Netflix is serious about our efforts to support a safe and respectful work environment. As part of that effort, we ask all who work with us (either as employees, contingent workers, or in any other capacity) to review and acknowledge Netflix's Commitment to Respect policy. Although the policy speaks of "candidates" and "employees" it equally applies to any other person working with us. Additionally, our Insider Trading Policy and Contingent Worker Privacy Notice apply to anyone with access to our physical sites and/or systems, or tools. Our Contingent Worker Privacy Notice applies to contingent workers with whom we collect personal information while you are working with Netflix.
Please review the below policies & notices.
rv. 09-2023
Our Commitment to Respect
At Netflix, we believe you are part of a great team of stunning colleagues and you deserve the best working environment. That’s why it’s critically important to us that you are treated equally, respectfully and feel safe in your workplace. But we need your help. We all have a responsibility to help create an inclusive and respectful work environment. We want to make sure that fun, creativity and innovation thrive, but never in a way that hurts you or someone else.
Let’s talk equality
You deserve the chance to thrive here, no matter who you are. We’re committed to diversity and inclusion and won’t treat any employee or candidate differently because of what are called “protected categories.” Protected categories are things like race, religion, color, ancestry, national origin, caste, sex, sexual orientation, gender, gender identity or expression, age, disability, medical condition, pregnancy, childbirth, genetic makeup, marital status, military service, and others depending on local laws. We’re committed to this in any aspect of your employment, including in recruitment, hiring, placement, job assignment, compensation, promotion, transfer, benefits, training, demotion, discipline, grievance, or dismissal.
Our inclusive work environment also extends to transgender and gender non-conforming employees. This means that employees should feel safe to express their gender identity or characteristics without fear of consequences. If you’re transitioning, work with your direct manager and Talent partner to let them know if you have any specific needs or concerns.
We all have different needs, so we’re happy to provide reasonable accommodations, consistent with local law, if you have a disability. Generally, a reasonable accommodation is a modification to a job or the work environment that will allow an employee with a disability to continue to do their job (or allow an applicant to go through the application process). Talk to your hiring manager or recruiter (for candidates) or direct manager or Talent partner (for employees) if you think you need an accommodation.
Diversity and inclusion is critically important to us, so any action that’s out of line with this policy won’t be tolerated and we’ll take action when necessary to ensure everyone is treated fairly.
R-E-S-P-E-C-T
It’s up to everyone to demand a respectful work environment at all times. We won’t tolerate sexual harassment or any other form of harassment or discrimination.
Sexual harassment includes things like unwelcome sexual advances, requests for sexual favors, gross, sexually-charged or obscene remarks or gestures, and any unwelcome touching or other physical contact. But harassment or discrimination can take many forms, and may include bullying, racial epithets, slurs and derogatory remarks, stereotypes and inappropriate jokes, posters, cartoons, texts, e-mail messages, or websites based on the protected categories.
It’s completely unacceptable for anyone to behave in a way that creates an abusive, disrespectful, intimidating, hostile, degrading, humiliating, or offensive environment. You deserve better than that. If someone you work with does behave this way, it could violate this policy even if it falls short of unlawful harassment under local law. We won’t tolerate behavior like this and we’ll take action as soon as and however we can, in accordance with local laws.
When you’re the boss
We expect even more from you if you’re a manager. Show your team what a respectful and safe work environment looks like. Beyond modeling great behavior, you must also take steps to make sure any inappropriate behaviors inconsistent with this policy are addressed immediately. Here’s a quick way to remember what your responsibilities are:
● Recognize - Recognize behaviors inconsistent with this policy EARLY, before they become big concerns.
● Report - Inform your Talent partner what you experienced or witnessed.
● Respond - Once aware of the issue, we will respond quickly and will take any necessary steps to remedy the concerns. You may be asked to help in this process.
If something happens
Tell us. We can’t fix what we don’t know. If you feel harassed or discriminated against (or if you see it happen to someone else), you should report it right away. You can call, talk, email, text or reach out however you feel comfortable. You can contact your manager or Talent partner. We’ve even set up a confidential reporting hotline, EthicsPoint, at www.netflix.ethicspoint.com if that works better for you.
We will respond to every concern raised involving behaviors inconsistent with these expectations. If we need more information, we will fairly and promptly look into the concerns in order to reach a conclusion. We’ll keep the investigation as confidential as possible--information about the complaint and the outcome will be shared on a limited, need-to-know basis. If we find improper conduct, we’ll take action.
