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Candidate Privacy Statement

Candidate Privacy Statement

Last Reviewed: June 02, 2025

Your privacy is important to Bentley. This Candidate Privacy Statement describes how Bentley Systems, Incorporated and its affiliates relevant to the job in question (‘we’, ‘us’, ‘Bentley’) collect and process personal data about job applicants and prospective candidates (“you”), how we use and protect this data, and your rights in relation to this data under applicable local law.

Specifically, this Candidate Privacy Statement describes our handling of personal data obtained about internal and external job applicants, including through the Bentley online recruitment platform and careers page (the “recruitment system”) directly from job applicants and from third party agencies, recruiters, job search sites, job fairs, recruiting events, colleague referrals, and recruiting platforms. It also describes the handling of personal data of candidates who expressed an interest in receiving information about future Bentley opportunities. Finally, this Statement covers all individuals applying for employment at Bentley, including applications for all types of contingent and non-permanent positions.

LA INFORMACIÓN QUE RECIBIMOS Y RECOPILAMOS

Data we collect directly from you

We may collect the following categories of personal data about you directly from you when you apply for a job with us:

  • Identifiers such as name, surname, and contact information (e.g., your address, email address, and phone number), username and password for the recruitment system;
  • Professional or employment-related information such as information contained in your resume or CV, job history, and other related documents submitted in connection with the application or recruitment process;
  • Education information such as education history, qualifications, and certifications;
  • Protected classifications for diversity recruitment and monitoring where the collection of such data is allowed by applicable local laws (e.g., race, ethnicity, gender, veteran status, and/or disabilities); citizenship or immigration information (e.g., for proof of right to work);
  • Sensitive data some information we collect may be considered sensitive in some jurisdictions, such as username and password for the recruitment system and sensitive information about personal characteristics (e.g., your race, ethnicity, and disability status). For example, in some countries, Bentley may ask for information such as race, ethnicity, or gender for the purposes of monitoring equal opportunity; however, for the purposes of your application we do not require applicants to provide this information. If you provide this information, it will not be considered in the hiring or selection process. To the extent that you provide us with sensitive personal information (race, ethnicity, political opinions or beliefs, membership of a trade union or political party, physical or mental health information, sexual orientation or information related to criminal convictions or offences), you expressly authorize Bentley to handle such information in accordance with this Candidate Privacy Statement;
  • Visual information such as video submissions, interview recordings, headshots, and on-premises location monitoring for security purposes (e.g., video surveillance when attending our premises for an interview);
  • Internet and other electronic network activity such as browser type and operating system; browser history, clickstream data, search history, and information regarding your interaction with a website, application, or advertisement, including access logs and other activity information related to your use of the Bentley recruitment system; the length of time you visit the Bentley recruiting system; and the referring URL, or the website that led you to the Bentley recruiting system;
  • Financial details such as your tax status or financial account information for reimbursements;
  • Inferences such as your preferences, characteristics, soft-skills, and behavior; and
  • Other information you may choose to voluntarily submit to us in connection with your application (e.g., information contained in a cover letter, information disclosed in an interview or information you volunteer regarding your criminal records history, compensation history, family history or personal situation).

To the extent we collect sensitive data or special categories of personal data (as described above), we do so only to the extent necessary for the purposes described in this Candidate Privacy Statement and where required by law will ask for your consent to process this information.

Data we collect from other sources

We may also collect the following types of personal data about you from other sources:

  • Protected classifications for diversity recruitment and monitoring, where the collection of such data is allowed by applicable local laws. Such personal data may be collected directly from you where you choose to provide it;
  • Education information such as educational history details collected from educational institutions you have attended or educational reporting and degree verification providers;
  • Professional or employment-related information such as employment history obtained from employment screening agencies, publicly available registers or databases, former employers and/or educational institutions (as allowed by applicable laws), and information about your performance or conduct from references, other Bentley employees, clients or service providers, or former employers, and
  • Publicly available information from websites or social media including LinkedIn or other job-search platforms, including information you choose to voluntarily submit to us in connection with your application (e.g., when applying through LinkedIn).

Also, as we explain during the recruitment process, Bentley engages a third-party vendor for background screenings. Our approach to background screenings is detailed during the recruitment process and governed by applicable local law. Please also keep in mind that you are responsible for obtaining consent from your references before you provide their personal data to Bentley.

