Privacy Notice for Job Applicants

Last updated: October 2025

1. Introduction

This Privacy Notice for job applicants (’Privacy Notice’) describes how ASML Holding N.V. – based at De Run 6501, 5504 DR, Veldhoven, the Netherlands – and its group companies (‘ASML’, ‘us’, ‘our’ or ‘we’) process the personal data of candidates we contact and applicants that apply to a position (‘you’) in connection with ASML’s recruitment process.

 

We have carefully drafted this Privacy Notice to inform you in plain language about our privacy practices. The Privacy Notice tells you what personal data we process about you, why we process it and how we use it during our recruitment process. We encourage you to read the Privacy Notice in full. 

 

Translated versions of this Privacy Notice are available. The translated versions are provided for convenience only. In the event of any difference in meaning between the English language version and any translated version, the English language version will prevail. 

 

Assistance For The Disabled

 

Alternative formats of this Privacy Policy are available to individuals with a disability. Please contact privacyoffice@asml.com for assistance.

2. When does this privacy notice apply?

This Privacy Notice applies to the processing of personal data of job applicants or job prospects by ASML. Processing personal data is a broad term and includes (amongst other things) collecting, recording, storing, amending, reviewing, using and deleting personal data.

 

Some countries may have stricter or deviating local legal requirements. For example, local law may impose different requirements on how long we have to keep your data (data retention). In case of a conflict between this Privacy Notice and such requirements, the latter will prevail.  

3. What is ASML?

ASML is a supplier of semiconductor manufacturing equipment and the innovator behind lithography systems. We provide chipmakers with everything they need – hardware, software and services – to mass produce patterns on silicon through lithography.

4. What is personal data?

It is important for you to know that ‘personal data’ (or: ‘data’, ‘personal information’, or ‘your data’), means: any information relating to an identified or identifiable natural person (‘data subject’).

 

An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier – or by reference to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. 

5. What personal data do we process about you?

During the recruitment process, we ask you to provide us with information that enables us to assess your suitability for certain positions.  

 

We may process personal data about you, such as:

 

  1. Government-issued data and documentation required under immigration laws, such as passport number and expiry date, nationality, social security/national insurance/equivalent identification number and work permit;
     
  2. Internal data, such as employee/user ID, title, department, working hours, travel and expense claims, (corporate) credit or debit card numbers and relocation data;
     
  3. Recruitment data, such as curriculum vitae, application form, educational qualifications, professional qualifications, background and educational checks, and statements of conduct;
     
  4. Personal identifiers, such as contact details (i.e., name, alias, telephone number, postal address, e-mail address) and gender;
     
  5. Interview and communication data, such as information given by you during face-to-face and video interviews, via emails, phone calls and other means of communication;
     
  6. Job applicant experience feedback, such as feedback you provide in surveys around the recruitment process;
     
  7. Assessment and test results, such as results of tests and analyses that you have performed at our request;
     
  8. Contact details of your references whose consent you must have obtained;  
     
  9. Sensory or surveillance data, such as on premise information collected through access control and CCTV recordings;
     
  10. Account login information used to access company systems and applications, such as the recruitment portal;
     

Internet or other electronic network activity information, such as IP address and information obtained from cookies and similar tracking technology used on our websites and job application forms, from your use of our websites and job application forms. For more information, please read our Cookie Notice.

 

Special categories of personal data and sensitive personal data 
We may also process personal data that is considered as special categories of personal data or sensitive personal data. Such data may include data relating to racial or ethnic origin, genetic or biometric data, as well as data concerning your health. Furthermore, we may process personal data that is considered sensitive, such as veteran status or information relating to criminal convictions or offences. 

 

Please note that personal data required for our recruitment process may vary, depending on the position you apply for, the location (country) of this position and applicable local rules and regulations. We may process special category or sensitive personal data taking into account local legal requirements.  
 

We do not collect or process sensitive personal data or characteristics of protected classifications for the purpose of inferring characteristics about you.

