Applicant Privacy Policy

This Policy was last updated on February 15, 2026.

This Applicant Privacy Policy (this “Policy”) describes how Otter Products, LLC and its affiliates (collectively, “Otter,” “us,” or “we”) collect and process personal information of job applicants during the application and recruitment process. This Policy only applies to job applicants and personal information collected during the application and recruitment process. For further information about how we may collect and process your personal information when you visit one of our websites, please see the privacy policy of the respective website visited.

This Policy explains:

• What personal information we collect during the application and recruitment process.
• How we use, share, and protect it.
• Your rights and choices regarding your information.

Please read this Policy carefully. If you have any questions about this Policy, you may contact us at any time using one of the methods described below. In addition to this Policy, we may adopt region or country specific privacy practices to comply with requirements of the jurisdictions in which we operate.

We will only process your personal information in accordance with this Policy unless otherwise required by applicable law. We take steps to ensure that the personal information we collect about you is relevant and necessary to the application and recruitment process and processed for limited purposes.

Personal Information We May Collect

For the purposes of this Policy, “personal information” (also known as “personal data”) is any information that identifies or could be used to identify an individual. Personal information excludes anonymous or de-identified data that is not associated with a particular individual.

Depending on your interactions with us and how far you proceed with the application and recruitment process, we may collect one or more of the following categories of personal information about you. Not all categories of personal information will be collected or received about every individual.

• Identifiers such as your name, email address, telephone number, home address, social security number (U.S. citizens and residents only), and other similar identifiers.
• Protected Classification Characteristics such as your race, gender, ethnicity, political opinions or beliefs, membership of a trade union or political party, physical or mental health information (e.g., disability status), sexual orientation, religious or philosophical beliefs, data concerning health, genetic and biometric data, and information related to criminal convictions or offences.
• Professional or employment-related information such as references; prior employers; other relevant experience, education, or information contained in your resume or cover letter or provided during the application and recruitment process (including during phone-screenings or interviews); information contained in work authorizations and permits; and details regarding your expectations for employment (e.g., current and/or desired salary and other terms relating to compensation and benefits packages, willingness to relocate, or other job preferences).
• Non-public education information such as transcripts.
• Inferences drawn from other personal information such as opinions from your references about your performance in previous roles, your professional strengths and weaknesses, and your ability to perform the duties of the position for which you applied.

In some circumstances, the personal information we may collect may include sensitive personal information or information that falls under a special category data such as the types of information listed under Protected Classification Characteristics above. If you voluntarily provide us with sensitive personal information, you consent and permit us to handle such information in accordance with this Policy and applicable laws. You may withdraw your consent at any time by reaching out to us via the applicable privacy email address found below.

How We Collect Your Personal Information

We may collect personal information:

• Directly from you when you provide it to us as a job applicant;
• From third parties such as recruitment consultants or tools or in connection with a background, employment, or reference check, subject to your consent where required by law; and
• From publicly available online resources.

If you provide us with personal information of a reference or any other individual as part of your application, it is your responsibility to obtain consent from that individual prior to providing the information to us. By providing the individual’s personal information to us, you are confirming that you have obtained that individual’s prior consent.

We may also collect personal information automatically through cookies and other tracking technologies found on this website. The collection and use of such information is governed by our website’s Privacy Policy. For further information, please see Log Files, Cookies, and Other Tracking Technologies of such policy.

How We Use Your Personal Information

The personal information we collect is used for our business purposes as it relates to our application and recruitment process, which include to:

• Communicate with you throughout the application and recruitment process or contact you regarding other positions for which you may qualify.
• Administer your application and consider your suitability for the role such as assessing your skills and qualifications and determining your eligibility for employment and conducting reference checks.
• Make a job offer and enter into a contract of employment with you such as conducting background checks upon a job offer (where permitted under applicable laws) and assisting with obtaining an immigration visa or work permit (if required).
• Comply with applicable labor or employment laws and regulations, including retaining appropriate recruitment process records and monitoring for equal employment opportunity.
• Any other human resource, health and safety, or compliance purposes applicable to the application and recruitment process.

