EMEA T. Rowe Price Applicant Privacy Notice

T. Rowe Price International Ltd, 5 Paternoster Square, London EC4M 7DX, and T. Rowe Price (Luxembourg) Management Sàrl, 35, Boulevard du Prince Henri, L-1724 Luxembourg, Grand Duchy of Luxembourg, have prepared this EMEA T. Rowe Price Applicant Privacy Notice (Notice) to be provided to individuals applying for (or exploring) roles with either firm (individually and collectively, “T. Rowe Price,” “we,” and “us”). In addition, you will see a number of references to the “T. Rowe Price family of companies,” which includes other T. Rowe Price entities globally, such as T. Rowe Price Associates, Inc., and T. Rowe Price Group, Inc., both in the United States and their affiliates and subsidiaries.¹

This Notice explains the types of personal data we collect; how we use it; who we share it with, how we protect it; and your legal rights. “Personal data” means information that (either in isolation or in combination with other available information) enables you to be identified as an individual directly or indirectly. Please read the following carefully as it explains our practices regarding your personal data and how it is handled.

T. Rowe Price needs to process your personal data in order to make you aware of roles and to process your application for employment. There are also statutory requirements we have to comply with in relation to your application. If we are not able to carry out the processing activities we describe in this Notice, we may not be able to continue with your application. Of course, we hope it would never come to that; this is simply information we are obliged to provide to you as part of this Notice.

In certain limited circumstances, we may need to ask for your specific consent to process your personal data in a particular way, and in circumstances where that happens it will be clear what we are seeking consent for.

_{¹Certain of our affiliated companies, such as Oak Hill Advisors L.P., may have their own human resources privacy notice or policy that applies to you.}

We may collect personal data directly from you or it may be supplied to us by another party. In most cases, we only allow other parties to carry out the collection of personal data about you when those other parties are acting as a service provider or contractor to us. The retention, use, and disclosure of your personal data by these companies is subject to our contracts and applicable laws. However, certain third parties may carry out collections of personal data under certain circumstances, such as where third parties have direct relationships with you and these companies handle your personal data in accordance with their own privacy notices and applicable laws, such as recruitment agencies and background screening providers.

We may also collect personal data from other publicly or commercially available sources. We may create personal data about you, such as interview notes or records of your progress through the application process. Creation of personal data about you may occur through traditional means or through artificial intelligence (AI), including generative AI.

We may use cookies and other technologies to collect personal data regarding interactions with our digital content, such as our websites, mobile applications, or emails. To learn more about how we use cookies and how you can control your digital experiences, please see our Cookie Policy. We process all data we obtain from you or other sources, including data from your previous employer, or that we create, in accordance with this Notice.

The categories of personal data we may collect, process, maintain, use, and transfer, with your consent if and/or when required by applicable law, during the recruitment process and pre-onboarding stage before you may become an employee of T. Rowe Price include:

