Introduction

This privacy notice (the “Notice”) describes the ways that Panda Bluemoon Ltd. and it affiliates (“Company”, “we”, “us”, “our”), the company currently in process of recruiting you as a candidate (“you” or “candidate”), collects and uses your personal information as a candidate (“Candidate Data”).

The Company works with various service providers whom we have instructed to collect, store and process Candidate Data on our behalf for the purposes of recruiting candidates. One of those service providers is Comeet, which we use as a recruiting and applicant tracking platform (“Platform”) in order to handle your Candidate Data as a candidate and describe the rights and options available to you with respect to your Candidate Data, while we remain the responsible party for your Candidate Data when provided to the Platform in the context of your candidacy, and we determine the means and purposes for the processing of your Candidate Data.

Please note that this Notice is provided for transparency purposes only. If you have any questions related to your Candidate Data, you should contact the Company directly.

Categories of Candidate Data

When you apply to a position made available by the Company, the Company will collect and process the following types of Candidate Data:

• Personal Information: such as contact information, email address, home address, information included in your resumé (including information such as skills, work experience, education), notes submitted with the application, URL of your LinkedIn and other online profiles; and
• Information about your candidacy: such as the source who submitted your candidacy (e.g., recruiting agency, referral), email correspondences between you, the Company and between the Company and other sources (such as recruiting agency and referrals) about your candidacy, information from references, events in the lifecycle of your candidacy, your responses to questionnaires sent to you by us, information about your candidacy and employment options (such as availability to be hired and salary expectations), evaluations of your candidacy, internal discussions within the Company about your candidacy, and materials you or other parties (such as evaluators or background check providers) submitted in relation to your candidacy.

If you submit your candidacy directly (e.g., via email), then you are the main source of the Candidate Data. Your Candidate Data can also originate from other sources, such as your LinkedIn profile, recruitment agencies, headhunters and referrals.

Use and Disclosure of Candidate Data

We will use your Candidate Data in accordance with this Notice, and where applicable the Company Employee Privacy Notice, in order to evaluate and consider you as a candidate for various positions within the Company, to contact you to schedule meetings and interviews, and provide updates on your candidacy status.

We will share your Candidate Data with our service providers who assist us to collect, process and store Candidate Data. If your details are submitted to the Company by a third-party (such as an employee of the Company or a recruiting agency), the Company can give the third-party access to your name, photo and some of the general recruitment status.

If you apply to a job opening using a unique referral link that was provided to you by an employee of the Company to which you are applying, the Company may share some of your general recruitment status, without identifying you by name, with the person that provided you the referral link. The purpose of sharing the above information is to operate incentive programs (i.e. employee referral bonus programs) of the Company and to provide feedback to third-parties who submit candidates to the Company regarding their submission.

If we are required to disclose your information by a judicial, governmental and/or regulatory authority to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order.

If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your Candidate Data to such third party (whether actual or potential) in connection with the foregoing events. In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Candidate Data in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company.

International Transfers of Candidate Data

We host your Candidate Data in the European Economic Area and/or in countries deemed as providing an adequate level of data protection. Your Candidate Data will be accessible in the country where we or our service providers are located.

Security and Data Retention

• Retention. We will retain your Candidate Data for as long as we need it to assess you as a candidate, or as long as we have a valid legal basis to do so.
• Security. We implemented industry standard measures to reduce the risks of damage, loss, unauthorized access, or use, of your Candidate Data. However, these measures do not provide absolute information security.

Your Rights

Your rights may vary, depending on the applicable law. These rights may not be available in certain jurisdictions and/or may be subject to certain derogations or limitations. Accordingly. you may have the following rights:

• To ask us to receive a copy of your Candidate Data (or parts thereof) that is stored on our servers, including the Platform;
• to update, correct and/or delete your Candidate Data;
• to request the restriction of processing concerning your Candidate Data or to object the processing of your Candidate Data; and/or
• to lodge a complaint with a supervisory authority.
• If you wish to exercise any of these rights, please contact us. If you choose to exercise any of your rights, we will handle these requests in accordance with applicable law but please note that exercise of some of those rights may have some consequences in your application as a candidate.

Changes to this Privacy Notice

From time to time, we may change or update this Notice. If we do so, we will make efforts to notify you of such changes by any means.

Contact Us

If you have any questions, about this notice or report a concern related to Candidate Data, please contact the Company representative you were in touch with or send an email to: privacy@spinomenal.com.

Last Updated: May 2024