Applicant Privacy Notice

Last Updated: October, 2025

Tilting Point Media, LLC (together with its subsidiaries, “Tilting Point,” “we,” “us,” or “our”) is committed to protecting the privacy and security of personal data that you provide in connection with your application to or recruitment with Tilting Point. This Applicant Privacy Notice (this “Notice”) describes our practices with respect to the collection, use, disclosure, and other processing of your personal data in connection with your process of applying to Tilting Point.

Please note that data protection and privacy laws differ from jurisdiction to jurisdiction where Tilting Point has employees or business operations. This Notice includes additional information for applicants in the European Union or the United Kingdom (collectively, “Europe”) in the section titled “ADDITIONAL INFORMATION FOR EUROPEAN EMPLOYEES,” and additional information for applicants in California in the section titled “ADDITIONAL INFORMATION FOR CALIFORNIA EMPLOYEES.”

This Notice does not create or form part of any employment contract or otherwise.

This Notice does not govern the general collection and privacy practices of any third party websites or online services where our job openings may be posted, including any third-party job search, recruiting, or career networking websites. We encourage you to read the privacy policies of any websites or online services you engage with to understand how the personal information collected by those websites or online services may be processed, such as through the website’s use of cookies and similar technologies.

This Notice covers the following topics:

  • 1. CONTROLLER
  • 2. COLLECTION OF PERSONAL DATA
  • 3. PURPOSES OF PROCESSING PERSONAL DATA
  • 4. DISCLOSURE OF PERSONAL DATA
  • 5. RETENTION OF PERSONAL DATA
  • 6. INTERNATIONAL TRANSFER OF PERSONAL DATA
  • 7. SECURITY OF PERSONAL DATA
  • 8. THIRD PARTY SERVICES
  • 9. YOUR RIGHTS
  • 10. ADDITIONAL INFORMATION FOR EUROPEAN EMPLOYEES
  • 11. ADDITIONAL INFORMATION FOR CALIFORNIA EMPLOYEES
  • 12. YOUR OBLIGATIONS
  • 13. CHANGES TO THIS NOTICE
  • 14. CONTACT US

1. CONTROLLER

For most applicants, Tilting Point Media, LLC located at 360 NW 27 Street, Miami, Florida, 33127is the potential employer and data controller of your personal data. By “data controller,” we mean the entity that determines how and why personal data is processed.

For applicants in Spain, the potential employer and data controller of your personal data is Tilting Point Media S.L.U. are the data controller, located at Carrer de Laforja, 12, Principal 1ª 08006, Barcelona, Spain.

For applicants in Korea, the potential employer and data controller personal is Tilting Point Korea LLC located at Justco Pinnacle Gangnam 8th floor, 343, Hakdong-ro, Gangnam-gu, 060660, Seoul, Republic of Korea.

2. COLLECTION OF PERSONAL DATA

We may collect and use various categories of personal data about you as part of the application or recruitment process. For example, we collect personal data when you provide it to us (such as when you submit your application and CV or resume), from our service providers (e.g., recruitment agencies or job boards that send us your application), from Tilting Point personnel who may have referred you, and in other circumstances. The categories of personal data we may collect and process include the categories listed below. Please note, not all categories may be relevant to you based upon your where you live or the Tilting Point company with whom you are applying.

  • Contact information, such as name, home address, personal email and phone, work address, work email and phone, or social media handles.
  • Identification information, such as government-issued identification numbers (e.g., social security number, National insurance number, driver’s license number, passport number), candidate ID, or other similar identifiers.
  • Demographic information, such as date of birth/age, nationality, race, gender, sexual orientation, military/veteran status, marital status, or disability details.
  • Qualifications, such as professional or employment history, references, language proficiencies, professional qualifications, references, information in your company biography, information in your social media profiles, and other personal data collected during the recruitment and onboarding process.
  • Education information, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
  • Immigration status and other information that would allow us to verify your employment eligibility.
  • Screening and application information, such as background checks (where permitted by law), drug or alcohol tests, and other screens permitted by law, and other information reasonably necessary to assess your application or otherwise engage in our hiring or recruitment activities.
  • Audio, electronic, visual, or similar information, such as information about your access to offices and facilities (e.g., keycard scans or security camera footage).

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

Tilting Point will make reasonable efforts to ensure that your personal data is accurate, complete and up-to-date for the purposes for which it is to be used, including information disclosed to third parties. In most cases, we will rely on you to ensure that information is correct, accurate and complete.

