requirements, such as legal (local, state, and federal) and internal company reporting obligations, including required reporting for tax obligations, immigration, contractor payments, wages, headcount, management information, and demographics |
Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose | We may disclose this type of information to: - service providers - third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders) - third parties who may acquire the information as a result of a merger, acquisition, or other transfer of ownership |
Categories of Personal Information, such as the identifiers above, your telephone number, employment history, education, bank account number, other financial information, medical information, and health insurance information. We may also need to collect the telephone number of your emergency contacts, dependents, and beneficiaries. | |
Categories of Sources from which the Information was Collected | We may collect this type of information from: - you - through other Philo workforce members - external sources (such as data that you have posted publicly) - tracking technologies (such as cookies, web beacons, and pixel tags) - third party social media companies - third party career portals |
Business or Commercial Purpose(s) for which Information is Collected | We may use this type of information for: - recruiting - background screening and checks - making employment and staffing decisions - confirming your eligibility for employment under applicable law - assisting with immigration matters on your behalf - administering benefits and insurance - managing payroll and other forms of compensation - managing, awarding, and distributing equity - paying or reimbursing expenses - conducting performance reviews and managing career planning - providing human resources management services, including providing data maintenance and support services, administration of separation from Philo, approvals and authorization procedures, administration and handling of worker claims, and travel administration - maintaining your contact information - assessing training needs and conducting training - improving our culture and working environment, including conducting staff surveys and providing senior management with information about other employees - assisting you in an emergency, including maintaining contact details for you and your dependents or emergency contacts - handling any disputes related to your relationship with Philo - managing the work environment, which includes information collected relating to disciplinary actions and code of ethics conduct processes and investigations - conducting our business, including recording audio and audiovisual recordings of meetings and calls - providing technical support services for devices used for work - managing security on our systems and infrastructure and conducting investigations, which includes managing our software and hardware computer assets; systems testing, such as development of new systems and end-user testing of computer systems; training; monitoring email, internet access and usage of devices and accounts used for work; and monitoring and managing physical access to company facilities - obtaining financing, recapitalizing the company, or the purchase or sale of all or part of a business - complying with applicable law or regulatory requirements, such as legal (local, state, and federal) and internal company reporting obligations, including required reporting for tax obligations, immigration, contractor payments, wages, headcount, management information, and demographics |
Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose | We may disclose this type of information to: - service providers - third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders) - third parties who may acquire the information as a result of a merger, acquisition, or other transfer of ownership |
Characteristics about you that may be required by law or voluntarily provided by you, such as your date of birth, race, national origin, disability, medical condition, sex (including your gender, gender identity, gender expression, and pregnancy or childbirth and related medical conditions), marital status, citizenship status, veteran or military status, requests for parental, pregnancy, disability or sick leave, background check information (such as criminal records, historical addresses, education history, and employment history) and other characteristics. | |
Categories of Sources from which the Information was Collected | We may collect this type of information from: - you - through other Philo workforce members - external sources (such as data that you have posted publicly) - tracking technologies (such as cookies, web beacons, and pixel tags) - third party social media companies - third party career portals |
Business or Commercial Purpose(s) for which Information is Collected | We may use this type of information for: - assisting with immigration matters on your behalf - administering benefits and insurance - providing human resources management services, including providing data maintenance and support services, administration of separation from Philo, approvals and authorization procedures, administration and handling of worker claims, and travel administration - operating diversity, equity, and inclusion program - complying with applicable law or regulatory requirements, such as legal (local, state, and federal) and internal company reporting obligations, including required reporting for tax obligations, immigration, contractor payments, wages, headcount, management information, and demographics |
Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose | We may disclose this type of information to: - service providers - third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders) - third parties who may acquire the information as a result of a merger, acquisition, or other transfer of ownership |
Biometric, audio, electronic, or similar information. This may also include other physiological, biological, or behavioral characteristics about you. | |
