U.S. Job Applicant Privacy Notice

Last Updated: June 23, 2023

e.l.f. Cosmetics, Inc. (“e.l.f.” or “we”) respects your concerns about privacy. This U.S. Job Applicant Privacy Notice (this “Privacy Notice”) describes the types of personal information we obtain about individuals in the United States who apply for jobs with e.l.f. Beauty, Inc., its subsidiaries and its brands (“Job Applicants”). Please note that all U.S. employment arrangements for the e.l.f. Beauty family of brands are operated through our primary operating company, e.l.f. Cosmetics, Inc.

Certain terms used in this Privacy Notice have the meanings given to them in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and its implementing regulations (collectively, the “CCPA”).

Except to the extent required by applicable law, this Privacy Notice is not a contract and does not create any legal rights or obligations. Please note that if we provide you with a job offer and you accept the offer, our relevant employee privacy notice will apply to you at that time and the personal information that you provide to us after that time.

PERSONAL INFORMATION WE OBTAIN

e.l.f. may collect (and may have collected during the 12-month period prior to the Effective Date of this Privacy Notice) the following categories of personal information about Job Applicants:

Identifiers: identifiers, such as a real name, alias, postal address, telephone number, online identifier, email address, and other similar identifiers.
Sensory Information: audio and visual information (for example if you use video or phone interviewing as part of the application process, if you include photographs or videos you may provide in connection with your application, or if you have publicly available social media profiles). If you visit our offices or warehouses, your entry and exit and movements may be monitored by the building’s and our security systems.
Employment and Education Information: professional or employment-related information, such as salary expectations, information relating to your position (for example, job title and job description), talent management information (for example, résumé information, occupation details, education details, certifications and professional associations, and previous employment details).
Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, behavior, attitudes, intelligence, abilities, and aptitudes.
Other: job interview notes, responses to screening questions, assessment results, and any other information you provide in connection with the recruitment process.

Please note, for California resident Job Applicants, personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) may be included in the above categories.

HOW WE USE THE PERSONAL INFORMATION

We may use (and may have used during the 12-month period prior to the Effective Date of this Privacy Notice) personal information for the purpose of processing job applications, evaluating candidates for employment, and carrying out and supporting recruitment functions and activities, including as described below.

For California resident Job Applicants, in addition to purposes listed above, we list below relevant “business purposes” as they are described in the CCPA.

Recruiting; processing job applications; determining suitability for employment; determining physical and/or mental fitness for work; reviewing and evaluating applications; determining salary and other forms of compensation; reimbursing expenses; making travel arrangements; reviewing hiring decisions; and providing access to facilities.
Detecting or preventing theft or fraud, or attempted theft or fraud; and facilitating communication with you and your designated contacts in an emergency.
Performing data analytics; managing company human resources; and strategic planning.
Complying with legal requirements, such as tax, record-keeping and reporting obligations; conducting audits, management and resolution of health and safety matters; complying with requests from government or other public authorities; responding to legal process such as subpoenas and court orders; pursuing legal rights and remedies; defending litigation and managing complaints or claims; conducting investigations; and complying with internal policies and procedures.

e.l.f. does not collect or process sensitive personal information with the purpose of inferring characteristics about Job Applicants.

To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

RETENTION OF PERSONAL INFORMATION

We will retain personal information about Job Applicants for the time period reasonably necessary to achieve the purposes described in this Privacy Notice, or any other Privacy Notice provided at the time of collection, taking into account applicable statutes of limitation and records retention requirements under applicable law.

We may additionally retain certain of your personal data so that we may contact you about future opportunities at e.l.f. if we haven’t offered you the role for which you have applied.

SOURCES OF PERSONAL INFORMATION

During the 12-month period prior to the Effective Date of this Privacy Notice, e.l.f. may have obtained personal information about Job Applicants from the following categories of sources:

directly from you;
service providers, contractors and other vendors who provide services on our behalf;
recruiting and talent agencies;
publicly available sources such as your social media profiles (for example, LinkedIn, Instagram, TikTok); and
other sources as directed by you.

