Aptos Candidate Privacy Notice

Updated August 29, 2025

The privacy of your personal data that you provide to us during your job application process is important to us. “You” refers to anyone who has submitted a job application to Aptos (as defined below).

“We/our/us” refers to Aptos, LLC whose principal place of business is at 11175 Cicero Drive, Suite 650, Alpharetta, GA 30022, USA, and its affiliates located around the world as set out here: http://www.aptos.com/contact or https://revionics.com/contact-us, depending on which country the Aptos/Revionics entity you have submitted a job application to, resides (“Aptos”).

This Candidate Privacy Notice (“Notice”) sets out how we collect, manage, use, process, and share information collected from you when you apply for jobs with Aptos, including when you express interest in our job opportunities.

As part of our recruitment processes, we collect and process your personal data (i.e. information relating to you), which we will refer to as “Candidate Data.” Candidate Data, where applicable, also includes “Sensitive Candidate Data” (as defined below).

1. Information we collect from you and its source

The Candidate Data we collect about you comes predominantly from you, and may include, but is not limited, to the following:

Contact details: such as full name, home address, telephone or mobile number, email address or online identifier and onsite badge information (if you visit us or any venues hosted by us in person).
Identification details: such as your citizenship, residency and right to work in the country you are applying for a job in.
Employment and education history: including your cover letter, resume/CV, work experience, education, and relevant achievements. If needed for the role, we may also collect information from professional bodies, reference checks, or education providers.
“Sensitive Candidate Data”: in some cases where required by law we may ask for information like your race or ethnic background, age, gender, disability and veteran status. We usually get this information directly from you, but sometimes from other sources like background check providers, to the extent we have a business reason to do so or where it is allowed by law.
Job application: any information or answers you submit to us as part of your job application which includes much of the information set out above.
Assessments: we may collect information related to any assessment to determine your suitability for the role, such as phone screens, interviews, case studies and skills assessments
Voluntary surveys: such as candidate experience feedback survey. These programs are entirely optional and will be communicated as such. If you do choose to participate, we will collect certain information relating to your participation in the survey program.

Other Candidate Data about you is generated from third parties such sources such as:

References and those who have referred you to us: from past colleagues, employers, or academic or professional contacts
Recruitment agencies
Background check providers. Where permitted by a legitimate business purpose or required by law, once you have accepted a conditional offer from us, background check providers may supply us with Candidate Data (including but not limited to information about your educational and employment background, and any past criminal convictions) about you, subject to your consent in certain jurisdictions
Publicly available sources: like your LinkedIn profile, portfolio site, or GitHub. For some roles, we may also review your public social media activity.
Online usage information. We may collect your online usage information when you browse our websites or use our Talent Community platform, including cookie information, traffic data or profiles, which may be combined with any of the foregoing categories of Candidate Data.

2. How we use Candidate Data and our legal basis

2.1 In certain countries, we use your Candidate Data based on our legitimate interests — as long as doing so does not override your legal rights.

Here is how we may use your data:

To get in touch with you regarding a role at Aptos;
To manage the recruitment process, including setting up interviews and staying in touch with you along the way
To verify the information you or others provide, and to check your references;
To conduct background checks if you are offered the role, where permitted or required by law;
To reimburse any agreed travel or interview related expenses; and
To analyse and improve our hiring process, including using aggregated (non-identifiable) data.

In countries where legitimate interest is not recognised as a legal basis upon which we can process your Candidate Data, you consent to us using your Candidate Data as set out above and pursuant to the terms of this Notice.

2.2 Where you have provided your consent, including:

To share content that matches your career interests, send job updates, and invite you to events or opportunities, if you join our Talent Community; and
To enable us to conduct background checks if you are offered a role, in certain jurisdictions, where permitted or required by law;

2.3 To enable us to collect diversity and inclusion data (if required by law or to fulfil any legitimate business purposes) to inform our recruiting strategies and undertake appropriate actions and initiatives.

2.4 Where necessary for us to administer any future contract of employment with you, if applicable.

2.5 As legally required, to confirm your eligibility to work in the country in which you applied for a job, for immigration processing purposes, to conduct background checks, or submit reports required by local law (e.g. EEOC reporting).

If you fail to provide Candidate Data when requested, and that information is necessary for us to consider your application (e.g. evidence of qualifications or work history), your application will be discontinued.