3. PURPOSES OF PROCESSING PERSONAL DATA

We process your personal data to establish, manage or terminate your employment relationship with us, and for other purposes to the extent permitted or required under applicable law. For example, we may process your personal data for the following purposes:

Recruitment management. Managing the recruitment process generally; recruiting, interviewing, and evaluating job candidates; confirming eligibility for employment; 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; administering travel reimbursement (if applicable); communicating with you regarding your candidacy or opportunities with Tilting Point; and other business operations. This processing is based on the performance of the employment contract (or potential employment contract) or, in some cases, your consent where that consent is required or permitted by applicable law.

Business operations. Operating and managing our business, including managing Tilting Point communications and IT systems; research, development, and operation of our products or services; managing and allocating Tilting Point assets and personnel; strategic planning and project management; business continuity; maintenance of business and audit records; budgeting, financial management, and reporting; internal communications; information security; and evaluating and undergoing mergers, acquisitions, sales, re-organizations, or disposals and integration with purchasers.

Legal compliance, safety, and fraud prevention. Complying with legal obligations, such as tax, audit, recordkeeping, reporting, verifying identity, and eligibility to work, workers compensation, disability, worker safety, and equal employment opportunities monitoring requirements; complying with lawful requests and legal processes, such as responding to subpoenas or requests from government authorities and law enforcement; protecting our, your, or others’ rights, safety, and property; investigating and deterring against fraudulent, harmful, unauthorized, unethical, or illegal activity, or conduct in violation of our policies or procedures; pursuing legal rights and remedies, including investigating, making and defending complaints, grievances, suspected violations, or legal claims; administering and enforcing internal policies and procedures; and sharing information with government authorities, law enforcement, courts or private parties for the foregoing purposes.

Monitoring. Monitoring offices and facilities, IT and communications systems, devices, equipment and applications through manual review and automated tools such as security software, website and spam filtering, and monitoring our physical premises (e.g., by using security cameras and keycard scans) to protect our, your or others’ rights, safety and property; operate, maintain and protect the security of our network systems and devices; protect our proprietary and confidential information and intellectual property; for recordkeeping and archiving; for personnel training and/or performance management; for the compliance, safety and fraud prevention purposes described above; to investigate and respond to security and other incidents; and for business continuity.

Analytics. Tilting Point may create various profiles about an applicant’s preferences, characteristics, behavior, attitudes, intelligence, abilities, and aptitudes. Tilting Point may also create anonymous, aggregated, or deidentified data that we use to analyze our recruitment management, business operations, and for other lawful business purposes.

Artificial Intelligence (AI) and Automated Decisionmaking Technology. Our recruitment and hiring processes may be supported by applications or services that use AI or automated decisionmaking technology as part of the services that they provide to us. For example, we may use AI in some jurisdictions to help us screen candidacies to match profiles, to support human interviewing, or to screen for AI-generated content on candidate technical assessments. Please note, additional privacy policies or notices may apply when your personal information is used in connection with these technologies.

Research and Development. Creating anonymous, aggregated, or de-identified data that we use and share to analyze our workforce and business and for other lawful business purposes.

With your consent. In accordance with your prior direction or, in some cases, we may specifically ask you for your consent to collect, use, or share your personal data where permitted by law, such as circumstances where your decision not to consent will have no adverse consequences.

4. DISCLOSURE OF PERSONAL DATA

We may disclose personal data as necessary for the purposes described above. By way of example and not limitation, we may disclose your personal data to the following entities or persons:

Affiliates. Our corporate parent, 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.

Tilting Point service providers. Providers of services to Tilting Point, such as third parties that assist us with recruitment, application processing, human resources, training, travel, transportation and lodging, IT systems and support, information security, or background checks and other screenings.

Government authorities and law enforcement. Government authorities, law enforcement, or courts to protect our, your, or others’ rights, health, safety, and property; investigate and deter fraudulent, harmful, unauthorized, unethical, or illegal activity; investigate conduct in violation of our policies or procedures; or pursue legal rights and remedies, including investigating, making and defending complaints, grievances, suspected violations, or legal claims.

Business transfer participants. Parties to transactions and potential transactions whereby we sell, transfer, or otherwise share some or all of our business or assets, including personal data, such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

Professional advisors. Accountants, auditors, lawyers, insurers, bankers, and other outside professional advisors who require personal data in the course of providing their services.

5. RETENTION OF PERSONAL DATA

Personal data may be stored in hard copy or electronic format locally within the office where you apply as well as in the United States or other countries in which a Tilting Point company or our service providers operate. Your personal data may be transferred into our human resources system in the United States and used to manage your recruitment and hiring, may become part of your personnel file if you are hired, and may be used for other recruitment or hiring-related purposes.