• personal information, such as full name, previous names, and nickname; honorifics and titles; gender; date of birth; place of birth; age; passport details; government-issued numbers and identification documents, photos, signature, and nationality;
• contact information, such as your home and work postal addresses, email addresses, contact numbers for telephone and mobile, emergency contact details, and contact details for your current/former employer;
• education, work experience, and your views, such as information about your educational background and degree information; your work experience and other experience and skills included on your application forms, résumés/CVs, or otherwise collected as part of the recruitment process (including any professional credentials and licenses, certifications and memberships and affiliations) and other data from résumés/CVs; biographical data relating to past roles, such as work history, business title, position type and level, and reason(s) for leaving a job; data from social media profiles, such as Facebook, LinkedIn, and similar platforms; information provided during the recruitment process, including professional goals and interests, travel preferences, research/survey data, and other views you have shared with us;
• other application data, such as the information included in your application forms, résumés/CVs, other regulator-issued identifiers that may be used for licensing, registration, and/or compliance purposes (e.g., if you are a licensed professional we may collect your license number); your bank account number and details; current and expected compensation; and your photo if you choose to provide it;
• audio and visual information, such as voicemails, videos, and recorded conference calls;
• information produced or collected as part of the recruitment process, such as applicant number, notes, audio and visual data taken from your interview or information provided from recruitment agencies (e.g., photos, voice prints, and video/audio recordings in video interviews);
• information required for work and immigration visa/permit applications, such as your and your dependents’ full names; contact details; and education and work experience;
• background check information, such as information obtained through reference checks, confirmation about your work/educational background, work visa details, previous addresses, current and past directorships held by you and members of your immediate family, credit history, international credential verification, public safety verification, and adverse media searches;
• technical information when you access our digital content, including your IP address, your login information, browser type and version, device identifier, location and time zone setting, browser plug-in types and versions, operating system and platform, page response times, and download errors;
• information about your interactions with our digital content, such as the websites you visit before our websites; number of visits to digital content; length of visits to certain pages; pages viewed; page interaction information (such as scrolling, clicks, and mouse-overs); and methods used to browse away from the page and similar information for additional materials that can be accessed from our digital content, such as opening or closing documents or which videos are played and for how long;
• information regarding buildings and property, such as CCTV images filmed in and around our APAC offices and other visitor access data where you have attended any of our offices; and
• information relating to compliance matters, such as data subject requests and supporting documentation; records relating to complaints, investigations, incident details, and resolution of such matters; employment eligibility verification records; background screening records; and other records maintained to demonstrate compliance with applicable laws.

In addition to the collection, processing, and use of the types of personal data described above, T. Rowe Price may collect, process, maintain, use, and transfer the following special categories of personal data about you:

• health and medical data, such as information on disability, if you choose to voluntarily provide to T. Rowe Price, for purposes of accommodating your application and interview and compliance with legal obligations;
• religious affiliations, where this has been provided voluntarily to T. Rowe Price for purposes of our equal opportunities and diversity monitoring and initiatives or if disclosed by you voluntarily to help schedule interviews at appropriate times;
• criminal records data, in the event that T. Rowe Price has conducted or received the results of criminal records background checks in relation to you in the process of your application, where relevant and appropriate to the role that you are applying for;
• race or ethnicity data, such as information contained in your passport or other citizenship and right to work documentation, and information that you have voluntarily provided to T. Rowe Price for the purposes of our equal opportunities and diversity monitoring and initiatives;
• sexual orientation data, where this has been provided voluntarily to T. Rowe Price for the purposes of our equal opportunities and diversity monitoring and initiatives; and
• other types of personal data that may be defined as sensitive personal data according to applicable local law.

We use the personal data we collect from and about you and process it for a variety of purposes related to your application or other interactions with us and the running of our business generally, which are based on one or more legal justifications, as set out below:

When relying on the legitimate interests basis for processing your personal data, we will balance the legitimate interest(s) pursued by us and any relevant third party with your interest(s) and fundamental rights and freedoms in relation to the protection of your personal data to ensure that it is appropriate for us to rely on legitimate interests and to identify any additional steps we need to take to achieve the right balance.

We may use AI, including machine learning, as part of our business operations for one or more of the purposes set out above, which involve the processing of your personal data. For example, we may use tools powered by AI to assist us with identifying and considering suitable candidates for our vacancies or to assist with our information security programmes. When we communicate with you, this may also be powered by or incorporate AI.

We may use AI, including machine learning, as part of our business operations for one or more of the purposes set out above, which involve the processing of your personal data. For example, we may use tools powered by AI to assist us with identifying and considering suitable candidates for our vacancies or to assist with our information security programmes. When we communicate with you, this may also be powered by or incorporate AI.

Your personal data may also be processed as part of the training, testing, and use of AI to support one or more of the purposes set out above. Where we use AI, we do so in accordance with applicable law and our policies and procedures.