You deserve a fair and safe environment--and it’s up to everyone to help make it happen. Don’t allow an inappropriate situation to continue by not reporting it, no matter who is creating the situation. Nobody is exempt from this policy, no matter how important they may seem.
Finally, we won’t retaliate against anyone for bringing a good faith concern to our attention, or for cooperating truthfully in an investigation. We’ll also take action against anyone who retaliates against you if you’re involved in a complaint or investigation. We want to hear from you if something happens.
Questions?
We’re here for you. Reach out to your Talent partner, Employee Services or an employee representative if you have any questions about this policy or want to talk more about it.
rv. 12-2024
In order to take an active role in the prevention of insider trading violations by executive officers, directors, employees and other related individuals of Netflix, Inc. (the “Company”) and its subsidiaries, the Company has adopted this Insider Trading Policy (the “Policy”).
Statement of Intent
The Company opposes the misuse of material nonpublic information in the trading of securities and it is the intent of this Policy to implement procedures designed to prevent trading based on material nonpublic information regarding the Company, including any of its subsidiaries. The Company also wishes to discourage certain trading in its securities by its executive officers, directors, employees and other related individuals that may be contrary to the interests of our shareholders. The term "executive officer" herein shall have the same meaning as the term “officer” as defined under Rule 16a-1(f) of the Securities Exchange Act of 1934, as amended (the “Exchange Act”).
It is also Company policy to comply with applicable securities laws concerning trading in Company securities on the Company’s behalf.
Definition of Material Nonpublic Information
It is not possible to define all categories of material information. However, information should be regarded as material if there is a substantial likelihood that it would be considered important to a reasonable investor in making an investment decision regarding transactions of the Company’s securities. Put another way, there must be a substantial likelihood that the information would be viewed by the reasonable investor as having significantly altered the total mix of information available in the market concerning the Company. Either positive or negative information may be material.
Questions concerning whether nonpublic information is material can be directed to the Compliance Officer.
Covered Parties
The Policy covers executive officers, directors and all employees of, or consultants or contractors to, the Company or its subsidiaries, as well as their immediate family members who reside with them, anyone else who lives in their household, and any other individuals who do not live in their household but whose transactions in Company securities are directed by them or are subject to their influence or control (such as parents or children who consult with them before trading in Company securities) (“Insiders”). This Policy applies to trades of Company securities in which an Insider has any “beneficial” or other interest, or over which they exercise investment control.
Covered Transactions
This Policy applies to all transactions in the Company’s securities, including common stock, options for common stock and any other securities the Company may issue from time to time, such as preferred stock, warrants and convertible debentures, as well as to derivative securities relating to the Company’s securities, whether or not issued by the Company, such as publicly-traded options. Transactions subject to this Policy include purchases, sales and bona fide gifts of the Company’s securities (which may include gifts to trusts for estate planning purposes, as well as donations to a charitable organization).
Prohibited Transactions
No Insider shall engage in any transaction involving the Company’s securities, including any offer to purchase or offer to sell, during any period commencing with the date that the Insider possesses material nonpublic information concerning the Company or its subsidiaries, and ending at the beginning of the trading day following the date of public disclosure of that information, or at such time as such nonpublic information is no longer material.
No Insider shall disclose (“tip”) material nonpublic information about the Company or its subsidiaries to any other person where such information may be used by such person to their profit by trading in the securities of companies to which such information relates, nor shall such Insider or related person make recommendations or express opinions on the basis of material nonpublic information as to trading in the Company’s securities.
No Insider shall engage in any transaction involving another company’s securities while in possession of material nonpublic information about such company when that information is obtained in the course of employment with, or the performance of services on behalf of, the Company and the other company is a business partner of the Company such as one with which the Company is discussing a proposed transaction, collaborator, customer, distributor, vendor or supplier.
Except for participation in the Company’s stock option program, no executive officer or director shall, at any time, engage in any transactions involving any hedging or derivatives of Company securities, including trading in futures and derivative securities and engaging in hedging activities relating to our securities, including exchange traded options, puts, calls, collars, forward sale contracts, equity swaps, exchange funds or other arrangements or instruments designed to hedge or offset decreases in the market value of our securities, provided that it shall not be a violation of this Policy for an executive officer or director to engage in any such transaction initiated prior to March 4, 2020.