INFORMATION WE SHARE

During the 12-month period prior to the Effective Date of this Privacy Notice, e.l.f. may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

Category of Personal Information	Categories of Third Parties
Identifiers Employment and Education Information Sensory Information Inferences Other	Our affiliates and subsidiaries Our recruiting and talent agencies Our services providers

In addition, we may disclose information about you if required to do so by law or if we believe such action is necessary to comply with legal process.

e.l.f. does not sell or share for cross-context behavioral advertising purposes personal information about Job Applicants.

CALIFORNIA RESIDENT JOB APPLICANTS

Your Choices

If you are a California resident Job Applicant, you have certain choices regarding your personal information (subject to certain limitations at law), as described below.

Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed, and sold or shared about you.
Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.
Deletion: You have the right to request that we delete certain personal information we have collected from you.

How to Submit a Request

To submit an access, correction or deletion request, please email us at mwoginrich@elfbeauty.com or call us at (888) 315-9814. When you contact us, please let us know that you are a Job Applicant and please let us know what California privacy right you wish to exercise so that we can process your request in an efficient manner.

To submit a request as an authorized agent on behalf of a Job Applicant, please email us at mwoginrich@elfbeauty.com with the subject line “Authorized Agent—California Job Applicant Privacy Rights Request” and in the body of the email, please let us know which California privacy right you are exercising and the name of the Job Applicant, so that we can process your request in an efficient manner. We will request that the authorized agent has written permission from the Job Applicant to make requests on the Job Applicant’s behalf (or that the Job Applicant otherwise directly confirms the agent has permission to submit the request) and will need to verify the Job Applicant’s and the authorized agent’s identity.

Verifying Requests

To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. We may verify your identity by requiring you to provide us with some or all of following data elements for verification purposes:

your name;
your postal address, telephone number, or email address; and
the date of your application;

In addition, we may require you to sign a declaration under penalty of perjury that you are the Job Applicant whose personal information is the subject of the request.

Additional Information

If you choose to exercise any of your California privacy rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

HOW WE PROTECT PERSONAL INFORMATION

We maintain administrative, technical and physical safeguards designed to protect the personal information we obtain against accidental, unlawful or unauthorized access, destruction, loss, alteration, disclosure or use.

CHILDREN’S PERSONAL INFORMATION

We do not knowingly collect or solicit personal information online from children under the age of 13 in connection with our collection of Job Applicant’s personal information.

NON-E.L.F. SERVICES AND FEATURES

For your convenience and information, we may provide (for example, on our Careers website) links to or plug-ins of non-e.l.f. websites, apps and services that may be operated by companies not affiliated with e.l.f. In addition, Job Applicants may apply to employment at e.l.f. through third-parties, such as LinkedIn. The privacy practices of the relevant third parties, including details on the information they may collect about you, is subject to the privacy statements of these parties, which we strongly suggest you review. We are not responsible for the privacy practices of any non-e.l.f. websites, apps or services.

UPDATES TO THIS PRIVACY NOTICE

This Privacy Notice may be updated periodically to reflect changes in our personal information practices. Changes to the Privacy Notice will be posted on this page.

HOW TO CONTACT US

If you have questions or concerns about this Privacy Notice, please contact us by email at mwoginrich@elfbeauty.com.

You may also write to us at:

e.l.f. Cosmetics, Inc.
570 10th Street, 3^rd Floor
Oakland, CA 94607
ATTN: Legal Department and HR Department
RE: U.S. Job Applicant Privacy Notice

UK Job Applicant Privacy Notice

Last Updated: June 23, 2023

e.l.f. Beauty UK Limited and e.l.f. Cosmetics, Inc., the parent company of e.l.f. Beauty UK Limited, (collectively “e.l.f.”) respect your concerns about privacy. This UK Job Applicant Privacy Notice (this “Privacy Notice”) describes the types of personal data we obtain about individuals who apply for jobs with e.l.f. and its brands in the United Kingdom (“UK Job Applicants”). Please note that all employment arrangements for the e.l.f. Beauty family of brands are operated in the United Kingdom through our U.K. entity, e.l.f. Beauty UK Limited.

e.l.f. Beauty UK Limited is the controller in respect of personal data of UK Job Applicants in the United Kingdom.