2.6 How we use Sensitive Candidate Data

Aptos is required by law and/or governmental agencies in certain countries to collect your Sensitive Candidate Data to maintain records of the race, ethnicity, gender, disability, and veteran status of applicants. This data will be aggregated with other data to generate diversity statistics. Submission of this data is optional. There will be no negative consequences to your application if you choose not to provide this data.

Any such information provided by you will not be made available to any decision-maker in the recruitment process, will not be used to consider your suitability for the role, and will not be provided to your manager(s) in the event that you are successful with your application.

If you have provided us with disability or health information so that we can make adjustments to our recruitment process, we will use this to support you during your application.

By choosing to provide us with Sensitive Candidate Data, you consent to this processing. You can withdraw your consent at any time (this may not affect processing that has already occurred or Sensitive Candidate Data that has been de-identified so that we can no longer identify you).

3. Who we disclose your Candidate Data to

Within Aptos: Candidate Data will be shared with the Talent Acquisition and Human Resources functions within the Aptos/Revionics group on a “need to know” basis in connection with the recruitment process, including with other support functions, such as Finance and Legal. Aptos has its headquarters in the US and operates globally, so it may be that the hiring manager and other people involved in the recruitment process will be located in a country outside your country of residence, or in a different group company to the one that is hiring for the role.
Service providers. We may disclose Candidate Data with service providers who perform necessary duties and functions on our behalf (e.g., our applicant tracking system, human resource information systems and background check providers). We do not allow our third-party service providers to use your Candidate Data for their own purposes. We only permit them to process it for specified purposes and in accordance with our instructions, and they are required to keep it confidential.
Third parties with your consent such as your referees.
As legally required to a third parties (e.g., courts, law enforcement agencies, government agencies) as is required or permitted under applicable law, or to respond to a valid court order, subpoena, discovery request, search warrant, or other law enforcement requests.

Candidate Data may be transferred outside your country of residence for processing, including to countries whose laws are not regarded as providing an adequate level of protection for personal data under your local legislation. Such transfer and processing is subject to any applicable laws and, where required, will be subject to your consent.

If you are applying for a role based in the UK/EEA, we may transfer Candidate Data to countries outside of such territories. Where the country has not been deemed by the UK and/or the EU to provide an adequate level of protection for your personal information, we will only transfer the data in a way that is consistent with, and which respects UK and EU data protection laws. Typically, this will be through Standard Contractual Clauses (SCCs) and the UK Addendum to the Standard Contractual Clauses included in the contract Aptos has in place with the third-party supplier.

4. How long we keep your Candidate Data for

If you join Aptos: We will keep your Candidate Data so we can manage your employment with us. During your employment, you will also receive a new privacy notice that explains how we handle employee personal data.

If you do not join Aptos (or if you withdraw or decline our offer): We will retain your Candidate Data for the purposes provided in this Notice, such as to keep you in mind for current or future roles, to help us evaluate and improve our recruitment processes, and for record-keeping, as required or permitted under applicable law or to resolve inquiries or complaints.

If you do not want us to keep your information on file, please let us know by following the process in Section 5 below. Even if you choose to exercise such rights, please note that we will still be required to retain your Candidate Data for the period legally necessary for us to comply with our legal obligations, including record retention requirements for potential litigation or to defend against legal claims.

5. Access to your Candidate Data and other rights

Depending on which country you reside in, you may have certain rights in relation to your Candidate Data such as the right to access, correct, update, delete or restrict the processing of your Candidate Data or you may object to the processing of your Candidate Data. We will honor these rights to the extent required by applicable laws.

If we rely on consent as grounds for processing your Candidate Data, you may withdraw consent at any time — though if you do so, that will not affect the lawfulness of what we have done before you withdrew consent.

If you would no longer like to be considered for a position, you may withdraw your application at any time, by reaching out to us at candidateprivacy@aptos.com.

In certain instances, applicable laws may allow us legitimately and properly to refuse some of these requests; for instance, to comply with applicable legal obligations, to protect the legitimate rights of third parties or to preserve the confidentiality of management deliberations.

Additional information for California residents

If you are a California resident, you or your authorised agent (on your behalf), have the right to make the types of requests listed below in connection with the Candidate Data:

The right to request access to the Candidate Data we have collected about you
The right to request that we correct inaccurate or incomplete Candidate Data
The right to request deletion of Candidate Data we hold about you
The right to request that we limit the use of your Sensitive Candidate Data.