If you are offered a position and you accept, all personal information you provide to us as part of the application and recruitment processes will become part of your employment record. Upon hire, the personal information you have provided may be subject to subsequent uses with your consent. These additional uses will be described in the employee privacy policy of the specific Otter entity that employs you and will be provided to you upon hire.

European Economic Area (EEA)

For applicants located in the EEA, the lawful bases we use to process your personal information are as follows:

• Your consent;
• The legitimate interests of Otter such as to transmit personal information for internal administrative purposes, protect our legal rights, defend legal claims, and ensure information security (e.g., preventing unauthorized access to our computer systems and data);
• To comply with legal obligations;
• For the performance of a contract; and
• Where necessary to protect the vital interests of you or any person.

Where the collection or processing is based on your consent, you may withdraw your consent at any time, to the extent permitted by applicable law, using our Privacy Request Form.

Who We Share Your Information With

Companies within our Corporate Family

Otter Products, LLC may share your personal information with one of the Otter affiliates listed below when you apply for a position with that Otter affiliate (e.g., when you apply for a position at Otter Products EMEA Unlimited, Otter Products, LLC may share your personal information with Otter Products EMEA Unlimited). Conversely, each Otter affiliate listed below may also share your personal information with Otter Products, LLC.

In each case, your personal information will only be shared as part of the application and recruiting process and pursuant to contractual safeguards. Recipients of your personal information are authorized to only use your personal information limited to the purposes necessary to provide services to the sharing entity.

The legal entity responsible for your personal information will depend on the location of the position(s) for which you apply:

Service Providers and Contractors

We may disclose your personal information to service providers and contractors that assist us with administering the recruitment process such as providing employment verification, background checks, data storage, and data hosting. These third parties are authorized to use your personal information only as necessary to provide these services to us (pursuant to written instructions), must abide by our data privacy and security requirements, and are not allowed to use your personal information for any other purposes. We will always seek to ensure that any third party who handles your personal information will do so in a manner consistent with this Policy and in accordance with applicable law.

Other Third Parties

We may share your personal information with other types of third parties where permitted or required by applicable law, including:

• Regulatory authorities (including tax authorities);
• Government agencies; and
• Parties in legal proceedings involving Otter, including Otter’s legal or other advisors; and
• For the performance of a contract; and
• Third parties with whom Otter is involved in a merger, acquisition, dissolution, sale or all or a portion of its assets, or other fundamental corporate transaction with.

Pursuant to Legal Requests or Requirements

In certain situations, we may be required to disclose personal information in response to lawful requests such as public authority or law enforcement requests, subpoenas, or other types of requests relating to legal proceedings. We reserve the right to disclose your personal information as necessary to comply with these obligations and the law. Additionally, we reserve the right to retain and disclose your personal information when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

Rights Regarding Your Personal Information

Depending on your country or, if located in the United States, your state of residence, you may have one or more of the following rights regarding the collection and use of your personal information:

• Right to know whether we have collected personal information about you and how we process your personal information and the right to access such data. If located in the United, States, depending on your state of residence, you may also be entitled to a list of the specific third parties (or categories) to which we have disclosed your personal data or a list of specific third parties (or categories) to whom we have disclosed any consumer’s personal data if we do not maintain such information in a format specific to you.
• Right to correct (i.e., rectification) any inaccurate or inaccurate or incomplete personal information that we maintain about you.
• Right to delete the personal information about you that we have either collected from you or obtained about you and retained, subject to exceptions in certain countries or states.
• Right to opt out of the processing of your personal information. If located in the United States, this may include the right to opt out of one or more of the following: : (i) the sale or the sharing of your personal information to third parties by us, (ii) the processing of your personal data for purposes of targeted advertising, or (iii) profiling in furtherance of decisions that may have a legal or other significant impact.
• Right to opt out of automated decision making, which allows you to not to have a decision made about you based on automated processing, including profiling. As of the last updated date of this Policy, Otter does not use automated decision-making technology, including profiling, during the application and recruitment process.
• Right to obtain a copy of your personal information in a portable and machine-readable format that allows you to transmit the data to another party without hindrance (i.e., the right to data portability).
• Right to restrict the processing of your personal information.
• • Right not to be discriminated against if you choose to exercise any of the above rights.