EL USO QUE LE DAMOS A LA INFORMACIÓN RECOPILADA

We aim to only collect and use your personal data for specific and necessary purposes. For example, we use your personal data to:

  • Operate, manage, and improve the recruitment system, job applications and a database of interested individuals;
  • Communicate with you in relation to your expressed interest in Bentley, job opportunities, application, or the recruitment process;
  • Verify your information, including through reference checks, publicly available information (for example, on LinkedIn or other job search platforms) and, where applicable, background checks;
  • Send you information about other positions with the Bentley group of companies which may be of interest to you (where required under applicable law, we will obtain your consent for such communications); and
  • Comply with legal obligations to which we are subject and cooperate with regulators and law enforcement bodies. For example, Bentley may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Certain countries require us to have a legal basis to process your personal data. The precise legal bases might vary by country, but in general, our legal bases to process your personal data are: to comply with our contractual obligations to you or to take steps to enter into a contract with you; to comply with our legal obligations; with your consent; for human resources administration and employment-related purposes, and to meet our legitimate interests (we put in place robust safeguards to ensure that your privacy or other fundamental rights and freedoms are not overridden by our legitimate interest).

When we are required by applicable local laws to collect certain personal data about you, your failure to provide this data may prevent or delay the fulfilment of our legal obligations and may impact our ability to employ you. If we ask for your consent to process your personal data, you may withdraw your consent at any time by contacting us using the details at the end of this Candidate Privacy Statement.

We may also deidentify or anonymize your data in such a way that you may not reasonably be re-identified by us or another party, and we may use this deidentified data for any purpose. To the extent we deidentify any data originally based on personal data, we will maintain and use such information in deidentified form and will not attempt to reidentify the data.

RAZONES POR LAS QUE COMPARTIMOS LA INFORMACIÓN QUE RECOPILAMOS

Bentley does not “sell” or “share” job candidate data as those terms are defined under applicable law. Bentley may, however, disclose your personal data to others in limited situations for our business purposes as follows

  • Affiliates. We may share your personal data with other companies that fall within the Bentley group, for example for recruitment purposes, human resource management and internal reporting. In such cases, we may disclose Identifiers Professional or employment-related information, Education information, Protected classifications Visual information, Sensitive data, Internet and other electronic network activity, Financial details, Inferences, Other information and/or Publicly available information.
  • Service Providers. We may disclose your personal data to our service providers that perform business operations for us related to recruitment process, such as recruitment platform hosting, background check providers, identity verification and other pre-employment screening providers, payment service providers, interview travel booking and expense reimbursement providers. In such cases, we may disclose Identifiers Professional or employment- related information, Education information, Protected classifications Visual information, Sensitive data, Internet and other electronic network activity, Financial details, Inferences, Other information and/or Publicly available information.
  • Legal Services Providers. We may disclose Identifiers, Professional or employment-related information, Education information, Protected classifications Visual information, Sensitive data, Internet and other electronic network activity, Financial details, Inferences, Other information and Publicly available information.
  • Law enforcement agency, court, regulator, tax authority, government authority or other third party. We may share your personal data with these parties if necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, your rights or the rights of any third party.
  • Other Companies. If (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected about you to the other company. As part of the business transfer process, we may disclose certain of your information with lenders, auditors, and third-party advisors, including attorneys and consultants.

Where required by applicable law, Bentley will provide additional disclosures and/or request your consent before disclosing your personal data to such recipients. A list of Bentley’s affiliates can be found in the List of Subsidiaries section of Bentley’s most recent Form 10-K, available under the “Annual Filings” page located here. You may contact us using the details at the end of this Candidate Privacy Statement for information regarding other third parties that may process job applicant and prospective candidate personal data.

YOUR RIGHTS OVER YOUR PERSONAL DATA

You may have certain rights regarding your personal data, subject to applicable local laws, including: the right to access, correct, update, delete, receive a copy of, or restrict or limit our use of your personal data or sensitive personal data, to opt-out of “sales” of personal data or “sharing” of personal data for cross-context behavioral advertising purposes (as these terms are defined under applicable local law), to data portability, and to request an explanation of the rules governing the processing of your personal data in some locations.

These rights may be limited or denied in some circumstances. For example, we may retain your personal data where required or permitted by applicable law. We do not “sell” or “share” your personal data as those terms are defined under applicable local law, nor do we sell or share personal data from individuals under 16 years old. We do not use or disclose sensitive personal data for purposes other than permitted under applicable law.

To exercise your rights under applicable local law or if you are an authorized agent submitting a request on behalf of an individual under applicable local law, please contact us using the contact details provided in the “How to Contact Us” section below. When we process personal data based on your consent, you can withdraw consent at any time with effect for the future. If you would like to confirm your eligibility for or exercise such rights, please contact us at [email protected].

We will contact you if we need additional information from you to honor your requests. When you or your authorized agent contact us in connection with your personal data rights under applicable local law, we will ask you to validate your identity before fulfilling your request. Authorized agents may also be required to provide a copy of the consumer’s signed permission authorizing the agent to submit requests on the consumer’s behalf.