Your personal data is intended for T. Rowe Price and may be disclosed within the T. Rowe Price family of companies and, in certain circumstances, to third parties, including to other parties as directed by you.

We may disclose your personal data to:

• T. Rowe Price's family of companies. As the T. Rowe Price entity that you are applying to work for or interacting with is part of a wider group of companies with headquarters in the U.S. and offices located across the globe, which all partially share management, IT, human resources, legal, compliance, finance, and audit responsibility, we may disclose your personal data among the T. Rowe Price family of companies, including our subsidiaries and affiliates, in order to process your application and to conduct the relevant activities described in this Notice. Due to the global nature of T. Rowe Price, the T. Rowe Price family of companies participate in a centralised management of the group, and thus the transfer of personal data within, and among, the T. Rowe Price family of companies is necessary to support the functions in different business contexts. Our family of companies includes subsidiaries and affiliates whose names include “T. Rowe Price,” “Oak Hill Advisors,” and “OHA.”

We may also disclose your personal data to the following types of other organisations:

• External auditors, accountants, background check service providers, legal, and other professional advisors.
• Our service providers. We use other companies or contractors (service providers) to perform services on our behalf or to assist us with the operation of T. Rowe Price business. For example, when you use our online portal to apply for employment, the HR information database is currently operated by a service provider. While we may use a service provider to assist in relation to any of the purposes for which we may collect personal data, they generally fit within one or more of the following categories of service providers:
  • Infrastructure and technology service providers;
  • Analysis, research, event, and communications providers; and/or
  • Providers of administrative services for T. Rowe Price, such as recruiting agencies, relocation and visa application providers, and travel services.
  In the course of providing such services, these service providers may have access to your personal data. However, we will only provide our service providers with the information that is necessary for them to perform the services. They will act under our instructions, and we instruct them not to use your personal data for any other purpose. We will always use our best efforts to ensure that all the service providers we work with will keep your personal data secure.
• Other parties permitted by law. In certain circumstances, we may be required to disclose your personal data in order to comply with a legal or regulatory obligation (for example, we may be required to disclose personal data to the police, regulators, government agencies, or judicial or administrative authorities). We may also disclose your personal data to other parties where disclosure is both legally permissible and necessary to protect or defend our rights, in matters of national security, for law enforcement purposes, to enforce our agreements, or to protect your rights or those of the public.
• Other parties in connection with ordinary business activities. We may disclose your personal data, such as your business contact details, photo, and biographical information collected during the application process, to other parties with which we or another member within the T. Rowe Price family of companies interact in the ordinary course of business, such as when you are included on an email with others or to confirm your details or role.
• Other parties connected with business transfers. We may transfer your personal data to other parties (including existing or newly formed companies in the T. Rowe Price family of companies) in connection with a reorganisation, restructuring, merger, acquisition or transfer of assets, provided that the receiving party agrees to treat your personal data in a manner consistent with this Notice.

The personal data that we collect from you may be transferred to, and stored at, a destination outside the jurisdiction in which you are located.

If you are located in the European Economic Area (EEA) or the United Kingdom (UK), this means the personal data may be transferred to, stored at, and accessed from a destination outside the EEA or UK, including to T. Rowe Price Associates, Inc., in the United States. It may also be processed by staff operating outside the EEA or UK and who work for us, for an affiliate, or for one of our service providers. If you are located outside the EEA or UK, then in addition to the above, this means that personal data may be transferred to, and stored at, a destination in the EEA or UK.

For transfers to T. Rowe Price entities that are not in the EEA or UK, T. Rowe Price will be bound by the EU Standard Data Protection Clauses (pursuant to Article 46(2)(c) General Data Protection Regulation) or the UK’s International Data Transfer Addendum to such Clauses (as applicable) or other appropriate safeguards to ensure that your data is protected adequately. You can ask for a copy of our appropriate safeguards by contacting us as set out below under “Contact us.”