Except as may otherwise be authorized under this Policy, executive officers and directors shall not initiate any transactions subsequent to March 4, 2020 that involve pledging any Company securities as collateral for a loan or holding them as security in a margin account.
Problematic Transactions
While employees (other than executive officers, except as otherwise provided) are not prohibited by this Policy from using Company securities as collateral for loans or in margin accounts with respect to the Company’s securities or engaging in transactions involving hedging or derivatives of Company securities, including by means of exchange traded options, puts, calls, collars, forward sale contracts, equity swaps, exchange funds or other arrangements or instruments designed to hedge or offset decreases in the market value of our securities, the Company discourages employees from such activity because, among other problems, these types of transactions may result in transactions in Company securities occurring outside the Open Window (defined below). Limit orders with brokers should not extend beyond any Open Window and be cancellable upon an imposition of a black-out period. Employees interested in trading outside of the Open Window should look into adopting a 10b5-1 trading plan, as described below. Exercising stock options issued pursuant to the Company’s stock option plan, as otherwise permitted under this Policy, is not considered problematic.
The Company’s Trading Window
The Company has determined that all executive officers, directors, and those other persons identified on Attachment 1 (as may be amended from time to time by the Compliance Officer), shall be prohibited from buying, selling or otherwise effecting transactions in any stock or other securities of the Company or derivative securities thereof EXCEPT during the following trading window:
Beginning at the open of market on the trading day following the date of public disclosure of the Company’s financial results for a preceding calendar quarter or year and ending at the close of market on the 10th day of the second calendar month of the current calendar quarter (the “Open Window”).
In addition, the Company, through the Compliance Officer, may authorize longer or additional trading windows in which buying, selling, gifting or otherwise effecting transactions in the Company’s securities would be permitted pursuant to this Policy as if it were the “Open Window.” Similarly, the Company, through the Compliance Officer, may impose special black-out periods during which certain persons will be prohibited from buying, selling or otherwise effecting transactions in the Company’s securities, even though the trading window would otherwise be open. If a special black-out period is imposed, the Company will notify affected individuals, who should thereafter not engage in any transaction involving the Company’s securities and should not disclose to others the fact of such suspension of trading.
It should be noted that even during the Open Window, any person possessing material nonpublic information should not engage in any transactions in the Company’s securities until the beginning of the trading day following the date of public disclosure of such information, whether or not the Company has recommended a suspension of trading to that person.
Pre-Clearance of Trades and Other Transactions
All executive officers and directors of the Company and other persons designated by the Compliance Officer as being subject to pre-clearance requirements must refrain from trading in or gifting the Company’s securities, even during the Open Window, without first contacting the Company’s Compliance Officer and obtaining pre-clearance to commence trading in the Company’s securities.
In addition, all executive officers and directors are required to comply with Section 16 of the Exchange Act and related rules and regulations, which set forth reporting obligations as well as limitations on “short swing” transactions. The Company is available to assist in filing Section 16 reporting; however, the obligation to comply with Section 16 is personal. Please direct any inquiries concerning compliance to the Compliance Officer. Executive officers and directors who wish to pledge the Company's stock as collateral after March 4, 2020 must first contact the Company's Compliance Officer to request an exemption and pre-clearance to enter into the transaction.
Adoption and Effect of 10b5-1 Trading Plans
The Company permits all directors, executive officers and employees to adopt trading plans in accordance with Rule 10b5-1(c) under the Exchange Act (“10b5-1 trading plans”). A 10b5-1 trading plan must comply with the requirements of Rule 10b5-1 and may only be adopted or amended in an Open Window and when the person adopting the plan is not otherwise in possession of material nonpublic information about the Company, its subsidiaries or its securities. All 10b5-1 trading plans must be pre-approved by the Compliance Officer or his delegate. The restrictions on trading set forth in this Policy shall not apply to trades made pursuant to a 10b5-1 trading plan. More information concerning trading plans is available from the Compliance Officer.
Exemptions from this Policy
The exercise of stock options under the Company’s stock option plan with a cash payment of the exercise price is exempt from this Policy, since the other party to these transactions is the Company itself and the price does not vary with the market, but is fixed by the terms of the option agreement, or the Company withholding a portion of the shares underlying the options to satisfy exercise price or tax withholding requirements. This exemption does not apply to the sale of any shares issued upon such exercise and it does not apply to a cashless exercise of options, which is accomplished by a sale of a portion of the shares issued upon exercise of an option.
