Recruitment Privacy Notice

The Privacy Notice is issued on behalf of the Adverity Group affiliated company indicated in the job advertisement, which acts as data controller of your personal data. For the purposes of this Privacy Notice, when we use “We”, “Us”, “Our” or “Adverity”, we are talking about the Adverity affiliated company indicated in the job advertisement.

The Adverity Group is made up by different affiliated companies spread around the world. You can read more about the Adverity Group, its affiliated companies and their respective contact details here: https://www.adverity.com/about.

We are committed to protecting and respecting your privacy. This Privacy Notice (together with any other documents referred to herein) sets out the basis on which the personal data collected from you, or that you provide to Us, will be processed by Us in connection with Our recruitment processes. Please read the following carefully to understand Our views and practices regarding your personal data and how We will treat it.

We use Workable, an online application provided by SMPC, 95-97 Leoforos Kiffisias, 15125 Marousi, Greece, to assist with Our recruitment process. We use Workable to process personal data as a data processor on Our behalf. Workable is only entitled to process your personal data in accordance with Our instructions.

Where you apply for a job opening posted by Us, these Privacy Notice provisions will apply to Our processing of your personal information in addition to Our other Privacy Notice which has been provided to you separately or is available on Our Website.

Where you apply for a job opening via the application function on a job site or similar online service provider (“Partner”), you should note that the relevant Partner may retain your personal data and may also collect data from Us in respect of the progress of your application. Any use by the Partner of your data will be in accordance with the Partner’s Privacy Notice.

Your Personal Information

Information We collect from You

We collect and process some or all of the following types of information from you:

• Information that you provide when you apply for a role. This includes information provided through an online job site, via email, in person at interviews and/or by any other method.

• In particular, We process personal details such as name, email address, address, telephone number, date of birth, qualifications, experience, information relating to your employment history, skills experience that you provide to Us, as well as your video in case you conduct your interview using the Video Interview feature.

• Audio and video recordings of interviews, where you have agreed to the recording.

• Transcripts generated from recorded interviews.

• Interview notes and recruiter comment

• Competency assessments, evaluation results and fit ratings.

• AI-generated interview summaries and any recruiter edits or corrections.

• Interview metadata, such as the date, time and participants.

• If you contact Us, We may keep a record of that correspondence.

• A record of your progress through any hiring process that we may conduct.

• Details of your visits to Adverity’s Website as indicated in Adverity`s Website Privacy Notice.
• Details of your visits to Workable`s Website including, but not limited to, traffic data, location data, weblogs and other communication data, the site that referred you to Workable`s Website and the resources that you access.

Information We Collect From Other Sources

Workable provides Us with the facility to link the data you provide to Us, with other publicly available information about you that you have published on the Internet – this may include sources such as LinkedIn and other social media profiles.

Workable’s technology allows Us to search various databases – some publicly available and others not, which may include your personal data (including your CV or Resumé), to find possible candidates to fill Our job openings. Where We find you in this way we will obtain your personal data from these sources.

We may receive your personal data from a third party who recommends you as a candidate for a specific job opening or for our business more generally.

Uses Made Of Your Information

Lawful basis for processing

We rely on either your consent, if applying to us directly, or our legitimate interest in case of active sourcing, as the lawful basis on which We collect and use your personal data. Our legitimate interests are the recruitment of staff for Our business.

Where you apply for a job opening through the Indeed Apply functionality, we rely on your consent, which is freely given by you during the application process, to disclose your personal data to Indeed on the basis described below.

Where you choose to join our Talent Pool, we rely on your consent to retain and use your personal data for this separate purpose. Your decision to join the Talent Pool is optional and does not affect your application for any role.