Categories of Sources from which the Information was Collected | We may collect this type of information from: - you - equipment and software used for work - external sources (such as data that you have posted publicly) - third party social media companies - service providers |
Business or Commercial Purpose(s) for which Information is Collected | We may use this type of information for: - recruiting - conducting our business, including recording audio and audiovisual recordings of meetings and calls - providing technical support services for devices used for work - managing security on our systems and infrastructure and conducting investigations, which includes managing our software and hardware computer assets; systems testing, such as development of new systems and end-user testing of computer systems; training; monitoring email, internet access and usage of devices and accounts used for work; and monitoring and managing physical access to company facilities - complying with applicable law or regulatory requirements, such as legal (local, state, and federal) and internal company reporting obligations, including required reporting for tax obligations, immigration, contractor payments, wages, headcount, management information, and demographics |
Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose | We may disclose this type of information to: - service providers - third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders) - third parties who may acquire the information as a result of a merger, acquisition, or other transfer of ownership |
Internet or other electronic network activity information, including, but not limited to, your browsing history, search history, and email content, and information regarding your interaction with internet websites, applications, or advertisements on company issued devices, personal devices used for company purposes, or through company user accounts. | |
Categories of Sources from which the Information was Collected | We may collect this type of information from: - you - equipment and software used for work - tracking technologies (such as cookies, web beacons, and pixel tags) |
Business or Commercial Purpose(s) for which Information is Collected | We may use this type of information for: - managing the work environment, which includes information collected relating to disciplinary actions and code of ethics conduct processes and investigations - conducting our business, including recording audio and audiovisual recordings of meetings and calls - providing technical support services for devices for work - managing security on our systems and infrastructure and conducting investigations, which includes managing our software and hardware computer assets; systems testing, such as development of new systems and end-user testing of computer systems; training; monitoring email, internet access and usage of devices and accounts used for work; and monitoring and managing physical access to company facilities - complying with applicable law or regulatory requirements, such as legal (local, state, and federal) and internal company reporting obligations, including required reporting for tax obligations, immigration, contractor payments, wages, headcount, management information, and demographics |
Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose | We may disclose this type of information to: - service providers - third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders) - third parties who may acquire the information as a result of a merger, acquisition, or other transfer of ownership |
Geolocation Data, such as tracking your access to company facilities. | |
Categories of Sources from which the Information was Collected | We may collect this type of information from: - you - equipment and software used for work - external sources (such as data that you have posted publicly) - third party social media companies |
Business or Commercial Purpose(s) for which Information is Collected | We may use this type of information for: - managing the work environment, which includes information collected relating to disciplinary actions and code of ethics conduct processes and investigations - conducting our business, including recording audio and audiovisual recordings of meetings and calls - providing technical support services for devices used for work - managing security on our systems and infrastructure and conducting investigations, which includes managing our software and hardware computer assets; systems testing, such as development of new systems and end-user testing of computer systems; training; monitoring email, internet access and usage of devices and accounts used for work; and monitoring and managing physical access to company facilities - obtaining financing, recapitalizing the company, or the purchase or sale of all or part of a business - complying with applicable law or regulatory requirements, such as legal (local, state, and federal) and internal company reporting obligations, including required reporting for tax obligations, immigration, contractor payments, wages, headcount, management information, and demographics |
Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose | We may disclose this type of information to: - service providers - third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders) - third parties who may acquire the information as a result of a merger, acquisition, or other transfer of ownership |
Audio, electronic, visual, or similar information about you. | |
Categories of Sources from which the Information was Collected | We may collect this type of information from: - you - external sources (such as data that you have posted publicly) - equipment and software used for work - third party social media companies - third party career portals |
