Alto Neuroscience, Inc.

Privacy Notice for Job Candidates

Effective Date: July 12, 2024

1. Introduction

This notice (“Notice”) describes the categories of personal information that Alto Neuroscience, Inc. and its subsidiaries (“Company”, “we”, “us” and “our”) collect about individuals who apply or are recruited for a job with us or one of our subsidiaries (“candidates”), and how we use and disclose that information. While the Company does not yet meet the thresholds to be subject to U.S. state consumer privacy laws (such as the California Consumer Privacy Act), we are providing this Notice as a courtesy to our job candidates.

This Notice applies to personal information collected about you in your capacity as a job candidate. See our Privacy Policy for information about our practices when you use our website or otherwise interact with us offline or online in the same manner that a website visitor or someone who is not a job candidate may interact with us.
This Notice does not create or form part of any contract for employment or otherwise.  
If you have questions about this Notice, please contact privacy@altoneuroscience.com.

2. Information we may collect about candidates

2.1 Categories of personal information

We may collect and process the following categories of personal information during the application and recruitment process:

  • Contact information, such as home address, telephone number, and email address;
  • Information from job application materials or recruiters, such as your job application, resume or CV, cover letter, writing samples, references, work history, education transcripts, whether you are subject to prior employer obligations, and information that referrers provide about you;
  • Professional qualifications, such as licenses, permits, memberships, and certifications;
  • Information from the application process, such as any phone-screens, interviews, evaluations and outcomes of recruiting exercises;
  • Immigration status and other information that would allow us to verify your employment eligibility;
  • Biographical information, such as name, gender/gender identity, pronouns, date of birth, professional history, references, language proficiencies, education details, and information you make publicly available through job search or career networking sites;
  • Job preferences, such as desired position and compensation, location preferences and willingness to relocate;
  • Employment history, such as your prior employers, how long you worked with each of your prior employers, and your prior positions;
  • Background check information, such as information necessary to complete background, credit, drug/alcohol and/or other checks when permitted by law, and information received during these checks;
  • Information needed to understand and assess accommodation requests regarding potential disabilities or other health conditions;
  • Medical information if you meet with us in-person, such as your body temperature, health symptoms, vaccination status and other screening information in connection with the Company’s health and safety plans and protocols, including screening required to access Company offices/facilities and other measures designed to prevent the transmission of COVID-19 or other infectious diseases; and
  • Other information you provide to us.

Providing personal information to us is voluntary.  However, if you do not provide sufficient information, we may be unable to consider your application or, if you are hired, your subsequent promotion, transfer or relocation.

In certain cases we may ask you for additional information for purposes of complying with applicable laws.  We may also inquire about criminal and/or credit records. We will do so only where permitted by applicable law.

2.2 Sources of personal information

We collect personal information from you when you apply for a job and throughout the job application or recruitment process.  We may also collect your personal information from other sources and combine it with the personal information you provide us.  For example, we may collect your personal information from:

  • Job board websites you may use to apply for a job with us;
  • Prior employers that provide us with employment references;
  • Professional references that you authorize us to contact;
  • Pre-employment screening services, such as background check providers (where permitted by law);
  • Employment agencies and recruiters;
  • Your educational institutions;
  • Other Company personnel.

This section generally describes our practices currently and during the preceding 12 months.

3. How we use personal information about candidates

3.1 Purposes for which we use personal information

We may use the categories of personal information above for the following purposes:

  • Recruitment management. Managing recruitment generally, such as:
    • operating the careers website we maintain at altoneuroscience.com/careers or any other site to which this Notice is posted (“Careers Site”);
    • recruiting, interviewing and evaluating job candidates;
    • conducting background checks and other pre-employment screening (where permitted by law);
    • analyzing and improving our application and recruitment processes;
    • accommodating disabilities or health conditions;
    • communicating with you regarding your candidacy, opportunities with the Company or about the Careers Site and any changes to applicable terms or policies; and
    • other business operations.
  • Compliance, safety and protection, such as:
    • complying with or monitoring compliance with legal and other requirements, such as tax, audit, recordkeeping, reporting, verifying identity and eligibility to work, and equal opportunities monitoring requirements, where applicable;
    • complying with internal policies and procedures;
    • complying with lawful requests and legal process, such as to respond to subpoenas or requests from government authorities;
    • protecting our, your or others’ rights, safety and property, including by complying with applicable public health guidelines and requirements, including, without limitation, guidance from the Centers for Disease Control or other public health authorities relating to the prevention and control of COVID-19 or other infectious diseases;
    • investigating and deterring against fraudulent, harmful, unauthorized, unethical or illegal activity, or conduct in violation of our policies or procedures;
    • controlling access to and monitoring our physical premises (e.g., by requiring health screenings to access offices/facilities;
    • pursuing legal rights and remedies, including investigating, making and defending complaints or legal claims; administering and enforcing internal policies and procedures; and
    • providing information to government authorities, law enforcement, courts or private parties where we have a good-faith belief it is necessary for the foregoing purposes.
  • Analytics.  Creating anonymous, aggregated or de-identified data that we use and disclose to analyze our application and recruitment activities, business and for other lawful business purposes. We do not attempt to reidentify deidentified information derived from personal information, except for the purpose of testing whether our deidentification processes comply with applicable law.

3.2 Disclosing personal information

We may disclose your personal information to the following parties to facilitate one or more of the purposes described above:

  • Subsidiaries and affiliates. Our subsidiaries and other affiliates under the control of our corporate parent, for purposes consistent with this Notice or to operate shared infrastructure, systems and technology.
  • Company service providers. Companies that provide us with services that help us manage the recruiting process and operate our business, such as job boards, recruiters, interviewing and testing, pre-employment screening, interview travel booking and expense reimbursement (where applicable), relocation (where applicable), and recruitment analytics.
  • Government authorities, law enforcement and others. Government authorities, law enforcement, courts, and others for the purposes described in the Compliance, safety and protection section above.
  • Business transfer participants.  Parties (and their advisors) to transactions and potential transactions pursuant to which we sell or transfer some or all of our business or assets, including your personal information, such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.
  • Professional advisors. Lawyers, immigration advisors, and other outside professional advisors who require your information in the course of providing their services.
  • Other parties not listed above but that are identified at or before the point at which we collect your personal information.

3.3 Retention

The criteria for deciding how long to retain personal information is generally based on whether such period is sufficient to fulfill the purposes for which we collected it as described in this Notice, including complying with our legal record retention obligations and for other Compliance, safety and protection purposes described above.

4. Third Parties

This Notice does not address, and we are not responsible for, the practices of any third parties, which have their own rules for how they collect and use your personal information.  Our links to third party websites or services are not endorsements.

5. Changes to this Notice

We reserve the right to change this Notice at any time.  The “Effective Date” heading at the top of this Notice indicates when it was last revised.  Any changes will become effective when we post the revised notice on our Careers Site.

6. Your obligations

Apart from your obligation to provide complete and accurate information in the recruiting process, it is your responsibility to ensure that information you submit does not violate any third party’s rights.

You should keep your personal information on file with the Company up to date and inform us of any significant changes to it.

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