ПОЛИТИКА КОНФИДЕНЦИАЛЬНОСТИ ДЛЯ КАНДИДАТОВ НА РАБОТУ

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Effective Date: 01 July 2024

This Privacy Notice explains how we, VIZOR APPS LTD, acting as a data controller, our subsidiaries and affiliates (jointly referred to as "VIZOR" or "we", "us", "our", or similar derivatives) process information associated with you as a person ("Personal Information") during our hiring activities. This Privacy Notice is directed at any person who is considered a job applicant, a candidate for a role or is otherwise engaging with us with respect to our hiring process ("Candidate", "you" or any derivatives thereof).

The purpose of this Privacy Notice is to explain to you and other data subjects which Personal Information we collect, which processing principles apply, which legal basis for processing we rely on, how your Personal Information is processed, transferred and how long it is retained. This Privacy Notice also explains your rights with regard to your Personal Information.

We are a data controller in relation to your Personal Information. This means that we are responsible for deciding how and what reasons we store and use Personal Information about you. We may engage other persons to process your Personal Information according to our instructions – data processors.

If you have any questions regarding this Privacy Notice or any other data protection or privacy matters, please send an email inquiry to privacy@vizor-apps.com. You may also contact our Data Protection Officer by email at dpo@vizor-apps.com.

Which Personal Information is Collected?

Your contact details:

• Your full name or preferred referrals (if applicable);

• Country and city of your residence or your location;

• Telephone number, primary email address, messengers contact details (if applicable).

Other personal details:

• Gender, date of birth, marital status.

Education and trainings information:

• Academic educational background, degrees, diplomas, certificates;

• Trainings and professional examinations;

• Additional training information.

Professional experience:

• Legal company names and their brand names (trade names), job titles, job descriptions, achievements, dates of start and of termination of employment.

Job preferences:

• Job openings of your interest;

• Salary, bonuses, and other benefits preferences;

• Office location preferences;

• Preferences for remote / hybrid / office mode of work.

Organizational details:

• Information about your citizenships, residence and work permits obtained.

Other:

• Any other information provided by you in your CV, resume, or cover letter;

• Any information provided by you to us in your correspondence or phone calls, during interviews;

• CCTV recordings (if you are visiting VIZOR's offices in Cyprus for an on-site interview).

Collection of Sensitive Information

We do not collect sensitive types of Personal Information (i.e., sexual orientation, religious beliefs, or political affiliation). We do not envisage that we will process criminal record information.

If you decide to disclose any information about your health, that information will be used for the sole purpose of adjusting the hiring process to meet your needs. We do not require mandatory disclosure of such information and do not retain it.

Why Do We Process Your Personal Information?

We will rely on four legal grounds to collect, store, transfer or otherwise process your Personal Information for the designated purposes:

How Do We Collect Your Personal Information?

We collect Personal Information about candidates from the following sources:

• You, the Candidate.

• An employee who referred you pursuant to our internal referral program, from whom we collect your CV and contact information.

• Your publicly available profiles published on professional platforms, for example such as LinkedIn, Behance, ArtStation and other career networks.

What Will Happen If You Fail to Provide Personal Information

If you fail to provide the requested information which is necessary for us to consider your application (such as evidence of your professional qualifications or employment history), we will not be able to process your application. For example, if we require references for the role and you fail to provide us with relevant details, we will not be able to proceed with your application consideration.

Automated Decision-Making

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

When Do We Share Your Personal Information?

We may share and / or transfer your Personal Information in the following cases:

• Internally. We will disclose your Personal Information to the personnel involved in our hiring and recruitment processes (to both, employees and external contractors).

• Affiliates. We may share your Personal Information with subsidiaries and affiliates.

• Third-party service providers. We may share your Personal Information with our third-party service providers in connection with provision of the services related to recruitment and talent acquisition (i.e., our applicant tracking systems, email service providers, internal communication systems and messengers). We do not allow our third-party service providers to use your Personal Information for their own purposes. We only permit them to process your Personal Information for specified purposes and in accordance with our instructions.