Purposes of processing

We use information held about you in the following ways:

• To consider your application in respect of a role for which you have applied.
• To consider your application in respect of other roles.
• To retain your personal data and contact you about future roles that may be relevant to your skills and experience where you have separately consented to join our Talent Pool.
• To communicate with you in respect of the recruitment process.
• To conduct and, where you have agreed, record and transcribe interviews, prepare interview notes and summaries, assess your suitability against job-related criteria and document recruitment decisions.
• To enhance any information that we receive from you with information obtained from third party data providers
• To find appropriate candidates to fill Our job openings.
• To help our service providers (such as Workable and its processors and data providers) and Partners (such as the job sites through which you may have applied) improve their services.
• To create your employee profile in Personio and support your onboarding and employment administration if you are hired. For this purpose, when you are moved to the ‘hired’ stage in Workable, we transfer your first name, last name and personal email address, together with the title, location and department of the role, to Personio. We do not transfer CVs, interview notes, ratings or attachments as part of this process.

Use of artificial intelligence tools in recruitment

We use artificial intelligence (AI) tools to support certain recruitment activities. For sourced prospects, AI tools may help compare publicly available professional profiles against job-related criteria, prepare short summaries or indicative fit ratings. For applicants, AI tools may help summarise CVs, applications and interview transcripts against job-related criteria or competencies. These tools assist Our Talent Acquisition team only. An Adverity recruiter reviews the relevant output and makes all decisions about whether to contact, progress or reject a person. We do not make decisions producing legal effects, or similarly significantly affecting you, solely by automated means. We do not ask the AI tools to assess special-category information, or to infer or assess emotions, mood, tone or sentiment. For sourced prospects, We rely on Our legitimate interest in identifying and recruiting suitable people. For applicants, We rely on the lawful basis described in the “Lawful basis for processing” section above. Further details about these legal bases and your rights are set out in this Privacy Notice.

Recording is optional. If you do not agree to recording, this will not adversely affect your application and the interview may proceed without being recorded. Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

Automated decision making/profiling

We may use AI-powered tools, including Workable’s technology, to support Our recruitment processes, including sourcing, screening and interview assessment. These tools may identify or prioritise people for Our Talent Acquisition team to consider based on job-related criteria identified by Us. Adverity does not make recruitment decisions based solely on automated processing. A recruiter reviews the relevant information and makes and owns every decision to contact, progress or reject a prospect or applicant. For further details, please see the "Use of artificial intelligence tools in recruitment" section of this Privacy Notice.

Disclosure of Your Information

As set out above, we pass your information to the following third party service providers, including Workable, who use it only in accordance with our instructions and as otherwise required by law:

• IT service providers who provide hosting, maintenance and security services to Adverity;
• Workable, an online application tool provided by SMPC, 95-97 Leoforos Kiffisias, 15125 Marousi, Greece;
• Google Workspace (Google Cloud EMEA Limited), including Google Drive, to schedule interviews and to store and retrieve interview recordings, transcripts and related recruitment materials
• Slack (Slack Technologies Ltd, 3rd & 4th Floor, No 1., Central Park (Block G), Leopardstown, Dublin 18, Ireland) in order to facilitate communication within our talent acquisition team;
• Zoom (Zoom Video Communications Inc.), to schedule and conduct interviews and, where you have agreed, to record and transcribe interviews;
• Providers of AI-assisted recruitment tools, including Anthropic (Claude) and Google (Gemini), where used by Adverity to support sourcing, screening, interview assessment or recruitment communications;
• Personio (Personio SE & Co. KG, Rundfunkplatz 4, 80335 Munich, Germany), Adverity’s HR information system, which receives limited personal data of successful candidates after they are moved to the ‘hired’ stage in Workable, for the purposes of onboarding and employment administration;
• Other Adverity affiliated companies (as listed here: https://www.adverity.com/about).

Where you have applied for a job opening through the Indeed Apply functionality, and where you have consented to this disclosure, We will disclose to Indeed certain personal data that We hold, including but not limited to a unique identifier used by Indeed to identify you, and information about your progress through our hiring process for the applicable job opening, as well as tangible, intangible, visual, electronic, present, or future information that we hold about you, such as your name, contact details and other information involving analysis of data relating to you as an applicant for employment (collectively “Disposition Data”). Indeed’s Privacy Notice in respect of Indeed’s use of the Disposition Data is available on Indeed’s website.