PERSONAL DATA WE OBTAIN

e.l.f. may collect the following categories of personal data about UK Job Applicants:

Identifiers: identifiers, such as a real name, alias, postal address, telephone number, online identifier, email address, and other similar identifiers
Additional UK Job Applicant Data: signature, location, physical characteristics or description, financial information, medical information, race, national origin, religion, age, sex, marital status, and citizenship status
Sensory Information: audio and visual information (for example if you use video or phone interviewing as part of the application process, if you include photographs or videos you may provide in connection with your application, or if you have publicly available social media profiles). If you visit our offices or warehouses, your entry and exit and movements may be monitored by the building’s and our security systems.
Employment Information: professional or employment-related information, such as compensation and benefits, information relating to your current position (for example, job title and job description), résumé information, education details, certifications and professional associations, pre-employment screening and background check information (including criminal records information), and emergency contact information.
Other: job interview notes, responses to screening questions, assessment results, and any other information you provide in connection with the recruitment process.

SOURCES OF PERSONAL DATA

e.l.f. may have obtained personal data about UK Job Applicants from the following categories of sources:

directly from you;
service providers, contractors and other vendors who provide services on our behalf;
recruiting and talent agencies;
publicly available sources such as your social media profiles (for example, LinkedIn, Instagram, TikTok); and
other sources as directed by you.

HOW WE USE PERSONAL DATA

We use personal data for the purpose of processing job applications, evaluating candidates for employment, and carrying out and supporting HR functions and activities, including as described below.

Recruiting; processing job applications; determining suitability for employment; reviewing and evaluating applications; determining salary and other forms of compensation; providing references; reimbursing expenses; making travel arrangements; reviewing hiring decisions; and providing access to facilities.

We process personal data for these general recruitment purposes on the basis that it is necessary for our legitimate interests in ensuring that UK Job Applicants are appropriately qualified and our business is adequately resourced.

Detecting or preventing theft or fraud, or attempted theft or fraud; and facilitating communication with you and your designated contacts in an emergency.

We process personal data for these purposes on the basis that it is necessary for our legitimate interests in managing and administering our business, and ensuring the safety and security of our job applicants, assets, and staff.

Performing data analytics; managing company human resources; and strategic planning.

We process personal data for these purposes on the basis that it is necessary for our legitimate interests in managing and administering our business or because we are required to do so by law.

Complying with legal requirements, such as tax, record-keeping and reporting obligations; conducting audits, management and resolution of health and safety matters; complying with requests from government or other public authorities; responding to legal process such as subpoenas and court orders; pursuing legal rights and remedies; defending litigation and managing complaints or claims; conducting investigations; and complying with internal policies and procedures.

We process personal data for these purposes on the basis that we are required to do so by law, or in accordance our legitimate interests where it is necessary for the establishment, exercise or defense of legal claims.

We may, in limited circumstances and solely to the extent necessary, collect certain types of sensitive personal data for specific purposes, including: the collection of health/medical information in order to accommodate a disability or illness and to establish fitness to work; health and safety and accident information, in order to comply with health and safety law obligations and in order to make insurance claims; securing immigration statuses; and information relating to criminal background checks.

We do not collect your sensitive personal data unless you have provided your explicit consent.

INFORMATION WE SHARE

We may share the personal data we obtain about UK Job Applicants with e.l.f. Beauty, Inc. (the parent company of e.l.f. Cosmetics, Inc.), our subsidiaries and controlled affiliates for the purposes described in this Privacy Notice. We also may share personal data with service providers who perform services on our behalf based on our instructions.

In addition, we may disclose information about you if required to do so by law or if we believe such action is necessary to comply with legal process. We also reserve the right to transfer personal data we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation).