Post-Termination Transactions
If a person is in possession of material nonpublic information when their service terminates, that individual should not trade in Company securities until that information has become public or is no longer material.
Consequences for Violation
Directors and employees who violate this Policy shall also be subject to disciplinary action by the Company, which may include ineligibility for future participation in the Company’s equity stock option and other incentive plans or termination of employment or service.
Pursuant to U.S. federal and state securities laws, Insiders may be subject to criminal and civil fines and penalties as well as imprisonment for engaging in transactions in the Company’s securities at a time when they are in possession of material nonpublic information regarding the Company or its subsidiaries. In addition, Insiders may be liable for improper transactions by any person (commonly referred to as a “tippee”) to whom they have disclosed material nonpublic information regarding the Company or its subsidiaries or to whom they have made recommendations or expressed opinions on the basis of such information as to trading in the Company’s securities.
Individual Responsibility
Every executive officer, director and employee, consultant and contractor has the individual responsibility to comply with this Policy, and the applicable laws of their jurisdiction. An Insider may, from time to time, have to forego a proposed transaction in the Company’s securities even if he or she planned to make the transaction before learning of the material nonpublic information and even though the Insider believes he or she may suffer an economic loss or forego anticipated profit by waiting. Trading in the Company’s securities during the trading window (including with pre-clearance) should not be considered a “safe harbor,” and all directors, executive officers and other persons should use good judgment at all times.
Compliance Officer
● The Company’s Chief Legal Officer shall serve as the Insider Trading Compliance Officer (the “Compliance Officer”). The duties of the Compliance Officer shall include, but not be limited to, the following:
● Pre-clearing transactions as required under this Policy.
● Assisting, as requested, in the preparation and filing of Section 16 reports (Forms 3, 4 and 5) for Section 16 reporting persons.
● Serving as the designated recipient at the Company of copies of reports filed with the Securities and Exchange Commission by Section 16 reporting persons under Section 16 of the Exchange Act.
● Circulating the Policy (and/or a summary thereof) to all employees, including Section 16 reporting persons, on an annual basis.
● Assisting the Company in implementation of the Policy.
● Coordinating with Company counsel regarding compliance activities with respect to Rule 144 requirements and regarding changing requirements and recommendations for compliance with Section 16 of the Exchange Act and insider trading laws to ensure that the Policy is amended as necessary to comply with such requirements.
The duties may be delegated by the Compliance Officer to such other individuals as the Compliance Officer deems appropriate.
* * * * *
Attachment 1
Persons subject to trading window restrictions
Insiders, as defined in the Company’s Insider Trading Policy, except for the following:
● Employees, contractors and consultants who are employed or retained through a direct or indirect subsidiary of the Company that is specifically and solely engaged in the production of original content and not otherwise included as a matter of business practice in the distribution of corporate information about the Company and its financial performance, unless such person has been notified in writing by the Compliance Officer that the trading window applies to them.
● Employees of subsidiaries that are not integrated into the Company's email systems and/or who do not have access to consolidated financial data.
rv. 10-2023
This Netflix Contingent Worker Privacy Notice (“Privacy Notice”) explains how we and the Netflix group of companies collect and use information, including your personal information. This Privacy Notice is for contingent workers, whether engaged directly by Netflix or through an agency or vendor. It applies during and after your relationship with us. For clarity, residents of the European Economic Area (“EEA”) are deemed to have acknowledged (rather than agreed to) the Privacy Notice.
See our Contingent Workers California Consumer Privacy Act (CCPA) Privacy Notice by clicking on the link California Consumer Privacy Act (CCPA) Privacy Notice - Contingent Workers, or simply scrolling down.
Contacting Us
For questions about this Privacy Notice, or our use of your personal information, cookies or similar technologies, please contact our Data Protection Officer/Privacy Office by email at corporateprivacy@netflix.com.
The Netflix data controller of your personal information is the Netflix company you are providing services for.
Collection of Information
We receive and store personal information about you such as:
Information you or your employer/agency provides to us: Depending on your role and circumstances this may include your personal details, such as your name, contact details and national ID number; professional/work employment and skills related information; the communications you have with us/your employer or that you send on our/your employer’s behalf; your schedule and availability; contract details; financial information (such as bank account numbers); log-in credentials; information about your work permit or visa status; background check or references; and sensitive personal information (see the “Sensitive Personal Information” section below).