You have the right not to be discriminated against for exercising your rights.

We do not “sell” or “share” Candidate Data and have not done so in the twelve months prior to the effective date of this Notice.

Section 1 above describes the categories of Candidate Data we have collected from you in the past 12 months. Sections 2 and 3 describe the purposes for which we may collect and disclose Candidate Data, and the categories of recipients of disclosures made for business purposes in the past 12 months. Section 4 describes how long we retain your Candidate Data for.

Authorized agent: You may authorize an agent to exercise your rights on your behalf. Your authorized agent may make a request on your behalf by reaching out to candidateprivacy@aptos.com. When your authorized agent makes a request on your behalf, we may require you to directly confirm the following with us:

Your identity
That you have provided the authorized agent permission to submit the request

If you’d like to request that we limit the use of your Sensitive Candidate Data, please email us at candidateprivacy@aptos.com with a pre-populated subject line.

De-identified data: We may de-identify Candidate Data so that it cannot be used to identify you and is no longer considered personal information under California law. For example, we may de-identify certain Sensitive Candidate Data so that we can share it more widely in our external reports. If so, we will maintain and use that data only in de-identified form and will not attempt to re-identify the data.

Additional information for Canadian residents

If you reside in Alberta, British Columbia or Quebec, we may collect, use or disclose Candidate Data without your consent so long as those activities are reasonable for the purposes of recruiting and we will comply with the terms of this Notice in doing so.

Your Candidate Data may be disclosed to third party recipients as set out in Section 3 above and may be communicated outside of your province.

We may, in certain cases, use or communicate your Candidate Data, without your consent, for certain other purposes permitted by law, such as fraud prevention. In certain cases, we may not be able to process an application on your behalf if you do not agree to the collection of your Candidate Data.

Subject to any restrictions and/or exemptions under applicable law, in addition to the information set out in this Section 5, you have the right to:

request access to your Candidate Data;
request rectification or correction of your Candidate Data;
request deindexation of your Candidate Data in certain circumstances;
request data portability (i.e., request a copy of your Candidate Data in a commonly used technological format); and
withdraw your consent to the use or communication of your Candidate Data.

by contacting us at candidateprivacy@aptos.com or the Data Privacy Officer at privacy@aptos.com or writing to us at Aptos Canada Inc., 9300 Trans-Canada Highway, Suite 300, Saint-Laurent, QC, H4S 1K5, Canada

How to make a request

To exercise your rights set out above, please email us at candidateprivacy@aptos.com. Some of your rights such as the right to delete your information may be exercised directly by you by using the functionality available on our applicant tracking system.

If you email us to exercise your rights, please provide details about the request you are making. In order to protect your information from unauthorized access or deletion, we may require you to provide additional information to verify your identity. If we cannot verify your identity, we will not be able to fulfil your requests to know, access, correct, or delete your information.

If you exercise the right of an access request, and we hold Candidate Data about you, we are required to provide you with information on it, including a description and copy of the Candidate Data and an explanation of why we are processing it.

We will respond to your questions within the timeframes required under applicable data protection laws.

6. Complaints

If you have questions or complaints regarding this Notice, please notify us at privacy@aptos.com

You may have the right to make a complaint at any time to a data protection authority or regulator about our collection and use of your Candidate Data, if this is permitted by local laws. However, before doing so, we would encourage you to first contact us directly, to allow us an opportunity to resolve any concerns you may have.

7. Changes to this Notice

We may change this Notice from time to time. The effective date will be identified at the top of this page.

8. Contact Us

You may contact us by emailing or writing to us at:

privacy@aptos.com
Aptos, LLC
11175 Cicero Drive
Suite 650, Alpharetta,
GA 30022,
USA

The data controller for your Candidate Data depends on the location of the job posting to which you applied (please refer to the table below) and their contact details are set out here: https://www.aptos.com/contact or https://revionics.com/contact-us. If you have questions or concerns regarding the terms of this Notice, please contact us using the contact details above.

Location of Job Posting	Data Controller
Australia	Revionics Limited (Australian branch)
Canada	Aptos Canada Inc.
France	Revionics Limited
Mexico	Aptos Software Mexico, S.de R.L. de C.V.
Germany	Revionics, LLC
India	Aptos India Private Limited
United Kingdom	Aptos Solutions UK Limited or Revionics Limited
United States	Aptos, LLC or Revionics, LLC