• Public authorities. Your Personal Information may be disclosed to public authorities subject to valid court order, warrant or subpoena.

• Corporate transactions. Your Personal Information may be disclosed or transferred to relevant third parties in the event of, or as part of the due diligence for, any proposed or actual sale, merger, consolidation, joint venture, transfer, or other disposition of all or part of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding). If a corporate transaction occurs, we will provide notification of any changes to the control of your information, as well as choices you may have.

When and where we may transfer your Personal Information to a third-party, we will do so subject to necessary safeguards and precautions, including verifying that the third party has necessary technical and organizational measures in place to ensure compliance with GDPR.

During our ordinary course of business, we may share your Personal Information with entities located outside the European Economic Area ("EEA"). It may be in our legitimate business interest to transfer your Personal Information to a country that does not provide the same level of Personal Information protection (legislation- or enforcement-wise) as EEA countries. Where this is the case, we will rely on appropriate safeguards, including standard contractual clauses as amended from time to time by the European Commission.

Data Security

We have put in place appropriate administrative, technical and physical security measures to prevent your personal information from being accidentally lost, misused, altered, disclosed or accessed in an unauthorized way.

In addition, we provide your Personal Information to employees, contractors and other third parties on a strict ‘need-to-know’ basis. They will only process your Personal Information under our instructions, and they are subject to confidentiality obligations.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

How Long Will We Retain Your Personal Information?

Please be advised that we will retain your personal information for a period of 5 (five) years following the communication of our decision regarding your application. We retain your Personal Information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your Personal Information in accordance with the legal requirements.

If we wish to retain your Personal Information in our HR database so that we can contact you with regard to any future open job positions, we will write to you separately, seeking your explicit consent to retain your Personal Information for a fixed period for the designated purpose.

Your Rights to Your Personal Information

You have the rights to your Personal Information as described below and you can exercise them by contacting us at privacy@vizor-apps.com. We shall consider your request under applicable legal provisions. In case we receive particular requests, we may be obligated to verify such requests and thus, ask you to verify your identity before complying with the request to protect your privacy and security.

You have the right to:

• Access your Personal Information:

Under art. 15 of the GDPR, you have a right of access that gives you the right to obtain a copy of your Personal Information, as well as other supplementary information.

• Rectify (correct) your Personal Information:

Under art. 16 of the GDPR, you have the right to have inaccurate Personal Information rectified.

• Have your Personal Information erased (deleted):

Under art. 17 of the GDPR, you have the right to have Personal Information erased. This is also known as the ‘right to be forgotten’. The right is not absolute and only applies in certain circumstances.

• Restrict processing of your Personal Information:

Art. 18 of the GDPR gives you the right to restrict the processing of your Personal Information in certain circumstances. This means that you can limit the way that we use your Personal Information.

• Transmit your Personal Information:

Under art. 20 of the GDPR, you have the right to data portability that gives you the right to receive Personal Information you have provided to us in a structured, commonly used and machine-readable format. It also gives you the right to request that we transmit those data directly to another controller.

• Object to processing of your Personal Information:

Art. 21 of the GDPR gives you the right to object to the processing of your Personal Information at any time. This effectively allows you to stop or prevent us from processing your Personal Information.

• Withdraw your consent for Personal Information processing:

Art. 7 (3) of the GDPR gives you the right to withdraw your consent for Personal Information processing. Any withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

• Lodge a complaint with a supervisory authority:

In accordance with art. 77 of the GDPR, you, as a data subject, have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or where an alleged infringement of the GDPR has taken place.

If you believe that an infringement of GDPR took place, you may lodge a complaint with a data protection authority. The competent data protection authority for us is the Commissioner for Personal Data Protection (http://www.dataprotection.gov.cy, commissioner@dataprotection.gov.cy).