Information from other sources: Depending on your role and circumstances, we may also obtain personal information from other sources where relevant, including your travel arrangements from travel agents/agencies; background check or identity check data obtained from screening agencies (as permitted by applicable law), immigration/work permit status from immigration advisors; data providers, from which we obtain grouped demographic data; and information you make available publicly, such as through LinkedIn.
Information we collect automatically: Depending on how you access our tools, services and facilities, we may collect information about you and your access of those tools, services and facilities. We monitor our devices, systems and facilities with security and configuration tools that we build internally (such as Stethoscope) or purchase from third parties (such as Jamf and Microsoft Intune). The tools we use vary by devices and operating systems. For instance, we use different endpoint management tools for Windows, Mac, iOS, Android and Chromium (e.g., Chromebook) devices. These tools may collect data about our employees and the devices that they use for work, such as IP addresses, mac addresses, web-sites visited, and other data that helps us protect against malware and other cybersecurity risks. We also use these tools to configure devices remotely to ensure that they are secure, encrypted, and running approved and up to date software.
For more details on these tools and how they function, see the Endpoint Management and Security Tools Description.
We also collect information about you such as: badge/fob, or other device used to access our facilities, services and tools, how you use or interact with our services and tools, including emails and texts; device IDs or other unique identifiers, such as a contingent worker ID; if you visit a Netflix office your entry and exit from lobbies and other areas of our facilities may be logged by electronic passes or monitored by closed circuit TV cameras (CCTV); and information may be collected via the use of cookies, web beacons and other technologies. (See our “Cookies” section for more details.)
Sensitive Personal Information: We may also collect and use “special” or “sensitive” personal information, which may include personal information relating to your sexual orientation, religion or belief, political persuasion, marital status, race, ethnicity, health status, or whether you are a veteran, have a disability, are a trade union members, or have criminal convictions and history.
Use of Personal Information
Depending on your role and circumstances we may use your personal information for:
Management and administration of projects and workers: including coordination with your employer, managing work activities, projects and workers generally, carrying out recruitment and casting; conducting evaluations and payment administration, managing business travel arrangements, immigration and visas; budgeting, financial management and reporting; allocating resources and workers; fulfilling contractual obligations; managing individual and workplace health and safety; managing disciplinary matters (including internal investigations) and managing assignment terminations;
Protecting the physical security of individuals and our facilities: including logs of when you enter or leave Netflix facilities, recording and monitoring CCTV, security personnel assignment, safeguarding property and conducting security investigations;
Operating and ensuring the safety of our systems: including operating and managing our IT and communications systems; assigning and managing access rights; malware scanning files and emails, monitoring telephone, email, Internet and other Netflix resources; and protecting IT infrastructure and office equipment;
Communications: including communicating with your employer or agent (if applicable), contract negotiations; general business communications; ensuring business continuity; protecting the health and safety of Netflix personnel and others; operating our ethics hotline; and communications in an emergency;
Analyzing data and reporting on it: including to monitor, test, and manage our business, vendors, security (including physical, IT and communications), and the processes and tools used to support these; and to identify trends and market conditions in areas such as compensation, hiring, and benefits practices, and representation of underrepresented populations;
Development, improvement and use of IT, software, tools and processes: including those used to recruit, manage and pay workers; and support HR, finance, and personnel teams;
Compliance and protecting our business interests: including complying with applicable legal and other requirements, such as income tax and national insurance deductions; recordkeeping and reporting obligations; conducting audits; compliance with law enforcement and similar requests in accordance with applicable law; using our legal rights and remedies; defending litigation and managing any internal complaints or claims; government relations; complying with internal policies and procedures; and managing mergers, acquisitions and reorganizations or disposals.
Sensitive Personal Information: Where such personal data is required we will only use this as follows:
where we have your explicit consent;
where it is necessary for carrying out our obligations and exercising our rights in the field of employment, social security or social protection law or collective agreement;
where it is necessary to assess your capacity to work;
where it is necessary for reasons of substantial public interest;
where it is required under a specific legal obligation;
where you have clearly made the information public;
where you have clearly made this information available to us; or
where it is necessary for us to establish, make or defend legal claims.