Business or Commercial Purpose(s) for which Information is Collected | We may use this type of information for: - recruiting - providing human resources management services, including providing data maintenance and support services, administration of separation from Philo, approvals and authorization procedures, administration and handling of worker claims, and travel administration - managing the work environment, which includes information collected relating to disciplinary actions and code of ethics conduct processes and investigations - conducting our business, including recording audio and audiovisual recordings of meetings and calls - providing technical support services for devices used for work - managing security on our systems and infrastructure and conducting investigations, which includes managing our software and hardware computer assets; systems testing, such as development of new systems and end-user testing of computer systems; training; monitoring email, internet access and usage of devices and accounts used for work; and monitoring and managing physical access to company facilities - obtaining financing, recapitalizing the company, or the purchase or sale of all or part of a business - complying with applicable law or regulatory requirements, such as legal (local, state, and federal) and internal company reporting obligations, including required reporting for tax obligations, immigration, contractor payments, wages, headcount, management information, and demographics |
Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose | We may disclose this type of information to: - service providers - third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders) - third parties who may acquire the information as a result of a merger, acquisition, or other transfer of ownership |
Professional or employment-related information, including your job application, resume, education history, employment contracts, contractor agreements, performance reviews, expense reports, payroll and benefits data, internal and external contact information, memberships in professional organizations, professional certifications, employment history, and information about you obtained from video, audio, systems, or other forms of monitoring or surveillance. | |
Categories of Sources from which the Information was Collected | We may collect this type of information from: - you - through other Philo workforce members - external sources (such as data that you have posted publicly) - third party social media companies - third party career portals |
Business or Commercial Purpose(s) for which Information is Collected | We may use this type of information for: - recruiting - background screening and checks - making employment and staffing decisions - confirming your eligibility for employment under applicable law - assisting with immigration matters on your behalf - administering benefits and insurance - managing payroll and other forms of compensation - managing, awarding, and distributing equity - paying or reimbursing expenses - conducting performance reviews and managing career planning - providing human resources management services, including providing data maintenance and support services, administration of separation from Philo, approvals and authorization procedures, administration and handling of worker claims, and travel administration - assessing training needs and conducting training - improving our culture and working environment, including conducting staff surveys and providing senior management with information about other employees - handling any disputes related to your relationship with Philo - managing the work environment, which includes information collected relating to disciplinary actions and code of ethics conduct processes and investigations - conducting our business, including recording audio and audiovisual recordings of meetings and calls - complying with applicable law or regulatory requirements, such as legal (local, state, and federal) and internal company reporting obligations, including required reporting for tax obligations, immigration, contractor payments, wages, headcount, management information, and demographics |
Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose | We may disclose this type of information to: - service providers - third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders) - third parties who may acquire the information as a result of a merger, acquisition, or other transfer of ownership |
Education information that is not publicly available, including your grade point averages, transcripts, and any other educational information. | |
Categories of Sources from which the Information was Collected | We may collect this type of information from: - you - through other Philo workforce members - external sources (such as data that you have posted publicly) |
Business or Commercial Purpose(s) for which Information is Collected | We may use this type of information for: - recruiting - background screening and checks - making employment and staffing decisions - confirming your eligibility for employment under applicable law - assisting with immigration matters on your behalf - conducting performance reviews and managing career planning - providing human resources management services, including providing data maintenance and support services, administration of separation from Philo, approvals and authorization procedures, administration and handling of worker claims, and travel administration - assessing training needs and conducting training - improving our culture and working environment, including conducting staff surveys and providing senior management with information about other employees - conducting our business, including recording audio and audiovisual recordings of meetings and calls - complying with applicable law or regulatory requirements, such as legal (local, state, and federal) and internal company reporting obligations, including required reporting for tax obligations, immigration, contractor payments, wages, headcount, management information, and demographics |
Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose | We may disclose this type of information to: - service providers - third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders) - third parties who may acquire the information as a result of a merger, acquisition, or other transfer of ownership |
Inferences drawn from any of the information we collect that may reflect your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes. | |