Exercising Your Rights

Your Right to Know/Access, Correct, or Delete

To exercise your right to know/access, correct, or delete, please submit your request using our Privacy Request Form or by calling us at 1-855-688-7269.

When you submit one of the above requests, you will be asked to provide the following information about yourself to help us verify your identity:

• First and last name
• Whether you are a customer, employee/former employee, or job applicant
• State of residence or, if located outside the United States, country of residence
• Type of request (e.g., know/access, correct, delete)

The information you provide as part of your request will only be used to verify your identity. You do not need to create an account with us to submit your request. Only you, your authorized agent, or, if the consumer is less than 18 years of age, the consumer’s parent or legal guardian may make a request.

Within ten (10) business days, we will confirm receipt of your request and ask you to verify your identity. Once your identity has been verified, we will endeavor to complete your request within thirty (30) calendar days or as otherwise required by applicable law. If we require more time, we will inform you in writing electronically of the reason for the delay and of the extension period.

Exercising Any of Your Other Rights

To exercise any other rights besides your right to know/access, correct, or delete, please reach out to the applicable privacy email address for the Otter entity to which you are applying or by calling 1-855-688-7269.

Reasons Why We May Deny Your Request

We will exercise commercially reasonable efforts to verify your identity; however, if you do not provide the information necessary for us to verify your identity or fail to respond to our request to confirm your identity and email address, or we are otherwise unable to verify your identity based on the information you provided and the information we maintain, we will be unable to fulfill your original request.

If you make a request to delete your personal information, we may not be able to delete certain personal information, including if it interferes with our regulatory or compliance obligations, affects legal matters, or it involves disproportionate cost or effort.

We may not be able to honor your request to the extent it restricts our ability to comply with applicable laws and regulations or if we believe the information is necessary to exercise or defend a legal claim. Additionally, your request may be denied because the information falls under an exception under applicable law.

If we deny your request, we will notify you and let you know the reasons why we denied your request. To the extent we can honor part of your request, we will honor that portion of your request.

Appealing Our Decision

Requests by Authorized Agents

Certain states allow an authorized agent to submit a data privacy request on your behalf. We may ask your authorized agent to provide proof that you gave such agent permission to submit the request. Additionally, we may also require you to either verify your own identity directly with us or directly confirm with us that you provided the authorized agent with permission to submit a request for you.

Complaints

If you wish to raise a complaint on how we have handled your personal information, you can contact us by emailing us at [email protected]. If you reside in the EEA, you also have the right to lodge a complaint with your applicable Data Protection Authority.

California Specific Disclosures

This section contains additional information required by the California Consumer Privacy Act and applies to California applicants:

• To see the categories of personal information that we have collected and the categories of sources from which we collected such personal information in the past twelve (12) months, please see Personal Information We May Collect and How We Collect Your Personal Information, respectively.
• To see the business purposes for which we have collected and used your personal information for in the past twelve (12) months, please see How We Use Your Personal Information. We have not sold or shared your personal information to any categories of third parties in the past twelve (12) months.
• In addition to the rights described in Rights Regarding Your Information, California residents also have the right to opt-out of sensitive data processing, which gives you the right to request that we limit our use of your sensitive personal information to only that use which is necessary to perform the services or provide our products to you. For further information about how we use your sensitive personal information, please see Personal Information We May Collect.
• We do not sell or share personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization from the parent or guardian of such consumer (the "right to opt-in").