For residents of the EEA, our legal basis for collecting and using the personal information described in this Privacy Notice will depend on the personal information concerned and the specific context in which we collect and use it. We will normally collect personal information from you where we need the personal information:
to prepare for or perform a contract with you (for example, when you sign a contract to provide Netflix services);
where the use of the personal information is in our (or a third party’s) legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms (for example, to analyze certain information so that we can improve our processes and tools);
where use of your personal information is necessary for carrying out our obligations and exercising our rights in the field of employment, social security or social protection law or collective agreement; or
where we have your consent to do so.
In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect a substantial public interest or your vital interests or those of another person (for example, to protect your security and health and those of others). For questions about our use of your personal information (including the legal bases and transfer mechanisms we rely on) and our use of cookies or similar technologies, please contact our Data Protection Officer/Privacy Office by email at corporateprivacy@netflix.com.
Disclosure of Information
We share your personal information to third parties for certain purposes, as described below:
Your employer/agency: We may share personal information with your employer/agency, for example when we communicate with them about your availability.
Service Providers: We use other companies, agents or contractors (“Service Providers”) to help us with our activities described in the “Use of Personal Information” section above. For example, we appoint Service Providers to: provide security, safety and management support; and provide communications, infrastructure and IT services.
We do not authorize Service Providers to use or share your personal data except in connection with providing their services (which includes maintaining and improving their services);
The Netflix group of companies: We share your personal information among the Netflix group of companies as needed for storage; providing you with access to our tools; making decisions about improving our processes; and for other purposes described in the Use of Personal Information section of this Privacy Notice.
Protecting you, Netflix and others: Netflix and its Service Providers may share and use your personal and other information where we or they reasonably believe we need to do so to: comply with any applicable law, regulation, legal process, or governmental request; put into effect any contract or policies we have in place with you; investigate and defend ourselves or others against any third-party claims or allegations; enforce applicable terms of use, including investigation of potential violations of such terms; detect, prevent, or otherwise address illegal or suspected illegal activities, security or technical issues; or protect against harm to the rights, property or safety of Netflix, its workers or the public, as required or permitted by law.
Business transfers: In connection with any reorganization, restructuring, merger or sale, or other transfer of assets, we may transfer information, including personal information, provided that the receiving party agrees to respect your personal information in a manner that is consistent with our Privacy Notice.
International data transfers
Whenever in the course of sharing information, we transfer personal information to countries outside of the EEA and other regions with comprehensive data protection laws, we will ensure that the personal information is transferred in accordance with this Privacy Notice and as permitted by the applicable laws on data protection.
We ensure that appropriate contractual, technical, and organizational measures are in place.
For contingent workers based in Korea, personal information transferred (such as name and contact information) may be saved electronically on servers located (for example) in the United States, Singapore and/or Ireland operated by our Service Providers for record keeping purposes and other purposes as set out in this Privacy Statement.
Your Information and Rights
You can make the following requests:
You can request access to the personal information we hold about you, or to correct, update or delete it.
You can ask us to stop using your personal information in certain ways, ask us to limit use of your personal information or in some circumstances request to move your personal information.
If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any use of your personal information that we carried out prior to your withdrawal, nor will it affect the use of your personal information carried out in reliance on lawful grounds other than consent.
You have the right to complain to a data protection authority about our collection and use of your personal information.
To make requests, please contact our Data Protection Officer/Privacy Office at corporateprivacy@netflix.com. We respond to all requests in accordance with applicable data protection laws.
If you are a California consumer, please see our Contingent Worker (CCPA) Privacy Notice by simply scrolling down.
Retention
Netflix will only keep your personal data for as long as necessary for the purposes we collected it for, including to comply with any legal, accounting, or reporting requirements. To decide the appropriate length of time to keep your personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or sharing of your personal data, the purposes for which we use your personal data and whether we can achieve those purposes in other ways, and the applicable legal requirements.
Security
We use appropriate physical, technical and organizational measures to safeguard your personal information against loss, theft and unauthorized access, use and modification. Please note that even reasonable security measures may not prevent all incidents.
Other Websites, Platforms and Applications
Our sites and online platforms may be provided through and/or include features operated by third party platforms, or contain links to sites operated by third parties whose policies regarding the handling of information may differ from ours. For example, you may be able to share a link to a recruiting post on social media. These websites and platforms have separate and independent privacy or data policies, privacy statements, notices and terms of use, which we recommend you read carefully.
