Beeline Candidate Privacy Notice - December 2024

When you apply to work with Beeline.com, LLC or any of its subsidiaries or affiliates (collectively “Beeline”), we will
collect the personal information contained in and acquired in conjunction with your application. In this case, we
are a "data controller.” This means that we are responsible for deciding how we hold and use personal information
about you.

Beeline is committed to complying with the applicable data privacy and security requirements in the countries in which it operates including, but not limited to, the EU and UK General Data Protection Regulations (collectively “GDPR”), the California Consumer Privacy Act (“CCPA”), and the California Privacy Rights Act (“CPRA”), (collectively, “Applicable Data Protection Laws”.) The term “personal information” used throughout this notice will apply to information that relates to or can be used to identify you as determined by Applicable Data Protection Laws.

This notice provides applicants (whether for an employee or intern position) with information about the personal information we collect, how and why your personal information will be used, and how long we will retain it. It also provides you with certain information that we are required to provide you under Applicable Data Protection Laws.

Your personal information will be processed for the purposes of managing our recruitment and hiring-related activities, which include assessing your skills for a position, setting up and conducting interviews and tests for applicants, evaluating and assessing the results thereto, conducting reference and/or background checks, and as is otherwise needed in the recruitment and hiring processes. We process your information as necessary for our legitimate interests (that is, the solicitation, evaluation, and selection of applicants for employment or engagement) or where we have your consent to do so.

This notice does not form part of any contract of employment or engagement, does not confer any employment status on you and does not confer any contractual right on you or place any contractual obligation on Beeline. In the event that you are offered and accept employment with Beeline, your personal information processed under this notice will become a part of your employment record which shall then be subject to Beeline’s Employee Data Privacy Notice.

I. Data protection principles
We will comply with Applicable Data Protection Laws and their principles, which means that your personal information will be:

• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Retained only as necessary for the purposes we have told you about.
• Kept securely.

II. How personal information is collected about you

In connection with your application for work with us, we will collect your personal information from you, from recruitment agencies (who may provide us with information such as CVs, and your named references.) We gather, store, and use personal information about you that you provide:

• To us in your resume, curriculum vitae, cover letter, and/or writing sample;
• To any of Beeline’s hiring partners.by use of their website or other means such as LinkedIn;
• On our application form;
• During an interview;
• Through a third party including social media platforms;
• From test results or writing samples (where applicable); and

We also gather, store, and use personal information about you that your references provide to us during a reference check or background check (where permitted by applicable law.)

In some cases, we may perform a background check, subject to applicable local laws. When we do that, we may collect the following categories of information from a background check provider: name, title, address, telephone number, personal email address, date of birth, employment history, national ID, social security number, references, education. Section IV, below, provides more information about the "special categories" of Sensitive Personal Information we may collect, use and store.

III. Information Beeline collects

The categories of personal information that Beeline collects include:

• Application information: Name, address, contact details, recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process), previous employment background, education history, professional qualifications, language and other relevant skills, professional certifications including certification expiration dates, veteran status, background checks where permitted by law (including official checks by third parties or similar and through Google or social media searches).
• Interview information: As a part of the interview process we may capture CCTV footage from systems in place at our office location(s). CCTV is used for the safety and security of our staff, visitors and property. For interviews conducted remotely our systems will capture audio, video, system access requests, system access rights and access logs, information required to access Beeline and third party systems and applications such as credentials, system ID, email account, IP address, device ID, and hashed system passwords.
• Sensitive information. Please note that that we collect, store and use the following sensitive or special categories of more sensitive personal information for specific purposes, such as to accommodate a disability or illness during the application or interview process, and we collect diversity-related personal data (such as gender, race or ethnicity) solely in order to comply with legal obligations and internal policies relating to diversity and anti-discrimination. Please be assured that we will only use such sensitive data for the purposes set out in this notice and as provided by applicable law. Sensitive information will never be sold or used for the purpose of inferring characteristics about our applicants.
o Information about your race or ethnicity and your gender;
o Information about your health, including any medical condition or disability, health and sickness records, and
o Information about criminal convictions and offenses (where permitted by applicable law.)

IV. How we will use information about you

We will use the above-described categories of personal information we collect about you to:

• Assess your skills, qualifications, and suitability for the work in the applicable jurisdiction(s).
• Carry out background and reference checks as appropriate and in accordance with applicable laws.
• Communicate with you about the recruitment process.
• Determining the terms under which you will work for us.
• Keep records related to our hiring processes.
• Comply with legal or regulatory requirements.

We may use your information to re-engage with you for future employment opportunities.

V. If you fail to provide information

If you fail to provide information when requested, and that information 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 a credit check or references for a certain role and you fail to provide us with relevant details, we will not be able to take your application further.

