Last Updated: January 1, 2024

This Privacy Notice explains how Turtle Beach Corporation and its subsidiaries and affiliated companies (collectively, “Turtle Beach,” “we,” “our,” or “us”) collects, uses, discloses, and otherwise processes personal information about our California-based recruits and job applicants.

This Privacy Notice is not a contract and does not create any legal rights or obligations. This Privacy Notice also is not intended to replace other notices or disclosures we may provide to you in connection with their application for a job or eventual role in our organization, which will supersede any conflicting disclosures contained in this Privacy Notice.

What is Personal Information?

When we use the term “personal information” in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you within the context of you acting as a recruit or job applicant of Turtle Beach. It does not include aggregated or deidentified information that is maintained in a form that cannot reasonably be used to infer information about, or otherwise be linked to, a particular individual. Where we maintain de-identified data, we will maintain and use the data in deidentified form and not attempt to reidentify the data except as required or permitted by law.

Our Collection of Personal Information

During the recruiting process and when you apply for a job with us, we collect the following professional or employment-related personal information:

• Contact Information: such as full name, email address, home address and telephone number.
• Professional History & Qualifications: such as previous employers, positions, and work experience, professional licenses, certificates or other qualifications, employment references, or referrals, and information relating to potential conflicts with the role you are applying or being considered for.
• Educational History & Qualifications: such as highest level of education, the schools the you attended and when they were in attendance, degrees, certificates, or other educational qualifications the you earned, and the your transcripts or educational references.
• Compensation Information: such as previous or desired salary, bonus, benefits, expenses, and stock or equity grants, as permitted by law.
• Equal Opportunity Information: such as age, race, ethnicity, national origin, citizenship, immigration status, sex, gender identity or transgender status, sexual orientation, religion, disability, or accommodation request, or marital or veteran status when you choose to provide it, but it will not be used in the hiring decision unless specifically permitted by law.
• Web-Related Information: such as technical details about your visits to our online services contained in log files or analytics data relating to their usage and activity on our online services. For more information, please refer to this general Privacy Notice on our website. The Privacy Notice governs our use of information collected from our website visitors. If there is any conflict between our website Privacy Notice and this Job Applicant Privacy Notice, this Job Applicant Privacy Notice will govern with respect to our use of personal information in connection with recruiting and job applications.
• Other Application and Interview Information: any personal information you choose to share with us in an interview or application, CV, resume, transcripts, or other supporting documentation.
• Background Check Data: when permitted by applicable law, we may choose to conduct a background check in connection with your application for purposes such as verifying your professional and educational history and qualifications or identifying criminal history that may be relevant to our consideration of your application. We may request your Social Security Number or other personal information for purposes of conducting the background check. Background check results may include personal data that you have not previously provided to us.
• Inferences: we may generate inferences or predictions about recruits and job applicants, and their abilities, interests, or preferences based on the other personal information we collect and the interactions we have with them.

Although we often collect the personal information described above directly from you, we may also collect certain information from references, recruiters, job-related social media sites (such as LinkedIn), and publicly available sources (such as government records and social media sites). In addition, we may also collect this information through service providers and other third parties that collect it on our behalf, such as communications providers, background check providers, scheduling providers, and application providers.

Please note that some of the information described above may also be considered “sensitive information” under applicable law. For more information, please see the Sensitive Information section below for more information.

Sensitive Information

The following personal information elements we collect may be classified as “sensitive” under certain privacy laws (“sensitive information”):

• Information relating to racial and ethnic origin, citizenship or immigration status, religious beliefs, health, disabilities, sexual orientation, gender identity, and transgender status.

We use this sensitive information for the purposes set forth in the Our Collection and Use of Personal Information section above. Turtle Beach does not use or disclose sensitive personal information for any purpose other than for performing services that would reasonably be expected in connection with job applications (such as considering job applications, conducting background checks and maintaining related records), for detecting security incidents, fraud and other illegal actions, or for short term transient use.

Our Use of Personal Information

We use the personal information we collect during the recruiting process and when you apply for a job with us to:

• Identify you as a potential candidate and review your application for a position with us;
• Verify the information provided to us in connection with their application or received from other sources;
• Determine their eligibility and suitability for the potential position or other opportunities with us;
• Facilitate the recruiting and interview process;
• Communicate with you about the status of your application or other opportunities with us that may be of interest to them;
• Assess and improve the performance and success of our recruiting and hiring process;
• Conduct internal investigations, audits, compliance, risk management, problem resolution, and security operations;
• Fulfill contractual obligations to recruits, applicants and other third parties; and
• Comply with applicable law, rule, regulation, legal proceeding, and government investigations, including relating to tax reporting and immigration.