 

How do we obtain your personal data? 
We collect personal data directly from you when you apply for a position with us, show interest in us, or when we contact you with a possible job offer. In addition, we may collect your personal data independently through different career orienting platforms and websites. We also collect your personal data from third parties, such as professional recruitment agencies, your references, prior employers, and pre-employment and background check providers, to the extent permitted by applicable law.

6. What are the purposes and legal bases for processing your personal data?

We may process your personal data for one or more of the purposes in the table below.  

The legal bases (or justified reasons) for processing your personal data are:

 

  • The legitimate interests of ASML for recruitment purposes, and in some cases the protection of our assets and business, as further detailed in the table below (‘legitimate interests’);
  • For entering into and managing a contract or employment relationship (‘performance of a contract’);
  • Compliance with our legal obligations (‘legal obligation’);
  • Protecting your vital interest or that of another natural person (‘vital interests’); and  
  • Your specific and informed consent (‘consent’).


In the event that the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. We would like to draw your attention to the fact that the withdrawal of your consent does not affect the lawfulness of the processing of your personal data prior to the withdrawal of your consent. 


a. To identify and evaluate your qualifications for available positions,
including your eligibility for future positions at ASML; 

Government-issued data 

Internal data 

Recruitment data 

Personal identifiers 

Interview and communication data 

Assessment and test results 

Legitimate interests 
b. To verify the data you submitted and carrying out reference checks,
pre-employment screening and background checks (where applicable); 

Government-issued data 

Internal data 

Recruitment data 

Personal identifiers 

Interview and communication data 

Contact details of references 

Sensitive data 

Legitimate interests 

Legal obligation 

Consent 
c. To inform you about the progress of your application or other
vacancies at ASML that we consider suitable for you; 

Personal identifiers 

Interview and communication data 

Legitimate interests 
d. For recruitment marketing, such as custom audience, talent pool
creation for future job openings and email communication concerning
job openings; 

Personal identifiers 

Internal data 

Interview and communication data 

Internet or electronic network activity information
 
Legitimate interests 

Consent 
e. To conduct surveys on the improvement of our recruitment processes; 

Job applicant experience feedback 

Personal identifiers 

Legitimate interests 
f. To prepare a job offer and employment contract, where applicable,
and to fulfill onboarding activities in case of a successful application; 

Government-issued data 

Internal data 

Recruitment data 

Personal identifiers 

Interview and communication data 

Assessment and test results 

Account login 

Legitimate interests 

Legal obligation 
g. To assess your fitness to work and for the provision of facilities in
the workplace or application process for any accommodation; 

Government-issued data 

Internal data 

Recruitment data 

Assessment and test results 

Health data 

Legitimate interests 

Consent 

Legal obligation 
h. To manage your job application account in order for you to be able
to track your application progress; 

Internal data  

Account login information 

Legitimate interests 
i. To efficiently manage and operate administrative, information
technology, and communications systems, risk management and
insurance functions, budgeting, financial management, and strategic planning; 

Internal data 

Account login information 

Internet or electronic network activity information 

Legitimate interests 
j. To test, develop and use Artificial Intelligence systems or other
similar technologies; 

Recruitment data 

Interview and communication data 

Internet or electronic network activity information
 
Legitimate interests 
k. To enhance user experience such as analyzing data to optimize
platforms functionality, improve workflow efficiency; 
Internet or electronic network activity information 

Legitimate interests 

Consent 

l. To protect the health, safety, security and integrity of ASML and its
workers, business partners and visitors, (IT) facilities and assets,
including occupational safety and health; and 

Internal data 

Personal identifiers 

Sensory or surveillance data 

Account login information 

Government-issued data 

Legitimate interests 

Legal obligation 
m. To comply with the law, including the investigation of any possible
cases of non-compliance with statutory or contractual obligations or the
disclosure of personal data to government institutions or supervisory
authorities, as well as to exercise or defend legal claims. 