Changes to This Privacy Notice
We will update this Privacy Notice from time to time in response to changing legal, regulatory or operational requirements. We will provide notice of any such changes (including when they will take effect) in accordance with law. Your continued use of the services after any such updates take effect will constitute acknowledgement and (as applicable) acceptance of those changes. To see when this Privacy Notice was last updated, please see the "Last Updated" section below.
Cookies
We and our Service Providers use cookies and other technologies (such as web beacons). Cookies are small data files that are commonly stored on your device when you browse and use websites and online services. We may use other technologies such as browser storage and plugins (e.g. HTML5, IndexedDB and WebSQL), which may also store small amounts of data on your device. In many cases, declining cookies will make the web beacons (also known as clear gifs or pixel tags) associated with such cookies, less effective. We use these types of technologies for various reasons, like making it easier for you to access the tools and services you have may have access to while working at Netflix; understand their performance and how they are used; and to deliver and tailor our messages, and understand interactions with our messages (including emails, and recruiting posts on third party sites).
California Consumer Privacy Act (CCPA) Privacy Notice - Contingent Workers
This Privacy Notice applies to contingent workers (current and former) of Netflix whether retained directly or through a vendor or agency who are California residents (or in the case of former contingent workers, were at the time of their engagement with Netflix). Netflix provides you with this Privacy Notice to inform you of our personal information practices and does not create an employment relationship between us.
Personal Information We Collect
We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“CCPA personal information”). We have collected the following categories of CCPA personal information from consumers within the last twelve (12) months:
Identifiers: “Identifiers” covers a broad range of information, including things like name, email address, postal address, telephone number, and IP address. We collect CCPA personal information that falls into this category. For example, we may collect name, email address, phone number and your postal address in the course of your engagement. We may collect personal information including your social security number, tax identification number, or similar tax IDs and may collect other forms of government issued IDs, such as your driver’s license or passport number. We may assign you a contingent worker ID and issue you a company email address, badge/fob, phone and/or devices, which may all have identifiers associated with them. We collect IP addresses or may set cookies when you connect to our systems. These sorts of identifiers may be associated with your contingent worker ID.
Characteristics of protected classifications under California or federal law: This covers a broad range of information like race, citizenship status, sex, gender identity, marital status, sexual orientation, military status or whether you are a veteran, religion, political affiliation, and whether you are a person with a disability, among other protected classes. When you may have applied as a contingent worker, when you onboarded, or during your engagement, you may provide or have provided information about such characteristics.
Internet or other electronic network activity information: When you are engaged at Netflix, many of our systems are online, so we collect CCPA personal information in this category, like when you access our tools or systems.
Geolocation data: When you enter and exit Netflix facilities using your badge/fob or log into our systems we can determine your general location. As noted above, we do collect IP addresses from which we can determine your general location. We may give you the option to allow us to collect precise geolocation data from GPS sensors (directly or through a service provider), in order to understand your location for safety and security purposes, including for alerts.
Audio, electronic, visual, thermal, olfactory or similar information: You may provide or we may capture photos, audio and/or video of you, for example for your badge or when you attend conference calls. When you are on Netflix facilities, your entry and exit from lobbies and other areas of our facilities may be monitored by CCTV.
Professional information: As part of your engagement, we collect CCPA personal information in this category, like information on your resume, job title, contact information, skills and expertise (e.g. languages spoken), your start and end date, the projects you work on, your pay rate or supplier/agency bill rate, bank account information, emergency contact information, information required for the processing of background checks (where applicable), information needed to support travel (including but not limited to booking flights and hotels), information about your work permit or visa status, and information collected through the Netflix ethics hotline (for jurisdictions where the hotline is launched).