Where you have applied to a job opening through another service provider, we may disclose data similar to the Disposition Data defined above to such service provider. The service provider shall be the data controller of this data and shall therefore be responsible for complying with all applicable law in respect of the use of that data following its transfer by Us.

In addition, Adverity may be legally obliged to disclose your personal data if the data are required to assert, exercise or defend legal claims.

If Workable or Adverity wish to use your data in a way that goes beyond that described above, they will first obtain your express consent.

How We store your Personal Data

Security

We take appropriate measures to ensure that all personal data is kept secure including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

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

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do Our best to protect your personal data, We cannot guarantee the security of your data transmitted through any online means, therefore any transmission remains at your own risk.

Where We store your Personal Data

Personal data held in Adverity's own systems is primarily stored on secure servers within the EEA.

Some of Our affiliated companies and service providers, including Workable and providers of AI-assisted recruitment tools, may access, process or store personal data outside the UK or EEA, including in the United States, where this is necessary to provide recruitment, hosting, support or related services. Where Adverity engages a service provider, including AI-based service provider, Adverity contracts with the relevant EU/EEA affiliate of that provider; the provider may nevertheless make onward transfers to its group companies or sub-processors outside the UK or EEA.

Where personal data is transferred to a country that has not been recognised as providing an adequate level of data protection, We use appropriate safeguards required by applicable law. Depending on the transfer, these may include the European Commission's Standard Contractual Clauses, the UK International Data Transfer Agreement or UK Addendum, and supplementary contractual, organisational or technical measures. Where applicable, We may also rely on an adequacy decision, including the EU–US Data Privacy Framework or the UK extension to that framework. Our contracts require service providers to apply equivalent safeguards to onward transfers and to process personal data only in accordance with Our instructions and applicable data protection law.

Please contact Us using the details in the "Contact" section if you would like further information about the safeguards applying to a particular transfer.

How long we keep your Personal Data

If your application is rejected, Adverity will retain your Personal Data as follows:

• For 2 years in our Talent Pool if you have expressly consented to this (you may withdraw your consent at any time by contacting us at dpo@adverity.com;
• For 6 months otherwise, as required by applicable laws.

If your application is accepted and you join Adverity, we will keep your data for the duration of your employment at Adverity and in accordance with statutory law thereafter.

Interview recordings, transcripts, interview notes and AI-generated summaries are retained in accordance with the applicable recruitment retention period stated above. Where consent to recording is withdrawn, Adverity will stop any further consent-based processing and assess whether the recording and transcript must be deleted, subject to any other applicable legal basis or retention obligation.

Additionally, your personal information will be deleted on one of the following occurrences, unless required otherwise by statutory law:

• deletion of your personal information by you (or by another person engaged by you); or
• receipt of a request by you (or another person engaged by you) to us.

Your rights

Under the General Data Protection Regulation and the UK GDPR, you have a number of important rights free of charge. In summary, those include rights to:

• access to your personal data and to certain other supplementary information that this Privacy Notice is already designed to address
• require Us to correct any mistakes in your information which We hold
• require the erasure of personal data concerning you in certain situations
• receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
• object at any time to processing of personal data concerning you for direct marketing
• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
• object in certain other situations to our continued processing of your personal data
• otherwise restrict our processing of your personal data in certain circumstances
• claim compensation for damages caused by our breach of any data protection laws
• where we rely on your consent, withdraw that consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. To withdraw your consent (for e.g. to our Talent Pool), contact us using the Contact details below.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the UK GDPR.

If you would like to exercise any of those rights, please:

• contact us using our Contact details below
• let Us have enough information to identify you,
• let Us have proof of your identity and address, and
• let Us know the information to which your request relates.

How to complain

We hope that We can resolve any query or concern you raise about Our use of your information.

The General Data Protection Regulation and the UK GDPR also gives you the right to lodge a complaint with a supervisory authority, in particular (under the GDPR) in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The contact details of respective supervisory authorities in the EU can be found here and the supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.

Contact

All questions, comments and requests regarding this Privacy Notice should be addressed to dpo@adverity.com or to the Adverity entity indicated in the job advertisement.