We will retain your personal data, including your CV/resume and any information provided during the recruitment process, for a maximum period of two (2) years from the date of receipt. This allows us to consider your application for future job opportunities that may arise. After this period, your data will be securely deleted or anonymized, unless you renew your consent for us to keep it for a longer period or you become employed by us (in which case your data will be processed in accordance with our employee privacy policy).

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

6. INTERNATIONAL TRANSFER OF PERSONAL DATA

Tilting Point is part of a multinational group of companies and may utilize service providers in jurisdictions inside and outside of the jurisdiction where you reside. Accordingly, your personal information may be disclosed to our personnel or service providers inside or outside of your jurisdiction of residence or employment in connection with the purposes outlined in this Notice, and may be subject to access by foreign governments, courts, law enforcement, or regulatory agencies under the laws and regulatory requirements of those jurisdictions.

Employees in Europe can view more information about transfers of their personal data in the section below titled “ADDITIONAL INFORMATION FOR EUROPEAN EMPLOYEES.”

7. SECURITY OF PERSONAL DATA

We use reasonable and appropriate administrative, technical, organizational, and physical security measures to help maintain the confidentiality and security of personal data and prevent personal data from becoming disclosed to individuals who are not described in this Notice. While we attempt to protect the information in our possession, no security system is perfect and we cannot promise that information about you will remain secure in all circumstances.

8. THIRD PARTY SERVICES

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.

9. YOUR RIGHTS

In some cases, the privacy laws in your jurisdiction may provide you with rights in respect of the personal data that we process about you. Subject to applicable law, those rights may include:

  • Right to Access. Provide you with information about our processing of your personal data and give you access to your personal data.
  • Right to Correct. Update or correct inaccuracies in your personal data.
  • Right to Delete. Delete your personal data.
  • Right to Portability. Transfer a machine-readable copy of your personal data to you or a third party of your choice.
  • Right to Restrict Processing. Restrict certain processing or disclosures of your personal data.
  • Right to Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal data that impacts your rights.
  • Right to Withdraw Consent. If we rely upon your consent to process your personal data, and to the extent permitted by applicable law, you have the right to withdraw your consent at any time.

You may contact privacy@tiltingpoint.com to request to exercise rights that are available in your jurisdiction.

Please note that these rights are not absolute, may not apply to you in your jurisdiction, may not apply to certain personal data that we process, or may be subject to limitation or exemption under applicable law.

10. ADDITIONAL INFORMATION FOR EUROPEAN APPLICANTS

This section applies only to Tilting Point applicants in Europe (the UK and the EU) and provides additional information relating to our requirements under European data protection law.

Our Legal Basis for Processing Your Personal Data. Tilting Point uses personal data where it is necessary to do so for the performance of a potential employment or other contract, where it is required by law (including employment law obligations), based on the applicant’s consent, if applicable, or where it is necessary for the legitimate performance of Tilting Point’s business interests and there is no unwarranted impact on the applicant’s interests or rights. We have a legitimate interest in the processing and transfer of applicant personal data to evaluate applications for employment, for group company internal business purposes, including to manage the centralization of data processing activities, to design efficient and workable business processes, to make business processes more efficient and cost effective, and for any other purpose described in this Notice or at the point of collection of personal data.

Tilting Point will not use personal data for any other purpose incompatible with the purposes described in this Notice, unless it is required or authorized by law, authorized by the applicant, or is in the applicant’s own vital interest (e.g., in the case of a medical emergency).

Transfers of Personal Data. We only transfer personal data outside the EEA or the UK if there is legally adequate data protection mechanism in place. If we transfer your personal data to a country outside of the EEA or the UK such that we are required to apply additional safeguards to your personal data under European data protection laws, we will do so. Please contact us at privacy@tiltingpoint.comfor further information about any such transfers or the specific safeguards applied.

Data Protection Authorities. We encourage all applicants to contact us regarding any questions, concerns, or complaints regarding our processing of your personal data. European applicants may also file a complaint with their local data protection authority. In the European Economic Area, you can find your data protection regulator here. In the United Kingdom, you can lodge a complaint with the UK Information Commissioner’s Office here.

11. ADDITIONAL INFORMATION FOR CALIFORNIA APPLICANTS

This section applies only to applicants who are California residents and supplements the practices described elsewhere in this Notice. It describes how we collect, use, sell, share, and retain personal data of California residents, and their rights with respect to their personal information. For purposes of this Notice, when we use the term “personal data” we are referring to “personal information” as that term is defined in the California Consumer Privacy Act of 2018, as amended (the “CCPA”). This section does not address information exempted from the scope of the CCPA.