Categories of Sources from which the Information was Collected | We may collect this type of information from: - you - through other Philo workforce members - external sources (such as data that you have posted publicly) - tracking technologies (such as cookies, web beacons, and pixel tags) - third party social media companies - third party career portals |
Business or Commercial Purpose(s) for which Information is Collected | We may use this type of information for: - recruiting - background screening and checks - making employment and staffing decisions - confirming your eligibility for employment under applicable law - conducting performance reviews and managing career planning - assessing training needs and conducting training - improving our culture and working environment, including conducting staff surveys and providing senior management with information about other employees - handling any disputes related to your relationship with Philo - managing the work environment, which includes information collected relating to disciplinary actions and code of ethics conduct processes and investigations - conducting our business, including recording audio and audiovisual recordings of meetings and calls - complying with applicable law or regulatory requirements, such as legal (local, state, and federal) and internal company reporting obligations, including required reporting for tax obligations, immigration, contractor payments, wages, headcount, management information, and demographics |
Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose | We may disclose this type of information to: - service providers - third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders) - third parties who may acquire the information as a result of a merger, acquisition, or other transfer of ownership |
2. Data Retention
Philo will keep your Personal Information for as long as your employment application and any working relationship with us lasts, and for a certain period after your application or working relationship with us has ended; but we will not keep or store Personal Information for longer than is reasonably necessary to fulfill the purposes (as described in this Notice) for which it was collected or that you authorized after collection, or as otherwise required by law. In determining how long we keep your Personal Information, we take into account our legal obligations (such as legal requirements to retain your information, financial reporting obligations, and equal opportunity or anti-discrimination reporting obligations), the nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of the Personal Information, and whether we may need to retain the Personal Information to resolve disputes, make and defend legal claims, conduct audits, pursue legitimate business purposes and/or enforce our agreements.
3. Data Rights
In certain jurisdictions and contexts, you may have the ability to exercise certain rights with respect to your Personal Information, including requesting your right to know what information is processed, request deletion of personal information, request correction of personal information, and limit or opt-out of certain processing activities.
Please contact us using the information provided below if you would like to exercise any of these rights. California residents can refer to our CCPA Notice for more information.
4. Use of AI and Automated Decision-Making
We may use technology that incorporates artificial intelligence and machine learning technologies to process applications. These tools could be considered automated employment decision tools ("AEDT") under New York City Local Law 144 or automated decision-making technologies ("ADMT") under state laws such as the California Consumer Privacy Act.
We use an applicant tracking system, Ashby, to help manage applications for open positions for which we are hiring. Our use of Ashby begins on or after August 18, 2026. See Section 1 above for information about the types of personal information we use for recruiting and hiring purposes. Ashby's automated features (i) assess the skills, experience, and qualifications relevant to the role as described in our postings, and (ii) flag applications that appear fraudulent, duplicative, or not genuinely submitted by the applicant. As a result, Ashby may rank, categorize, or make recommendations about applications or applicants. While we try to ensure that humans are involved in all of our recruiting and hiring processes, in some instances Ashby's automated processing may be the primary factor used in hiring decisions. As required by law, an independent auditor conducts annual bias audits of Ashby. A summary of the results of the most recent bias audit, including the audit date and data source, is available here.
In certain jurisdictions and contexts, you may have the right to opt-out of or appeal ADMT-related decisions, request that a member of our team review application decisions through a process that does not rely on automated tools, or request a reasonable accommodation. You may also have the right to obtain certain information specific to you about how we use ADMT. To exercise these rights, please email recruiting@philo.com or HR@philo.com. We verify requests in accordance with applicable law. We will not retaliate against you for exercising your rights.
For more information about the type and source of the data our tools collect, our data retention, and how these tools are used in evaluating your application, please review the rest of this Notice or email recruiting@philo.com.
5. Changes to this Notice
We reserve the right to modify this Notice at our discretion and at any time. When we make changes, we will reflect the date the Notice was updated. We encourage you to visit this notice to check for updates from time to time. We will also provide you with notice where required by applicable laws.
6. Contact Information
If you have a question related to this Notice, please contact us at: HR@philo.com
This Notice was last modified on the date indicated above and is effective on such date.