You have various rights in connection with our processing of your personal data, each of which is explained below. If you wish to exercise one or more of these rights, please contact us as stated below under “Contact us,” and include your name, email, and postal address as well as your specific request and any other information you think would be useful in order for us to process your request.

• Access. You may have the right to confirm with us whether your personal data is processed, and if it is, to request access to that personal data including the categories of personal data processed, the purpose of the processing and the recipients or categories of recipients. We do have to take into account the interests of others, however, and other applicable exceptions that may apply, so this is not an absolute right, and we may be entitled to charge a fee.
• Rectification/Correction. You may have the right to rectify or correct inaccurate or incomplete personal data concerning you. In addition, where you have used an online portal to load your personal data, and where there is functionality that allows you to do so, you may access, review, and update your personal data directly.
• Deletion. You may have the right to ask us to erase personal data concerning you, except we are not obligated to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
• Restriction. In limited circumstances, you may have the right to request that we restrict processing of your personal data. This may apply where you believe such data to be inaccurate, that our processing is unlawful, or that we no longer need to process such data for a particular purpose; however, this right is not absolute. Where we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it, we would mark stored personal data with the aim of limiting particular processing for particular purposes in accordance with your request, or otherwise restrict its processing.
• Portability. You may have the right to receive personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format and you may have the right to transmit that data to another entity.
• Objection. Under certain circumstances you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data, including profiling (profiling is not a standard practice, so when applicable), by us, and we can be required to no longer process your personal data. This may include requesting human intervention in relation to an automated decision (when applicable) so that you can express your view and to contest the decision. This right is not absolute and may not apply in certain circumstances.
• De-registration. Where you have registered an account with us (for example when you use our online portal to apply for a job), you may have the right to request deregistration of your account.
• Make a Complaint. You also have the right to lodge a complaint with the competent data protection supervisory authority, which in Luxembourg is the Commission Nationale pour la Protection des Données (CNPD) or in the UK is the Information Commissioner's Office (ICO). If you are based in, or the issues you would like to make a complaint about took place elsewhere in the EEA, a list of other local data protection authorities in these locations can be found here and for Switzerland can be found here. If you are based in, or the issue you would like to make a complaint about relates to any other location, please contact us as stated below under "Contact us."

If we need additional information to verify your identity, we will let you know. We will endeavour to respond to a verified request within a month after receipt, unless there are grounds for extending our response time frame. In the event of an extension, we will explain to you why the extension is necessary. In some cases, your ability to exercise a right will be limited, as required or permitted by applicable law. If we cannot fulfill your request because we cannot verify your identity or due to exceptions under applicable law, we’ll let you know in our response.

We will only retain your personal data for as long as it is necessary for the purpose for which the data was collected and to the extent permitted by applicable laws. For example, we may retain certain details and correspondence until the time limit for claims arising from the interaction has expired or to comply with regulatory requirements regarding the retention of that data. When we no longer need to use your information, we will remove it from our systems and records and/or take steps to promptly anonymise it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which we are subject).

We have implemented technical and organisational security measures in an effort to safeguard personal data in our custody and control. Such measures we have implemented include limiting access to personal data only to employees, contractors, and authorised service providers who need to know such information for the purposes described in this Notice; training for our employees and contractors; and other technical, administrative, and physical safeguards. While we endeavour to always protect our systems, sites, operations, and information against unauthorised access, use, modification, and disclosure, due to the inherent nature of the internet as an open global communications vehicle and other risk factors, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others, such as hackers.

This Notice is written in English and may be translated into other languages. In the event of any inconsistency between the English version and the translated version, the English version shall prevail.

If you have questions about this Notice or if you would like to exercise your rights as a data subject, you can get in touch with the right person here: International_HR@troweprice.com or through the post at:

International HR
T. Rowe Price
5 Paternoster Square, London EC4M 7DX.