Data Transfers

We may transfer the personal data that we collect about you to recipients in countries outside the United Kingdom, including to e.l.f. Cosmetics, Inc. and service providers located in the United States. Those countries, including the United States, may not provide the same level of protection for personal data as the United Kingdom.

When we transfer your personal data to recipients in other countries (such as the United States), we will comply with applicable legal requirements providing adequate protection for the transfer of personal data to recipients in countries outside of the United Kingdom. In all such cases, we will only transfer your personal data if:

the country to which the personal data will be transferred has been deemed by United Kingdom law to provide an adequate level of protection for personal data;
we have put in place appropriate safeguards in respect of the transfer, for example by implementing standard contractual clauses for data transfers recognized by United Kingdom law; or
we rely on one of the derogations available under United Kingdom law, such as where the transfer of personal data is necessary for us to establish, exercise or defend against legal claims.

You may request a copy of the safeguards that we have put in place in respect of transfers of personal data by contacting us as described in the How to Contact Us section below.

Data Retention

Your personal data is generally retained for the duration of our recruitment process for the role for which you have applied, as necessary to fulfil the purposes described above. We may additionally retain certain of your personal data so that we may contact you about future opportunities at e.l.f. if we haven’t offered you the role for which you have applied.

Retention periods may be extended if we are required to preserve your personal data in connection with litigation, investigations and proceedings, or if a longer retention period is required or permitted by applicable law.

Your Choices

You have the right to request:

confirmation of whether we process personal data relating to you and, if so, to request a copy of that personal data;
that we rectify or update your personal data that is inaccurate, incomplete or outdated;
that we erase your personal data in certain circumstances, such as where we collected personal data on the basis of your consent and you withdraw that consent, or when you object to use of your personal data;
that we restrict the use of your personal data in certain circumstances, such as while we consider another request that you have submitted, for example a request that we update your personal data;
withdrawal of your consent where you have given us consent to process your personal data (this will not affect the lawfulness of our processing prior to such withdrawal);
that we provide a copy of your personal data to you in a structured, commonly used and machine-readable format in certain circumstances; and
that we stop sending you marketing emails or other communications.

You also have the right to object to our use of your personal data in some circumstances.

If you wish to exercise any of your data protection rights or if you consider that we have processed your personal data in violation of applicable law, please contact us as detailed in the “How to contact us” section below.

Please note that the above rights are not absolute, and we may be entitled to refuse requests, wholly or partly, where exceptions under applicable law apply.

If you consider that we have processed your personal data in violation of applicable law, you may also lodge a complaint with the relevant supervisory authority. In the United Kingdom, contact details for the relevant supervisory authority are available here.

How We Protect Personal Data

We maintain appropriate administrative, technical and physical safeguards designed to protect the personal data we obtain against accidental, unlawful or unauthorized access, destruction, loss, alteration, disclosure or use.

Children’s Personal Data

We do not knowingly collect or solicit personal data online from children under the age of 13 in connection with our collection of UK Job Applicant personal data.

Links to Non-e.l.f. Services and Features

For your convenience and information, we may provide (for example, on our Careers website) links to or plug-ins of non-e.l.f. websites, apps and services that may be operated by companies not affiliated with e.l.f. The privacy practices of the relevant third parties, including details on the information they may collect about you, is subject to the privacy statements of these parties, which we strongly suggest you review. We are not responsible for the privacy practices of any non- e.l.f. websites, apps or services.

Updates to this Privacy Notice

This Privacy Notice may be updated periodically to reflect changes in our personal data practices. Changes to this Privacy Notice will be posted on this page .

How To Contact Us

If you have questions or concerns about this Privacy Notice, please contact us by email at mwoginrich@elfbeauty.com.

You may also write to us at:

e.l.f. Beauty UK Limited
c/o e.l.f. Cosmetics, Inc.
570 10^th Street
Oakland, CA 94607 USA
ATTN: Legal Department and HR Department
RE: UK Job Applicant Privacy Notice