Please note that if your accept an offer from us, we may transfer the personal information we collected about you during the recruiting and job application process to your personnel file with us.

Our Disclosure of Personal Information

We may share your personal information with the following third parties for the purposes described below:

• Within Turtle Beach: We share personal information relating to recruits and job applicants within our family of companies for internal administrative purposes and uses that are consistent with this Privacy Notice. For example, the Turtle Beach entity responsible for the job posting may share personal information about an applicant with another Turtle Beach entity that is responsible for our organization-wide recruiting and employment decisions.
• Recruiters and Job Application Providers: We often engage recruiters and job application providers to assist us in identifying potential job applicants and processing job applications we receive. In order for these third parties to assist us in the recruiting and job application process, we share personal information about potential and current personnel with them.
• Other Service Providers: In addition to the third parties identified above, we engage other third parties to perform certain functions on our behalf in connection with the uses of personal information described in the Our Collection and Use of Personal Information section above, including assisting us with our recruiting process, personnel management, benefits, and services offerings and other related business operations. Depending on the function the third party serves, the service provider may process personal information on our behalf or have access to personal information while performing functions on our behalf.
• Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third-party during negotiation of, in connection with, or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.
• Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:
• in connection with the establishment, exercise, or defense of legal claims;
• to comply with laws and regulations or to respond to lawful requests and legal process;
• to protect our rights and property and the rights and property of our agents, customers, and others, including to enforce our agreements, policies, and terms of use;
• to detect, suppress, or prevent fraud;
• to reduce credit risk and collect debts owed to us;
• to protect the health and safety of us, our customers, or any person; or
• as otherwise required by applicable law.
• Otherwise with Consent or Direction: We may disclose personal information about our recruits and job applicants to certain other third parties with your consent or direction.

Sales, Sharing or Targeted Advertising

Except as otherwise described in our Privacy Notice in connection with job applicants acting in their capacity as website visitors, we do not sell personal information about individuals acting in their capacity as job applicants, and we do not share or otherwise disclose personal information about individuals acting in their capacity as job applicants to third parties for the purpose of displaying advertisements that are selected based on personal information obtained or inferred over time from an individual’s activities across businesses or distinctly-branded websites, applications, or other services (otherwise known as “targeted advertising” or “cross-context behavioral advertising”).

Retention of Personal Information

We retain personal information only for as long as is reasonably necessary to fulfil the purpose for which it was collected. However, if necessary, we may retain personal information for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and accounting requirements set by a legislature, regulator, or other government authority.

To determine the appropriate duration of the retention of personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.

Once retention of the personal information is no longer necessary for the purposes outlined above, we will either delete or deidentify the personal information or, if this is not possible (for example, because personal information has been stored in backup archives), then we will securely store the personal information and isolate it from further processing until deletion or deidentification is possible.

Your Privacy Choices

California Privacy Rights

As a California resident, you may be able to exercise the following rights (subject to certain limitations at law):

The Right to Know	The right to confirm whether we are processing personal information about you and to obtain certain personalized details about the personal information we have collected about you, including: The categories of personal information collected; The categories of sources of the personal information; The purposes for which the personal information were collected; The categories of personal information disclosed to third parties (if any), and the categories of recipients to whom the personal information were disclosed; The categories of personal information shared for cross-context behavioral advertising purposes (if any), and the categories of recipients to whom the personal information were disclosed for those purposes; and The categories of personal information sold (if any), and the categories of third parties to whom the personal information were sold.
The Right to Access & Portability	The right to obtain access to the personal information we have collected about you and, where required by law, the right to obtain a copy of the personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
The Right to Correction	The right to correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.
The Right to Deletion	The right to have us delete the personal information we maintain about you, subject to certain exceptions.

You also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, please note that if the exercise of these rights limits our ability to process personal information, we may no longer be able to engage with you in the same manner.

Submitting Privacy Rights Requests

To submit a request to exercise one of the privacy rights identified above, please:

• Complete our online form; or
• Call (855) 254-9741.

Before processing your request, we will need to verify your identity and confirm you are a resident of the State of California. In order to verify your identity, we will generally either require the successful authentication of your work-related account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. As a result, we require requests to include full name, email address, home address, and telephone number. We may at times need to request additional personal information from you, taking into consideration our relationship with you and the sensitivity of your request.

In certain circumstances, we may decline a privacy rights request, particularly where you are not a resident of the State of California or where we are unable to verify your identity.

Submitting Authorized Agent Requests

In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.

Updates to This Privacy Notice

We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the “Last Updated” date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify you by prominent posting at the beginning of this Privacy Notice. All changes shall be effective from the date of publication unless otherwise provided in the notification.

Contact Us

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to HR_Privacy@turtlebeach.com.