As part of any recruitment process, KeelX Limited (hereinafter called ‘KeelX’) collects and processes personal data relating to job applicants. This personal data may be held by KeelX on paper or electronic format.

KeelX is committed to being transparent about how it collects and uses your personal data, to protecting the privacy and security of your personal data and to meeting its data protection obligations under the General Data Protection Regulation (GDPR).

The purpose of this privacy notice is to make you aware of how and why we will collect and use your personal data information during the recruitment process. We are required under the GDPR to notify you of the information contained in this privacy notice.

This privacy notice applies to all job applicants. It is non-contractual.

What information we may collect about you:

KeelX collects, uses, and processes a range of personal data about you during the recruitment process. This includes:

• Full name
• Date of birth
• Home address
• Contact telephone number(s)
• Email address
• Copy of Passport and/or ID document
• Marital status
• Academic and/or professional qualifications
• Work experience
• Various skills
• Current level of remuneration
• Other background check documentation

KeelX may also collect, use, and process the following special/sensitive categories of your personal data during the recruitment process:

• Information about your racial or ethnic origin
• If you have a disability for which KeelX needs to make reasonable adjustments and/or any other ailment such as epilepsy or diabetes

KeelX may collect this information from various sources e.g., application form, cover letter, curriculum vitae (CV), passport, ID, directly from the applicant, interview assessment forms or any other relevant documents.

Personal data will be stored in various places e.g., application records, HR management systems and other IT systems (including email).

Processing sensitive personal data about you:

KeelX may process and keep sensitive personal data about you, when necessary. If you provide us with unsolicited sensitive personal data, you are consenting to our use of that data subject to applicable law. The term “sensitive personal data” refers to the various categories of personal data identified by European and other data privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent.

These categories comprise personal identity numbers, data about personality and private life, financial account information, racial or ethnic origin, nationality, political opinions, membership of political parties or movements,

religious, philosophical or other similar beliefs, membership of a trade union or profession or trade association, physical or mental health, biometric or genetic data, addictions, sexual life, property matters or criminal record (including information about suspected criminal activities).

Why we process personal data:

We need to process data to take steps at your request before entering an interview and evaluation process with you. We may also need to process your data to enter into a contract with you.

In some cases, we need to process data to ensure that we are complying with our legal obligations i.e. it is mandatory to check a successful applicant's eligibility to work in Cyprus before employment starts.

KeelX has a legitimate interest in processing personal data during the recruitment process and keeping records of this process. Processing an applicant’s data as yours, allows us to manage the recruitment process, assess and confirm their suitability for the position and decide if the applicant will get an offer for the job. We may also need to process data from job applicants to respond to and defend against legal claims.

KeelX may also collect information whether applicants are disabled or not, to make reasonable adjustments for candidates who have a disability. KeelX processes such information to carry out its obligations and exercise specific rights in relation to employment.

Who has access to your personal data:

Your information may be shared internally within the HR team, interviewers, and IT staff members for the recruitment process.

KeelX will not share your personal data with third parties, unless your application for employment is successful. You will be informed about this process (employment’s privacy notice) in the case your application is successful and you have signed a contract of employment.

How we protect personal data:

We take the security of your personal data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.

In addition, we limit access to your personal data only to those employees that are in need to perform their job duties and responsibilities.

KeelX also has in place procedures to deal with a suspected data security breach and will notify the Information Commissioner’s Office (or any other applicable supervisory authority or regulator) and you of a suspected breach where we are legally required to do so.

For how long we keep your personal data:

If your application for employment is unsuccessful, the internal policy of KeelX is to keep your personal data for a year following your application for the recruitment process. In case you have send us your curriculum vitae we will keep it for a year in our records. In both cases if you want us to dispose and delete your personal data, we will follow your instructions upon your request.

As a data subject, you have certain rights under the GDPR:

• Access and obtain a copy of your personal data on request
• Require KeelX to change incorrect or incomplete personal data
• Require KeelX to delete or stop processing personal data, i.e., where the personal data is no longer necessary for processing
• Object to the processing of personal data where KeelX is relying on its legitimate interests as the legal ground for processing
• Require that we cease processing your personal data (e.g., if you choose to withdraw from our recruiting program), although note that we may need to retain certain personal data where required or permitted to under applicable law.

If you would like to exercise any of these rights, please contact our DPO by email at:

dpo@keelx.com

If you believe that KeelX has not complied with your personal data protection rights, you can complain to the Information Commissioner.

Transferring personal data outside the European Economic Area (EEA):

KeelX will not transfer your personal data to countries outside the EEA.

What if you do not provide personal data:

You are under no statutory or contractual obligation to provide personal data to KeelX during the recruitment process. However, if you do not provide such information, we may not be able to process your application properly or at all.

Changes to this privacy notice:

KeelX reserves the right to update or amend this privacy notice at any time. We will issue you with a new privacy notice when we make significant updates or amendments if this is still relevant to you. We may also notify you about the processing of your personal data in other ways.