VI. Automated decision making
Automated decisions are defined as decisions about individuals that are based solely on the automated processing of data and that produce legal effects that significantly affect the individuals involved. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

VII. How we may share your personal information
We share the above-described personal information within Beeline and with third-party service providers for business purposes. Service providers help us manage our recruiting and hiring processes, communicate with applicants, schedule interviews, and, when appropriate, conduct background checks. More specifically this processing activity includes:

Activity carried out by service provider
Application tracking system
Data storage
Onboarding system (if hired)
Communication tools (e.g., Teams, Outlook)
System security tools and applications
Background checks (where permitted by law)
Financial, tax and privacy/security audits
Expense reimbursement system
Travel reservations and scheduling

When you submit your personal information to any Beeline entity outside the United States, your personal information will be transferred to Beeline.com, LLC in the United States. This transfer will be subject to appropriate additional safeguards under either the EU_UK standard contractual clauses.

All of our third-party service providers and Beeline entities are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal information for their own purposes or to sell your personal information. We only permit them to process your personal information for specified purposes and in accordance with our instructions in support of the recruiting process.

Beeline will not “sell” candidate personal information or “share” candidate personal information for the purposes of conducting behavioral or targeted advertising, as “sell” and “share” are defined under Applicable Data Protection Law.

VIII. How we secure your information

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors, and other third parties who have a business need-to-know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. Details of these measures may be obtained from security@beeline.com.

IX. How long we keep your information

Beeline will retain your personal information for a reasonable period, taking into account legitimate business needs to capture and retain such information. Information will also be retained for a period necessary to comply with state, local, federal, or country specific regulations and requirements, and in accordance with Beeline’s data retention schedule.

In some circumstances we anonymize your personal information so that you are no longer identifiable, in which case we use such information without further notice to you.

X. Your rights

Under Applicable Data Protection Laws, you have certain rights regarding your personal information as follows:

• Access: You have the right to request to access personal information that Beeline holds about you.
• Rectification: You have the right to ask us to rectify personal information Beeline holds about you if it is inaccurate or not complete.
• Erasure: You can request that Beeline erase your personal information if such data is no longer necessary for the purpose for which it was collected or processed, or if you believe personal information has been unlawfully processed. We will keep basic data to identify you and retain it solely for preventing further unwanted processing.
• Restrict Processing: You have the right to ask Beeline to restrict how we process your personal information. This means we are permitted to store that information but not further process it. We keep just enough personal information to make sure we respect your request to restrict processing in the future.
• Object to Processing: Where processing is based on legitimate interests, you have the right to object to Beeline processing your personal information. Beeline will discontinue processing your personal information unless we can demonstrate compelling legitimate grounds for the processing. We will keep basic personal information to identify you and retain it solely for preventing further unwanted processing.
• Portability: Where processing is based on consent or performance of a contract (where applicable in your jurisdiction), you have the right to data portability. Beeline must allow you to obtain and reuse your personal information for your own purposes in a safe and secure way without this effecting the usability of your personal information. This right only applies to personal information that you have provided to Beeline as a data controller.
- Subject to legal considerations or certain exemptions, we may not always be able to address your request, for example if it would impact the duty of confidentiality we owe to others, if we are legally entitled to deal with the request in a different way, where we are legally required to maintain or report your personal information, or where we are processing your personal information for employment purposes.
- Please note that we may be required to ask you for further information in order to confirm your identity before we provide access to the information requested. This is an appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
- You will not ordinarily be required to pay a fee to access your personal information (or to exercise any of the other rights afforded you under Applicable Data Protection Laws), but we may charge a reasonable fee for any additional copies of the materials we provide. Where your request is manifestly unfounded or excessive but within the bounds of the rights afforded under Applicable Data Protection Laws, excluding any exceptions noted therein, we may also charge a reasonable fee.
• Please contact privacy@beeline.com to request access, rectification, or erasure, or to restrict processing, to object to processing, or to request data portability or you may write to us at the following address: 5011 Gate Parkway, Building 100, Suite 250, Jacksonville, FL 32256 USA.

XI. Your obligation to inform us of changes

We strive to maintain your personal information in a manner that is accurate, complete and up to date. However, you are required to inform Beeline of any relevant change in your personal information.

XII. Third party websites or other services

You may choose to provide us with access to certain personal information maintained by third parties such as social media platforms. The information we may receive varies by site and is controlled by the operator of the site and your privacy settings thereon. We are not responsible for the privacy practices of any non-Beeline operated websites, mobile apps or other digital services, including those that may be linked through Beeline systems or websites, and we encourage you to review the privacy policies or notices published thereon.

XIII. Third party data access requests

Where Beeline receives a request to disclose personal data from law enforcement or regulators, Beeline will carefully validate these requests, including reviewing the legality of any order and challenging the order if there are grounds under the law to do so before any personal data is disclosed. Where personal data is disclosed, Beeline will limit the scope of the personal data shared to that which is required under the request.

XIV. Contact us

If you have a questions, concern or complaint regarding this notice please contact us at humanresources@beeline.com.

XV. Right to lodge a complaint

In accordance with certain Applicable Data Protection Laws, if we are not able to satisfactorily resolve your questions, concerns, or complaints, or if you believe that the processing of your personal data infringes on your rights as set out above, you have the right, without prejudice to any other administrative or judicial remedies, to lodge a complaint with a supervisory authority, in particular, in the Member State of your habitual residence, place of work or place of the alleged infringement.