PRIVACY NOTICE FOR JOB APPLICANTS OF SOFOSERVE LIMITED

This Privacy Notice refers to hiring activities of Sofoserve Limited, its subsidiaries and affiliates (jointly referred to as Sofoserve Limited or we, us, our, or similar derivatives). 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 or you and any derivatives thereof).

The purpose of this Notice is to explain to the you and other data subjects which personal data we gather, which principles apply, which legal basis for processing we rely on, how your personal data is processed, transferred and how long it is retained for. We will also provide you with information on your rights with regards to your personal data.

We are a "data controller" in relation to your personal data. This means that we are responsible for deciding how we hold and use personal information about you.

We may engage other persons to process your personal data on the basis of our instructions – “data processors”.

Definitions

• Data controller or Controller: a person which determines the purposes and means of the processing of personal data.
• Data processor: a person which processes personal data on behalf of the Controller.
• Data subjects: (1) Candidates; (2) Third parties, providing references (i.e. former employers)
• GDPR: General Data Protection Regulation, or Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.
• Personal data: means any information relating to Data Subject which may make them identifiable.
• Process or processing: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Principles of Data Processing

The following principles shall apply to our processing of your personal data:

• Your personal data will be used lawfully, fairly and in a transparent way.
• Your personal data will be collected only for specified, explicit, legitimate, and limited purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Your personal data shall be adequate, relevant and limited to what is necessary in relation to those purposes.
• Your personal data will be accurate and kept up to date; inaccurate personal data will be erased or immediately rectified.
• Your personal data will be kept only as long as necessary for the purposes we have told you about.
• Your personal data will be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

Which Personal data is collected?

Your contact details:

• Last name, first name, other names or preferred names (if applicable)
• Country and city of your location
• Telephone number, primary e-mail address, social media (if applicable)

Other personal details:

• Gender, salutation, date of birth

Education and trainings information:

• Information about academic educational background, degrees, diplomas, certificates, majors and minors, dates of attendance
• Information on trainings attended and professional examinations passed
• Information on language skills, relevant certificates

Professional experience:

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

Job preferences:

• Job openings you are interested in
• 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 by the means of correspondence or phone calls, during interviews
• CCTV recordings (if visiting offices of Sofoserve Limited for an on-site interview).

Collection of sensitive information

We do not collect sensitive types of personal data (i.e., sexual orientation, religious beliefs, or political affiliation).
We do not envisage that we will process information about criminal convictions.

If case 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 we process your personal data?

We will rely on four legal grounds to collect, store, transfer or otherwise process your personal data:

• processing is necessary to take necessary steps prior to entering into a contract (1);
• processing is necessary for compliance with our legal obligation (2);
• processing is necessary for the purposes of the legitimate interests pursued by Sofoserve Limited (3);
• your consent to the processing of your personal data for one or more specific purposes (4).

Here are the examples of purposes of data processing and how they match the legal grounds:

When you have given your consent and intend to revoke it, you shall contact privacy@skadireveries.com. Please be advised, that we do not require your consent if we use your Personal Data to carry out our legal obligations or exercise specific rights vested in by law.

How do we collect your personal data?

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
• Recruitment agencies, from which we collect your CV and contact information
• Your named referees
• Your publicly available profiles published at professional platforms: LinkedIn, Behance, ArtStation, HeadHunter.ru, Rabota.by and etc.

If you fail to provide personal information

If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require references for this role and you fail to provide us with relevant details, we will not be able to take your application further.

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 data?

We may share and / or transfer your personal data in the following cases:

• Internally. We will disclose your personal data with personnel involved in our hiring and recruitment processes (both employees and external contractors).
• Affiliates. We may share your personal data with subsidiaries, affiliates, and companies under common control with Sofoserve Limited.
• Third-party service providers. We may share your data with our third-party service providers in connection with provision of the services related to recruitment and talent acquisition (i.e., our ATS system, email service providers, internal communication systems and messengers). We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
• Public authorities. Your personal data 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 data 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 Data with entities located outside the European Economic Area. It may be in our legitimate business interest to transfer your personal data to a country that does not provide the same level of personal data 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 security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

These measures include:

• We use services that provide encryption and antivirus protection
• We rely on a software that uses user authentication systems and provides for multifactor authentication
• We apply least privileges rule for user access rights
• We keep centralized event logs for data breach incident detection
• We implement role-based access control
• We carry out DPIAs when processing activity results in a high risk for the data subject
• We perform access review for leaving or changing position personnel
• We perform planned and unscheduled data audits
• We organize employees training
• We have implemented written policies and procedures to ensure our compliance with GDPR and other applicable laws
• We request external advice when necessary.

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 on our instructions and they are subject to a duty of confidentiality.

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 store your information?

We will retain your personal information for a period of 5 years after we have communicated to you our decision about whether to appoint you to role. 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 laws and regulations.

If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.
• Withdraw consent. Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely
• If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, request that we transfer a copy of your personal information to another party, or withdraw consent to processing, please send an enquiry to privacy@skadireveries.com.
• Your requests and grievances will be considered free of charge. We will take appropriate efforts to resolve your issues within one (1) month, unless the law established lesser deadlines, in which case we will inform you of such in writing.

In case your grievances are not resolved, you may lodge a complaint to the Commissioner for Personal Data Protection
(http://www.dataprotection.gov.cy/, commissioner@dataprotection.gov.cy)

Contact us

Sofoserve Limited, a company duly established and operating in the Republic of Cyprus, having its registered offices at Anastasiou Sioukri, 1, THEMIS COURT, Floor 4, Flat/Office 402, 3105, Limassol, Cyprus which is a controller of your personal data.

If you have any questions regarding this Notice or other data protection or privacy matters, please send an enquiry to privacy@skadireveries.com.