CCPA Categories of Personal Data Collected. The categories of personal data we may collect, or have collected in the 12 months preceding the “Last Updated” date of this Notice, and process in connection with your application are described below (additional details about each category are described above in the section titled “COLLECTION OF PERSONAL DATA”).

  • Identifiers, including contact information and identification information.
  • Protected classifications, including demographic information and disability or medical conditions.
  • Professional or employment-related information, including qualifications, immigration status, and screening and application information.
  • Audio, electronic, visual, or similar information, such as information about your access to offices and facilities (e.g., security camera footage).
  • Sensitive personal information, including health information and certain protected classifications listed above.
  • Education information, as described above.

To the extent that we collect sensitive personal information (as defined under the CCPA), we only use or disclose it for purposes permitted under the CCPA (e.g., to perform recruitment or hiring activities, monitor for security incidents, and for compliance and safety purposes). We do not collect or use sensitive personal information for the purpose of inferring characteristics about California applicants.

Sources of Personal Data. We collect personal data directly from you during your candidacy for a job.

We may also collect your personal data from various other sources and combine it with the personal data you provide to us. For example, we may collect your personal data from:

  • job board websites you may use to apply for a job with us;
  • prior employers, when they provide us with employment references;
  • professional references that you authorize us to contact;
  • providers of background check, credit check, or other screening services (where permitted by law);
  • your public social media profiles or other publicly available sources;
  • employment agencies or recruiters;
  • your related persons who chose to communicate with us directly;
  • company communications and IT systems/applications that automatically collect information about, and transmitted by, users; and
  • Tilting Point personnel.

Business Purposes for Disclosing Personal Data. We may disclose, and during the 12 months preceding the “Last Updated” date of this Notice may have disclosed, each of the categories of personal data we collect with other parties as necessary for the business purposes described in this Notice or as described at the time of collection, including the persons or entities listed in the section above titled “DISCLOSURE OF PERSONAL DATA.”

We do not and, during the 12 months preceding the “Last Updated” date of this Notice, have not “sold” or “shared” personal data about applicants. Further, we do not knowingly “sell” or “share” the personal data of California residents under 16 years of age.

Your California Privacy Rights. California applicants may exercise the rights listed below by contacting us as described at the beginning of this Notice. However, these rights are not absolute, and in certain cases we may not be able to respond to your request, such as when a legal exemption applies or if we are not able to verify your identity.

  • Know/Access. You can request the following information about how we have collected and used your personal data:
    • The specific pieces of personal data we have collected about you;
    • The categories of personal data we have collected about you;
    • The categories of sources from which the personal data is collected;
    • The categories of personal data that we sold or disclosed for a business purpose about you;
    • The categories of third parties to whom the personal data was sold or disclosed for a business purpose; and
    • the business or commercial purpose for collecting or selling personal data.
  • Delete. You can ask us to delete the personal data that we have collected from you.
  • Correct. You can ask us to correct inaccurate personal data that we maintain about you.
  • Nondiscrimination. You are entitled to exercise the rights described above free from discrimination.

To submit a request, please contact us using the contact information at the bottom of this Notice.

We may need to confirm your identity to process your requests to know/access, delete, or correct. In addition, consistent with California law, you may designate an authorized agent to make a request on your behalf. If you do so, we may require proof of your identification, the authorized agent’s proof of identification, and any other information that we may request in order to verify the request, including evidence of valid permission for the authorized agent to act on your behalf. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

12. YOUR OBLIGATIONS

Among other obligations, including without limitation the obligation to provide complete and accurate information in recruiting documents and processes, it is your responsibility to ensure that information you submit does not violate any third party’s rights.

You should keep your personal data on file with Tilting Point up to date and inform us of any significant changes to it.

13. CHANGES TO THIS NOTICE

Tilting Point reserves the right to change, amend, or alter this Notice at its sole discretion. Tilting Point will publish and make available to you any revised, amended, or altered Notice and post the date it was last updated at the top of this Notice.

14. CONTACT US

If you have any questions regarding this Notice or complaints regarding Tilting Point’s compliance with this Notice, you should first contact privacy@tiltingpoint.com. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of your personal data in accordance with this Notice.

If Tilting Point needs, or is required, to contact you concerning any event that involves personal data about you, we may do so by email, telephone, or mail.