Uses of CCPA personal information
We use categories of personal information listed above for the purposes noted in the Use of Information section of our Contingent Worker Privacy Statement. For ease of reference, we repeat that section below:
Depending on your role and circumstances we may use your personal information for:
Management and administration of projects and workers: including coordination with your employer, managing work activities, projects and workers generally, carrying out recruitment and casting; conducting evaluations and payment administration, managing business travel arrangements, immigration and visas; budgeting, financial management and reporting; allocating resources and workers; fulfilling contractual obligations; managing individual and workplace health and safety; managing disciplinary matters (including internal investigations) and managing assignment terminations;
Protecting the physical security of individuals and our facilities: including logs of when you enter or leave Netflix facilities, recording and monitoring CCTV, security personnel assignment, safeguarding property and conducting security investigations;
Operating and ensuring the safety of our systems: including operating and managing our IT and communications systems; assigning and managing access rights; malware scanning files and emails, monitoring telephone, email, Internet and other Netflix resources; and protecting IT infrastructure and office equipment;
Communications: including communicating with your employer or agent (if applicable), contract negotiations; general business communications; ensuring business continuity; protecting the health and safety of Netflix personnel and others; operating our ethics hotline; and communications in an emergency;
Analyzing data and reporting on it: including to monitor, test, and manage our business, vendors, security (including physical, IT and communications), and the processes and tools used to support these; and to identify trends and market conditions in areas such as compensation, hiring, and benefits practices, and representation of underrepresented populations;
Development, improvement and use of IT, software, tools and processes: including those used to recruit, manage and pay workers; and support HR, finance, and personnel teams;
Compliance and protecting our business interests: including complying with applicable legal and other requirements, such as income tax and national insurance deductions; recordkeeping and reporting obligations; conducting audits; compliance with law enforcement and similar requests in accordance with applicable law; using our legal rights and remedies; defending litigation and managing any internal complaints or claims; government relations; complying with internal policies and procedures; and managing mergers, acquisitions and reorganizations or disposals.
Categories of CCPA personal information disclosed for a business purpose
We disclose categories of personal information for business purposes. (Please see the Disclosure of Information section of our Contingent Worker Privacy Statement for additional details that may be of interest to you.)
Sensitive Personal Information
CCPA personal information may include information that may be considered Sensitive Personal Information as defined by the CCPA. We do not use or disclose Sensitive Personal Information for any purpose inconsistent with section 7027 (l) of the CCPA Regulations.
Sources of CCPA personal information
We explain our sources of information in the Collection of Information section of our Privacy Statement. (Please see that section for more information that may be of interest to you.) For ease of reference, in regard to CCPA personal information these are:
You, when you provide us CCPA personal information directly, and when we collect it automatically based on your interactions with us (for example when you enter or exit our facilities or access our systems).
Your employer/agency who may provide us CCPA personal information when you are considered or performing work for us.
Other sources such as service providers who support our business including security, travel, background check/screening, immigration, through sources in which you make information publicly available, such as through LinkedIn, and information about Internet Service Providers (ISPs) used by you to access our systems through public databases associating IP addresses with ISPs.
Your Rights under the California Consumer Privacy Act
You have the right to know what categories and specific pieces of CCPA personal information have been collected about you; the categories of sources from which CCPA personal information are collected; our business or commercial purpose for collecting, using, or disclosing CCPA personal information; the categories of third parties with whom we share CCPA personal information; the categories of CCPA personal information we have disclosed about you for a business purpose. You have a right to confirm whether or not we process your CCPA personal information as well as to access and receive a copy of the specific CCPA personal information we have collected about you.
You have a right to request the deletion of your CCPA personal information, subject to exceptions under the CCPA.
You have a right to request correction of any inaccurate CCPA personal information we hold about you.
You have the right to receive notice of our practices at or before collection of CCPA personal information (for example, this notice) and not receive discriminatory treatment or be retaliated against if you choose to exercise any of your rights.
We do not sell or share CCPA personal information. We do not knowingly sell, share or use the personal information of minors under 16 years of age.
You can assert these rights only where we receive a verified request from you. To make requests, or if you have a question regarding our privacy practices, please contact our Data Protection Officer at corporateprivacy@netflix.com. If you wish to contact us through an authorized agent, the authorized agent can submit a request on your behalf to corporateprivacy@netflix.com along with a statement, certified as may be required, that the agent is authorized to act on your behalf. In order to verify the request, we may ask you to verify your identity.
Retention
We retain categories of CCPA personal information in accordance with this Privacy Statement. For ease of reference, we repeat that section below:
Netflix will only keep your personal data for as long as necessary for the purposes we collected it for, including to comply with any legal, accounting, or reporting requirements. To decide the appropriate length of time to keep your CCPA personal information, we consider the amount, nature, and sensitivity of the CCPA personal information, the potential risk of harm from unauthorized use or sharing of your CCPA personal information, the purposes for which we use your CCPA personal information and whether we can achieve those purposes in other ways, and the applicable legal requirements.
If you would like to exercise your rights for personal information we retain, please contact as described in the “Your Rights under the California Consumer Privacy Act” section above. We take reasonable measures to destroy or de-identify the CCPA personal information in a secure manner when it is no longer required.