PERSONAL DATA PROTECTION INFORMATION PROVIDED BY THE DATA CONTROLLER ON THE PROTECTION OF PERSONAL DATA OF JOB APPLICANTS In fulfilling the information obligations regarding the protection of personal data, resulting from 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 (General Data Protection Regulation) (OJ L of 2016, No. 119, p. 1 as amended) (GDPR), in connection with the recruitment procedure with your participation, Clariter S.A. with registered office in Luxemburg provides the following information: 1. WHO CONTROLS YOUR PERSONAL DATA? The controller of personal data which you have provided, that is the entity that determines the purposes and ways of their processing, is Clariter S.A. with its registered office in Luxembourg, having its principal place of business at 2, rue Ste Zithe, L-2763 Luxembourg, holding the number in the Commercial and Companies Register B162627, TIN LU32086621, website address www.clariter.com, email address: info@clariter.com. For simplicity, the data controller is hereinafter referred to as the Clariter. 2. HAS CLARITER APPOINTED A DATA PROTECTION OFFICER? Clariter has not appointed a data protection officer since the GDPR does not require Clariter to do so. 3. FOR WHAT PURPOSE DO WE PROCESS PERSONAL DATA? The data will be processed: a) in order to conduct the recruitment proceeding by Clariter, due to the need to fulfill a legal obligation imposed on Clariter as a possible employer (due to local labor law provisions) (Article 6 (1) (c) of GDPR); If you want to voluntarily provide your data to a greater extent than indicated in regulations (e.g. photo, private telephone number, private e-mail address and others) or for the purposes of future recruitments, please give your consent to their processing in accordance with the clause published on the recruitment platform. Providing data in a broader scope, as well as consent to the processing of data for the purposes of future recruitments, is neither a necessary condition to participate in a specific recruitment process, nor does it affect its result. aa) If you have provided us with more of your data than required by the provisions of the labor law, the basis for the processing of this data is your consent (Article 6 (1) (a) of GDPR). b) in order to consider the execution of a contract other than an employment agreement, in particular a service agreement or a contract similar to that. The basis for data processing is then Article 6 (1) (b) of GDPR; c) for purposes resulting from the legitimate interests pursued by Clariter in the form of providing the necessary staff for its businesses (Article 6 (1) (f) of GDPR). The processing of your personal data is in each case legally justified. 4. ARE YOUR PERSONAL DATA SHARED WITH OTHERS? Clariter may share processed personal data with: (i) an employment agency cooperating with Clariter, (ii) an ICT service provider for Clariter or its affiliate, (iii) its affiliate. Clariter also warrants that the processing of personal data by the specified entities will be based on guarantees of implementation of appropriate technical and organisational measures to ensure that the processing complies with legal requirements and protects your rights. 5. HOW LONG DOES CLARITER PROCESS YOUR DATA? Clariter will process your personal data: a) until the recruitment process is completed, or b) if you agreed to participate in future recruitments - by the end of the calendar year following the year in which the processing of your data began, however, if Clariter's processing of data commenced in the last quarter of the calendar year, the processing period is extended to the end of the following calendar year (two years after the end of the year in which the processing of your data began). If you have withdrawn your consent to the processing of personal data, this data will be processed only until the end of the calendar month in which the consent was withdrawn. 6. WHAT REQUESTS CAN BE ADDRESSED TO CLARITER AS REGARDS YOUR PERSONAL DATA? The data subject has the right to request from Clariter: (a) access to their own personal data, (b) rectification of any inaccurate data, (c) erasure of data, (d) restriction of data processing, as well as the right (e) to object to the processing. We also have an obligation to notify you of any personal data breach if this results in a high risk to your rights or freedoms. The aforementioned rights will be exercised in accordance with the legal requirements, including the provisions of the GDPR. Please note, however, that we will also have to take into account, in each case, our rights and obligations as the controller. If you wish to exercise the above-mentioned rights, please contact Clariter or send a request to Clariters address by traditional mail or via email. Contact details are provided at the beginning of this information. 7. CAN YOU LODGE COMPLAINTS AGAINST US? A complaint can be lodged with the supervisory authority that is independent and that monitors the application of the act on the protection of personal data in order to protect the fundamental rights and freedoms in relation to the processing and facilitation of the free flow of personal data within the European Union. Find your National Data Protection Authority here: https://edpb.europa.eu/about-edpb/board/members_en 8. IS PROVISION OF PERSONAL DATA VOLUNTARY? As a rule, provision of data is voluntary, but without the data it is impossible to properly implement the recruitment process. In terms of data that the employer may request from the future employee - please read the information contained in point 3 above. 9. IS THERE ANYTHING ELSE TO BE ADDED? Due to its capital group structure Clariter intends to transfer your personal data outside European Economic Area (EEA) to a third country i.e. Israel which is recognized by the European Commission as providing adequate level of protection. In accordance with GDPR such a transfer does not require any specific authorization. Personal data will not be used to make an automated decision, including profiling, or automated data processing, which consists of using personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning the economic situation, health, personal preferences or interests, reliability or behaviour, location or movement. Clariter will not use your personal data for marketing purposes.