Internal data 

Recruitment data 

Personal identifiers 

Sensory or surveillance data 

Sensitive data 

Legal obligation 

Secondary use of personal data 
When we have collected personal data, this data may be used for a secondary purpose, but only if the secondary purpose is compatible with the original purpose. For example, statistical analysis may constitute as a compatible secondary purpose.   

7. Who has access to your personal data?

Access to your personal data within ASML 
Our workers are authorized to access personal data only to the extent necessary to serve one or more of the purposes set forth in Section 6 above and in so far as necessary within the scope of their roles and responsibilities as ASML workers.

 

Access to your personal data by third parties
Your personal data may be disclosed to third parties for the purpose of providing their products and/or services to ASML or vice versa. When we transfer personal data to third parties, we will only do so under strict confidentiality obligations and where necessary, we will have an agreement concerning the processing of your personal data in place. We may disclose your personal data to the following categories of third parties, including but not limited to:  

 

  • Agencies and consultants that may assist us in performing our business processes; and
  • IT service providers, including providers of infrastructure, cloud services, software solutions, and cybersecurity tools. 

 

Your personal data may also be disclosed to competent public authorities, governments, regulatory or fiscal agencies where it is necessary to comply with rules or regulations to which ASML is subject. Additionally, we may disclose your personal data to third parties at your direction and we may also disclose your personal data when we believe disclosure is necessary to comply with the law or to protect the rights, property, or safety of ASML, its customers, or others.  

ASML does not sell your personal data or disclose it for cross-border behavioral advertising to anyone. 

 

International transfers of your personal data

Due to our company’s multinational nature, the data we process about you may be transferred to, or accessed by, ASML, our affiliates and trusted third parties from different countries around the world. Your personal data will only be transferred to a country other than your country of residence if this is necessary for the fulfilment of the purposes described in this Privacy Notice.

 

When you are located in the EEA, we only transfer your personal data to countries based on transfer mechanisms as detailed in the table below, including but not limited to the following countries. This table does not apply to other regions: 

Transfer Mechanism CountriesDownload
1. An adequate level of data protection is provided based on a decision
adopted by the European Commission; or

Israel, Japan, Republic of Korea, United Kingdom,
United States (for organizations participating in
the EU-US Data Privacy Framework), Canada, Switzerland 

The list of countries which the European Commissionhas recognized as providing adequate protection

2. An instrument covers the requirements for the transfer of personal data,
including:   

a. Standard Contractual Clauses; 
b. ASML’s approved Binding Corporate Rules; 
c. Codes of conduct; and 
d. Certification mechanisms; or 

United States (for organizations not participating in
the EU-US Data Privacy Framework), China, Malaysia,
Singapore, Taiwan, India 
Standard Contractual Clauses

3. Where the transfer is otherwise permitted under applicable
data protection laws. 

8. How long will we keep your personal data?

Your personal data will be retained only for as long as necessary to fulfill the purposes outlined in Section 6 above, and to comply with any applicable legal, regulatory, or contractual obligations. Once the relevant retention period has ended, your data will be securely deleted, destroyed, or irreversibly anonymized to prevent unauthorized access or use.
 

The specific duration for which your data is retained is determined by a combination of the following factors: 
 

  • Legal and regulatory requirements: Compliance with applicable laws, regulations, and government directives that mandate specific retention periods.
  • Contractual obligations: Commitments arising from agreements with business partners that require data to be retained for a defined period.
  • Business and operational needs: Requirements related to the continuity of services, customer support, dispute resolution, audits, and internal reporting.
  • Technical constraints and system capabilities: Limitations or capabilities of the systems used to store and manage data, including backup and archival processes.
  • Data sensitivity and risk: The nature and classification of the data, including whether it contains sensitive or high-risk information that may require shorter retention or enhanced protection. 

 

If you accept an offer of employment by us, any relevant personal data collected during your pre-employment period will become part of your personnel records and will be subject to our Privacy Notice for Workers.  