Protection of Personal Information

The security of your personal information is extremely important to us. We use reasonable measures to protect your personal information from loss, theft, unauthorized use, disclosure, and modification. Such measures may include, without limitation, taking steps to ensure the reliability of employees or service providers having access to your data; limiting access rights and ensuring access controls; implementing reasonable authentication procedures, security and privacy training for employees, incident management procedures, and restrictions on storing, printing, and disposing of personal information; and the configuration and management of security protection software on devices that store or transmit personal information.

Although we employ various security measures, there is risk inherent in every internet transaction, no method of electronic transmission or storage can ever be fully secure. Therefore, we cannot guarantee the absolute security of your information. If you have questions about the security of your personal information, or if you have reason to believe that the personal information that we hold about you is no longer secure, please contact us immediately as described in this Policy.

Data Retention

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law. Once we no longer have a legitimate basis or legal right to retain your data, we will retain and securely destroy your personal information in accordance with our document retention policy and applicable laws and regulations. The criteria used to determine our retention periods may include one or more of the following: (i) whether we have an ongoing relationship with you; (ii) legal and statutory obligations; (iii) as advisable in light of our legal position (such as with respect to applicable statutes of limitations, litigation, audits, or regulatory investigations); and (iv) the amount, nature, and sensitivity of the personal information.

International Transfers

To facilitate our operations, we may, subject to applicable law, transfer, store, and otherwise process your personal information outside your country of residence and where information standards may differ. Any transfer of your personal information will be done in accordance with applicable laws and via a means to ensure an adequate level of protection. Some countries are recognized by the European Commission (EC) as providing an adequate level of protection according to EEA standards; however, for transfers to countries that have not been deemed to provide an adequate level of protection by the EC, we have implemented reasonable safeguards to ensure an adequate level of protection governs the transfer and usage of your personal information (e.g., the execution of standard contractual clauses adopted by the EC or participation in an applicable privacy framework).

EU-U.S. Data Privacy Framework with UK-U.S. Extension, and Swiss-U.S. Data Privacy Framework

Otter Products, LLC participates in and has certified its compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. Data Privacy Framework (UK-U.S. DPF), and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF). Otter Products, LLC is committed to subjecting all personal data received from European Union (EU) member countries, the United Kingdom (and Gibraltar), and Switzerland, respectively, in reliance on the relevant parts of the Data Privacy Framework (DPF) Program, to the DPF Principles. To learn more about the DPF, and to view our certification, visit the U.S. Department of Commerce’s Data Privacy Framework List.

Otter Products, LLC is responsible for the processing of personal data it receives, under each DPF, and subsequently transfers to a third-party acting as an agent on its behalf. Otter Products, LLC complies with the DPF Principles for all onward transfers of personal data from the EU, the United Kingdom and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the DPF, Otter Products, LLC is subject to the investigatory and regulatory enforcement powers of the U.S. Federal Trade Commission (FTC). In certain situations, Otter Products, LLC may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based alternative dispute resolution provider (free of charge) at a href="//https://feedback-form.trustarc.com/watchdog/request" target="_blank" rel="noopener noreferrer">TRUSTe Feedback and Resolution System.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Otter Products, LLC commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF in the context of the employment relationship.

Under certain conditions you may invoke binding arbitration when other dispute resolution procedures have been exhausted, as more fully described on the DPF website.

Accessibility

If you need to access this Policy in an alternative format due to having a disability, please contact us at [email protected] [email protected] or call 1-855-688-7269.

Contact Information

If you have any questions or concerns regarding this Policy or our privacy practices, you can contact us at:

Our privacy mailboxes are reserved for privacy related questions only. If you have a customer service inquiry (e.g., a warranty claim, issues accessing your account, order status), please visit our Customer Support Center.