EU Applicant Privacy Notice

TransMedics Group
Last reviewed: May 2025 

Introduction 

This notice provides an overview of the practices of TransMedics Group, Inc. and its affiliates and subsidiaries (collectively, “us” or “we”), with respect to the collection, use and disclosure, for  recruitment-related purposes, of personal data and sensitive personal data about applicants when applying for a job with us (collectively, “you” or “your”). 

What data do we collect about you?

We collect and process personal data and sensitive personal data relating to you (either directly from you or  from  public  or  third-party  information  sources  such  as  recruitment companies) for the purposes of considering and evaluating your eligibility and suitability for the job role you have applied for. The types of personal data we collect may include, among other things: 

  1. Data you provide to us through your application, including: 
    • Your name and contact details, including address, phone number, email, nationality, title, date of birth, gender, etc. 
    • Your application materials (CV, cover letter, previous work experience, education and transcripts, and our notes from any interviews with you). 
    • Your desired salary, type of employment sought and data available. 
    • Your identification documents (passport number, government identification numbers where permitted, and immigration status). 
    • Any other data you submit to us, including the name of the employer referring you and correspondences you may have with us during the application process.   
  2. Data from other sources: This may include from recruiters, employment research firms, identity verification services, the references you provide to us, websites and other publicly accessible data on the Internet. We will also receive data you submit to us through third-party websites. Where permitted, we collect details of professional registrations, and sanctions with professional bodies, financial checks or criminal convictions where you have consented to background checks.Please ensure you have the consent of any referees whose details you provide alongside your application for us to use their personal data as outlined in this notice.
  3. Information we collect automatically: When you make an application through our online platform, we will collect information sent to us by your computer, mobile phone or other access device. For example, this includes the pages you access, your computer IP address, device identifiers, the type of operating system you are using, your location, mobile network information, standard web log data and other information, your browser type and traffic to and from our site.
  4. Sensitive personal data. We may on some occasions, also collect certain sensitive data about you including: 
    • health checks, information about medical or health conditions, sickness certificates and whether or not you have a disability; 
    • race and religion to monitor equal opportunities; and 
    • criminal record checks and details of the commission or alleged commission by you of any criminal offence. 


How do we use this personal data and what is the legal basis for its use?

We collect, use and store your personal data for the following purposes: 

  1. Where necessary for us to review and assess your application for employment: 
    • This includes assessing your skills and interest in career opportunities with us, processing your application, analysing your qualifications, verifying your identity and eligibility for employment, and communicating with you about your application to respond to your enquiries and schedule interviews.

  2. Where necessary for our  legitimate interests, as listed below, and where these interests are not overridden by your data protection rights: 
    • Protecting our legal rights. This includes, but is not limited to, use in connection with legal claims, compliance, regulatory, auditing, investigative and disciplinary purposes (including disclosure of such information in connection with legal process or litigation) and other ethics and compliance reporting requirements. 
    • Maintaining the security and integrity of our facilities, equipment and electronic platforms. This includes administering access rights, monitoring compliance with company protocols, and where permitted by local law and in accordance with relevant policies, for investigations and disciplinary actions.

  3. Where necessary to comply with a legal obligation: 
    • Disclosures to law enforcement agencies or in connection with legal claims, or regulatory purposes (including disclosure of such information in connection with legal process or litigation).

  4. Where you have given consent: 
    • We may ask for your consent to carry out certain verification and staff background checks where this is required in connection with your role. Where we do process data based on consent, your consent can be withdrawn at any time.

If it is mandatory for you to provide data for these purposes, we will make this clear at the time the data is collected and will also explain what will happen if you do not provide the data.  

How will we share your personal data?

We may share your personal data with the following third parties for the purposes described in this notice: 

  • Service providers: We may share your personal data with third-party service providers who perform services on our behalf or for your benefit, such as background checkers and recruitment agents. 
  • Our affiliates: We may share your personal data with our affiliated entities, including for internal administrative purposes and uses that are consistent with this notice. 
  • Legal or government regulatory authorities: We may disclose your personal data to legal or government regulatory authorities, including in the event that we need to make or defend a legal claim. 
  • Our legal counsel and other legal authorities such as courts/tribunals: We may disclose your personal data in the event that we need to make or defend a legal claim or are legally obligated to assist with a claim made by a third party. 
  • Business transfers: We may disclose your personal data as part of a merger, acquisition, joint venture, or financing or sale of company assets, and your personal data could be transferred to a third party in such a transaction. 

International Data Transfers 

Any information that you provide to us may be stored in the European Union or the United States and is processed by us as set out in this notice. When we share your personal data with the organisations listed above, it may involve transferring your personal data outside of the European Union. In particular, as we are a US-based business, we may transfer your personal data to our affiliates in the United States for the purposes set out in this notice. In order to ensure the protection of your personal data, we have put in place Standard Contractual Clauses approved by the European Commission between TransMedics Group, Inc. and its affiliates and subsidiaries. 

Some of our service providers are also based outside the European Union which means that we need to transfer your personal data to them to in order to obtain the benefit of their services. In such cases we have either: put in place Standard Contractual Clauses approved by the European Commission; obtained your consent to transfer personal data after informing you about the possible risks of the transfer; done so when the transfer is necessary for the performance of a contract between you and us, or between us and a third party where the contract was entered into in your interest, or in order to establish, exercise or defend legal claims; or ensured that the service provider receives your personal data in a country that is deemed by the European Commission to provide adequate protection to your data. 

You can request details regarding the transfer mechanism used for your personal data by contacting us as set forth in the Contact us section below. 

How long will you hold my data?

If your application is unsuccessful, we will retain your personal data only for three (3) years from the expiration of your candidacy or as long as we need it for our legitimate interest in accordance with applicable law, unless you give us permission to hold your records on file for other positions that become available.  

If you accept employment with us, we will retain your personal data throughout your employment in accordance with a separate notice we provide to you upon your acceptance of employment.   

What are my choices and rights?

You may be entitled to: 

  1. ask us for a copy of your personal data; 
  2. to correct, delete or restrict processing of your personal data,  
  3. to obtain the personal data you provide in a structured, machine readable format and ask us to share (port) this personal data to other organisations; and 
  4. object to processing in some circumstances.  

Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to us processing your personal data, this will not affect any processing which has already taken place at that time. 

These rights may be limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your data.  

If you wish to exercise these rights, please contact us as set out below. If you have unresolved concerns you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.  

Updates to this notice 

This privacy notice may be updated periodically and any changes we make will be posted on this page. Please check back frequently to see any updates or changes to the policy. If we change the privacy notice in a material way, we will notify you of this and, if required, we will obtain your consent.  

Contact us

We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns or questions about how we process your data, feel free to contact us, at legalnotices@transmedics.com 

 

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