9. How is your personal data secured?

We take adequate measures to protect the confidentiality, integrity and availability of your personal data. The implementation of appropriate technical, physical and organizational measures protects your personal data against the following instances: 

 

  • Accidental or unlawful destruction;
  • Accidental loss, damage, alteration;
  • Unauthorized disclosure or access; and
  • Any other forms of unlawful processing (including, but not limited to improper use). 

 

We have procedures in place to deal with any (potential) personal data breach. You and the relevant data protection authorities will be notified of a personal data breach, where we are legally required to do so.  

10. What about your rights?

Where provided under the applicable law, you have rights in relation to your personal data, such as: 

 

  • The right to access the personal data we have about you;
  • The right to know how we process your personal data;
  • The right to obtain information on the instruments implemented in the context of international data transfers set forth in Section 7;
  • The right to have your personal data corrected;
  • The right to have your personal data deleted (‘right to be forgotten’);
  • The right to restrict processing of your personal data by us;
  • The right to object to automated decisions;  
  • The right to withdraw consent at any time and without detriment;
  • The right to object to certain data processing operations;  
  • The right to request a transfer of your personal data (‘right to data portability’);  
  • The right to copy, correct, delete your personal data by your relative in case of your death (if applicable); and
  • The right to obtain compensation if the data subject has suffered damage. 

 

If you feel we are not handling your request appropriately you also have the right to lodge a complaint with the relevant data protection authority. 

 

How to Exercise Your Rights

If you wish to exercise any of these rights, please use our Privacy Rights Request Form, which can be found on the privacy section of www.asml.com. Alternatively, you may email privacyoffice@asml.com. Some countries in which ASML operates require a single point of contact to address your requests or questions. When sending your request to privacyoffice@asml.com, we will forward that question or request to the person located in your region. 

 

We will always check your identity to ensure that it is you exercising your rights. To verify your identity, we match personal data that you provide to us against personal data we maintain in our files. The more risk entailed by the request (e.g., a request for specific pieces of personal data), the more items of personal data we may request to reduce the risk that someone might try to impersonate you. If we cannot verify your identity to a sufficient level of certainty to respond to your request, we will let you know promptly and explain why we cannot verify your identity and what further information we might need from you in order to be able to properly verify your identity and comply with your request.
 

When exercising your right, the more specific you are, the better we can assist you with your request. In some cases, where permitted by law, we may deny your request, in which case we will notify you of the reason for denial.  

 

ASML’s Non-Discrimination and Non-Retaliation Policy

 

ASML will not unlawfully discriminate or retaliate against you for exercising your rights. 

 

Authorized Agents of California Job Applicants

 

If an authorized agent submits a request to know, correct, or delete on your behalf, the authorized agent must submit with the request either (a) a power of attorney that is valid under California law, or (b) document signed by you that authorizes the authorized agent to submit the request on your behalf.  In addition, we may ask you to follow the applicable process described above for verifying your identity. You can obtain an “Authorized Agent Designation” form by contacting us at privacyoffice@asml.com

11. What about your responsibilities?

We would like to kindly remind you that you are responsible for providing us with accurate, complete and up-to-date data. In case you provide us with the personal data of other individuals, such as references, you must comply with (local) legal and ASML requirements, including informing the individuals concerned sufficiently about the processing of their data, by providing them with this Privacy Notice and obtaining their agreement before disclosing their personal data to us. 

12. How to contact us

When you have a question about the use of your personal data or about this Privacy Notice we invite you to send an email to our Privacy Office via privacyoffice@asml.com.

 

For job applicants at ASML Berlin GmbH, the Controller with respect to the processing of your data is ASML Berlin GmbH (Waldkraiburger Straße 5, Waldkraiburger Straße 5, 12347 Berlin, Germany). If you want to address your enquiry directly to our German Data Protection Officer, you can also send your email to privacyoffice@asml.com for the attention of our German Data Protection Officer (please add “attn. German DPO” or similar in the subject line of your email).

 

This Privacy Notice may be amended from time to time. You can find the previous versions of the Privacy Notice in the Privacy Notice Archive. 

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