We will not discriminate against you if you choose to exercise your privacy rights.

AUTOMATED DECISIONS

We do not generally make recruiting or hiring decisions based solely on automated decision-making or profiling (as those terms are defined under applicable local laws). In the event that we choose to rely solely on automated decision making and that could have a significant impact on you, or you could be subject to profiling, we will apply the appropriate safeguards as may be required by applicable laws.

DATA RETENTION

We store your personal data and content on our servers, and the servers of our service providers. Because we and our service providers maintain servers in global locations, your personal data may be transferred across national borders and stored outside of the country in which it was collected.

We will retain your personal data until the position you are applying for has been filled, after which we will retain your personal data for a period of time that enables us to comply with our legal obligations, typically twelve (12) months. We will delete your personal data when it is no longer required for these purposes. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the personal data.

DATA SECURITY

We use a combination of reasonable physical, administrative, and technological controls to protect your data from unauthorized access or malicious actions. For more information about our security practices, please visit the Trust Center at https://www.bentley.com/legal/trust-center/.

We limit the access employees, contractors, and agents of Bentley have to your personal data to those who need to know this data to perform their assigned functions and develop or improve our products and services.

INTERNATIONAL DATA TRANSFERS

Bentley is a global company, we transfer personal data across national borders to other countries, in compliance with the laws that apply to that data. For example, if your data is transferred from one of our entities in the European Economic Area (EEA), Switzerland, or the United Kingdom to the United States, or to another country outside of the EEA that does not provide adequate protection for personal data, as determined by the European Commission, we rely on the legal mechanism of Standard Contractual Clauses.

Bentley participates in the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework (collectively, the “Data Privacy Framework”) as set forth by the U.S. Department of Commerce, European Commission, UK Government, and Swiss Federal Administration regarding the collection, use, and retention of personal data transferred from the European Union, the United Kingdom (and Gibraltar), and Switzerland to the United States, and their related principles (the “Data Privacy Framework Principles”). Bentley has certified to the U.S. International Trade Administration within the U.S. Department of Commerce that it adheres to the Data Privacy Framework Principles. If there is any conflict between the terms in this Candidate Privacy Statement and the Data Privacy Framework Principles, the Data Privacy Framework Principles shall govern.

In compliance with the Data Privacy Framework Principles, Bentley commits to resolve complaints about our collection or use of your personal data. EU, UK (including Gibraltar), and Swiss individuals with inquiries or complaints regarding this policy should first contact at: [email protected].

Bentley has further committed to cooperate and comply with the advice of the panel established by the EU data protection authorities (“DPAs”), the UK Information Commissioner’s Office (“ICO”) and the Gibraltar Regulatory Authority (“GRA”), and the Swiss Federal Data Protection and Information Commissioner (“FDPIC”) with regard to unresolved Data Privacy Framework complaints concerning human resources data transferred from the EU, the UK (including Gibraltar), and Switzerland in the context of the employment relationship. If you have such an unresolved complaint, please contact the applicable DPA, the ICO, the GRA, or the FDPIC (free of charge). Under certain conditions, you may have the possibility to engage in binding arbitration to resolve residual disputes. For more information on this option, please see Annex I of the Data Privacy Framework Principles.

Bentley’s commitment to subject the personal information described in this Policy to the Data Privacy Framework is subject to the enforcement and investigative powers of the United States Federal Trade Commission. To learn more about the Data Privacy Framework program, and to view our certification, please visit  https://www.dataprivacyframework.gov/.

Bentley may share personal information with third parties under certain circumstances described above. Bentley’s obligations under the Data Privacy Framework Principles extend to third parties acting as agents who help us run our business and provide services, and Bentley remains liable should a third party acting as our agent process personal information subject to this Policy in a manner inconsistent with this Policy, except where Bentley is not responsible for the event giving rise to the damage.

Where required by applicable law, we will obtain your prior consent in relation to such international transfers. Please click here for a list of the international recipients that may process job applicant and prospective candidate personal data.

If you reside in the People’s Republic of China, we may transfer your data outside of China, in accordance with applicable law.

HOW TO CONTACT US

If you have questions or concerns regarding the way in which your personal data has been used, please contact us via the channels noted above. You can also contact our data protection officer at [email protected].

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the data protection authority in the country in which you reside.

CHANGES TO THE CANDIDATE PRIVACY STATEMENT

We may modify or update this Candidate Privacy Statement from time to time. If we make a material change to this Candidate Privacy Statement, we will notify you of the change.

For more information on Bentley’s general privacy practices (including when you visit Bentley.com or use Bentley products and services in a personal capacity), please see Bentley’s Privacy Statement here.

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